Defence, Dual-Use & Autonomous Systems

Defence, Dual-Use & Autonomous Systems

Defence, Dual-Use & Autonomous Systems

Legal analysis for drones, autonomous systems and dual-use technology — where export controls, sanctions and the limits of the EU AI Act meet.

Who this is for

Developers and suppliers of drones, unmanned and autonomous systems.

Companies whose products, software or know-how may qualify as dual-use.

Defence-sector teams entering EU, NATO or Ukrainian procurement and cooperation projects.

What we do

We assess products, software and technology transfers against the EU Dual-Use Regulation (EU) 2021/821.

We review sanctions exposure, end-user screening and contractual “no re-export to Russia” obligations under Article 12g of Regulation (EU) No 833/2014.

We analyse the scope and limits of the EU AI Act exclusion for AI systems used exclusively for military, defence or national-security purposes (Article 2(3)), including dual-use and mixed-use scenarios.

We address GDPR, NIS2 and Cyber Resilience Act obligations relevant to the product or activity.

We allocate responsibility for development, testing, supply and deployment in project and supply agreements.

Where we add value

Former Director of the Legal Department, Ministry of Defence of Ukraine.

Former Director of the Department of National Security, Ministry of Justice of Ukraine.

Eight years as external consultant to the Verkhovna Rada Committee on Legislative Support of Law Enforcement — direct experience of how Ukrainian security legislation is drafted and enacted.

Working knowledge of how defence technology is procured, tested and deployed in Ukraine — and of the EU rules that apply when it crosses borders.

Typical engagement

1. Establish the technology, intended use, parties and jurisdictions involved.

2. Analyse applicable controls, exclusions, sanctions and contractual exposure.

3. Deliver a written legal briefing with a classification view and open questions for the competent authority.

FAQ

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