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Volume XI, Number 205

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Golden Sentry Program Report for FY2020 – Government-to-Government End-Use Monitoring of Defense Articles and Defense Services

The Golden Sentry Program monitors government-to-government transfers to ensure defense articles and services provided to foreign governments by the U.S. are being used in accordance with the transfer agreements. The program’s goals are to (1) minimize security risks to the U.S. and its allies; and (2) ensure compliance with the U.S. technology control requirements.

There are two types of checks under the program: (1) Compliance Assessment Visits (CAVs); and (2) Focused Verification Checks (FVC).

Defense articles and services currently subject to end-use monitoring under the program:

  • Communications Security (COMSEC) equipment

  • Night Vision Devices (NVDS)

  • Man-Portable Air Defense Systems (MANPADS)

  • Unmanned Aircraft systems

  • Several Types of Missiles

Prior to implementing an end-use monitoring program on the transfer of articles or services, requesting countries may be subject to:

  • Country team assessments evaluating the partner country’s “ability and willingness to protect U.S. technologies” and their intended use of the requested defense items.

  • Releasability, disclosure, and technology reviews conducted by several interagency organizations on the transfers of technology.

Congressional notifications are sent for Congressional approval before any formal offers of transfer are made. A Letter of Offer and Acceptance then initiates the transfer, specifying:

  • Articles or services approved for transfer

  • Any special provisions under the agreement

Signing this letter binds the party to the agreement and end-use monitoring. After transfer of the defense articles or services, the receiving country is subject to routine end-use monitoring and, depending on the nature and sensitivity of the technology, may be subject to enhanced monitoring.

  • In FY2020, the U.S. conducted over 2,000 physical security checks (CAVs) of over 217,000 defense articles through the program.

  • The U.S. plans to conduct CAVs in the following countries in FY 2021: Bangladesh, Canada, Ecuador, Egypt, Ethiopia, Fiji (& Tonga), Italy, Japan, Moldova, Pakistan, Paraguay, Qatar, Saudi Arabia, Servia, Trinidad and Tobago, Ukraine, and Uzbekistan

© Copyright 2021 Squire Patton Boggs (US) LLPNational Law Review, Volume XI, Number 202
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