Manufacturers and exporters of military supplies are experiencing new limitations by United Nations (UN) and United States (U.S.) arms export restrictions. The UN Security Council implemented an arms embargo against Libya in February of 2011. It was created to ensure military supplies were not traded with Libya to impede human rights violations by the Libyan government during the “Arab Spring” protests. In 2014, the UN loosened the trade restrictions when the disputing factions agreed on a National Accord government. Rather than a complete ban, the Security Council required its Sanctions Committee approve any arms provided to Libya. In June 2016, the Security Council required the National Accord government to investigate seagoing vessels off Libya’s coast that might be illicitly exporting weapons and munitions to the Islamic State in Iraq and the Levant (ISIL). This inspection obligation has been periodically extended, most recently through June 2021.

Erik Prince, one of former President Trump’s close allies and founder of the infamous Blackwater private military contractor, allegedly violated this regulation by participating in a failed mercenary plot in Libya, called Project Opus, in 2019. Prince is accused of offering “weapons, drones and mercenaries to a Libyan militia commander seeking to overthrow the government.” In 2020, a panel of UN experts issued a classified report finding that Prince evaded the UN and U.S. arms embargoes in hopes of aiding in the overthrow of the Libyan government. This violation could result in UN-mandated sanctions, including an asset freeze and a travel ban. Prince was not acting alone. Three United Arab Emirates companies also allegedly participated in the organization and finance operations. Sanctions are yet to be imposed.

In addition, Prince’s acts, if proved, would violate the U.S. Arms Export Control Act. This legislation, enacted in 1976, allows the U.S. President to control the exportation of military items. The Act and its administrative provisions, the International Traffic in Arms Regulations (ITAR), require an export license for any exports or reexports of military equipment from the United States.

The United States also restricts the exportation of munitions and dual-use items to Russia. Due to the Russian government’s attempted assassination of an opposition leader by poisoning, on March 2, 2021, the United States implemented a variety of export controls and trade sanctions on Russia, including tightened restrictions of dual-use items under the Export Administration Regulations, stricter ITAR controls on munitions exports, and new trade and economic sanctions on specific Russian companies, government agencies, and government officials, such as the Federal Security Service. The new provisions  affect U.S. business firms that work with the Russian government (e.g., by providing Internet and telecommunications services) and any firms that do business with the sanctioned companies, agencies, and persons. The U.S. Secretary of State explained the restriction as intended to punish “Russia’s use of chemical weapons and abuse of human rights.”