For a compliance policy or screening tool, you need to distinguish between the Source Regimes (where the lists are agreed upon diplomatically) and the Implementation Lists (the actual legal documents you screen against).

Most screening tools ingest the Implementation Lists because those contain the specific codes (ECCNs) and legal definitions used by customs.

1. The “Big Four” (The Source Regimes)

These are the multilateral agreements where experts decide what counts as “dual-use.”

• Wassenaar Arrangement (WA): Covers conventional arms and dual-use goods and technologies (e.g., encryption, sensors, lasers, aerospace). This is the largest and most commercially relevant list.
• Nuclear Suppliers Group (NSG): Covers nuclear material and nuclear-related dual-use equipment (e.g., high-grade graphite, certain machine tools).
• Missile Technology Control Regime (MTCR): Covers delivery systems (missiles, drones) and related technology (e.g., propulsion, guidance systems).
• Australia Group (AG): Covers chemical and biological weapons proliferation (e.g., precursors, fermenters, toxins).

2. The Implementation Lists (What You Actually Screen)

Banks and exporters do not usually screen against the “Wassenaar list” directly. They screen against the national laws that incorporate those regimes.

List Name	Jurisdiction	Description
Commerce Control List (CCL)	USA	Managed by the BIS. Items are identified by an ECCN (Export Control Classification Number). This is the global “gold standard” because of the reach of the US Dollar.
EU Dual-Use Annex I	EU	The consolidated list for all EU member states (Regulation 2021/821). It combines all four regimes above into one document.
UK Strategic Export Control Lists	UK	The “Consolidated List of Strategic Military and Dual-Use Items.” Post-Brexit, the UK maintains its own, though it largely mirrors the EU/Wassenaar.
METI Control List	Japan	Managed by the Ministry of Economy, Trade and Industry. Highly specific for Asian trade corridors.

3. The “High Priority” Subsets (Crucial for 2025/2026)

Because screening millions of transactions against the full dual-use list is difficult (and generates many false positives), regulators have recently published shorter, prioritized lists specifically targeting Russian and Iranian supply chains.

• Common High Priority List (CHPL):
  • Issuers: Jointly identified by the US (BIS), EU, UK, and Japan.
  • Content: This is a subset of about 50 HS Codes (Harmonized System codes) that are essentially “Red Alert” items. It includes microelectronics (integrated circuits), CNC machine tools, and ball bearings.
  • Action: If you are building a tool, flagging these HS codes is the highest priority for immediate risk reduction.

4. The “Data Problem” (HS Codes vs. ECCN)

This is the hardest part of building a screening tool.

• The Mismatch: Dual-use lists are defined by technical specifications (e.g., “Carbon fiber with tensile strength > X”), but bank data usually only has HS Codes (e.g., “6815.10 – Articles of carbon”).
• The Solution: You need a Correlation Table.
  • The European Commission publishes a “Correlation Table” that maps EU Dual-Use codes to Customs CN codes.
  • Warning: It is not 1-to-1. One HS code might contain both controlled and uncontrolled items. This is why “catch-all” screening often produces false positives (e.g., stopping a shipment of tennis rackets because they share an HS code with controlled carbon fiber).