Compliance & Export Control

Our position

Counter-UAS technology is dual-use by nature. The sensing that protects a water treatment plant is the sensing that supports a targeting cycle. The distinction isn’t in the hardware. It’s in who holds it and what they do with it.

Which makes export control the thing that decides whether a piece of business happens — not an administrative step after it has been agreed. We treat it that way: screening runs before a technical conversation gets specific, not after a quote has been issued.

This costs us deals. We think that’s the correct outcome rather than an unfortunate side effect. A supplier who finds the export problem at the contract stage was not looking, and a supplier who works around it is a liability to every customer they have.

Dual-use control

Parts of the Orionyx portfolio constitute dual-use items within the meaning of Regulation (EU) 2021/821. In Lithuania this is administered through the Law on the Control of Strategic Goods, with the Ministry of the Economy and Innovation as the competent authority.

What that means in practice:

Stage	What happens
Classification	Every item and technology is assessed against the control lists before it is offered, supplied or transferred. Classification is documented, not assumed.
End-use verification	Who receives it, where it goes, what it is used for, and whether it stays there. Documented before supply.
Licensing	Where an authorisation is required, it is obtained before the transfer. Not in parallel with it.
Technology transfer	Controls apply to knowledge as well as hardware — including technical assistance, training and transmission by email. This catches people out regularly.
Records	Retained per the statutory periods and available to the authority on request.

The point most often missed: a detailed technical discussion can itself be a controlled transfer. This is why our early conversations stay at capability level and get specific only once the counterparty is established.

Screening

Before we engage substantively, we establish who we are dealing with. This runs against:

• EU sanctions lists — consolidated financial sanctions, sectoral measures, and territorial restrictions.
• Ownership and control — not just the entity in front of us, but who ultimately controls it. A compliant entity with a sanctioned owner is not a compliant counterparty.
• End use and end user — including whether the stated use is plausible for the stated user.
• Destination — embargoed and restricted destinations, and routes that suggest transhipment.

Screening is repeated periodically for ongoing relationships, because ownership changes and lists change. A counterparty who was clear at contract signature is not thereby clear three years later.

This applies in both directions. Suppliers and partners are screened on the same basis as customers. See Partners.

What happens to your enquiry

Concretely, so there are no surprises:

Enquiries from within the EU proceed normally. We’ll still establish the entity and the intended use, but this is routine rather than a hurdle.

Enquiries with end use outside the EU are reviewed before they are answered substantively. Depending on destination and item, this may be straightforward, may require a licence, or may not be possible. We’ll tell you which, and we’d rather tell you early.

Enquiries from sanctioned destinations are not processed. No exceptions, no creative structuring, no routing through a third country. If this describes you, please don’t waste your time or ours.

Enquiries where the stated use doesn’t fit the stated user get questions rather than a quote. Sometimes there’s a good explanation. When there isn’t, we stop.

On the public website: we publish no specifications, no detection ranges, no effector details. Not because they’re secret, but because publishing them would be a transfer to an audience we haven’t screened. This is also why our capability pages describe what systems do rather than how.

If you’re the customer

Our compliance obligations create some of yours. Worth knowing before we start rather than at contract stage:

• You’ll be asked for an end-use statement. Who operates the system, where, for what. For a licensable item, this is a formal document rather than an email.
• Onward transfer is restricted. You can’t pass supplied items or technology on without checking first. This survives the end of our contract.
• Re-export has consequences. Moving a system to a different country, including within a corporate group, may require a fresh authorisation.
• Training and documentation count. Technology transfer controls cover what we teach your operators, not only what we ship.

None of this is unusual for the sector. It’s listed here because customers new to controlled goods are often surprised by it at the worst moment, and a surprise at contract stage costs everyone weeks.

Authorities

Matter	Authority
Dual-use export control	Ministry of the Economy and Innovation of the Republic of Lithuania (Ekonomikos ir inovacijų ministerija)
Strategic goods coordination	Commission for the Coordination of Strategic Goods Control
Unmanned aircraft operations	Transport Safety Administration (Lietuvos transporto saugos administracija)
Data protection	State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija, VDAI)
Cybersecurity / NIS2	National Cyber Security Centre (Nacionalinis kibernetinio saugumo centras, NKSC)

To complete before publication: where Orionyx holds specific licences, registrations or authorisations, list them here and in the legal notice. If an internal compliance officer or responsible person has been designated, name the role here. Have this page reviewed by counsel admitted in Lithuania before going live — the statements on this page describe commitments, and they should describe ones you can evidence.

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