Evaluated screen

Cluster Munitions Transfer

Identifies entities that knowingly transfer, broker, arrange, or control a change in title, ownership, custody, or control of operational cluster munitions, explosive submunitions, explosive bomblets, or cluster-specific components. Import, export, transportation, sale, and distribution are assessed separately and are not inferred solely from a transfer event.

Type
Evaluated
Version
2026.08.21.2
Published
Aug 21, 2026
Inclusions
6
Exclusions
6
How to read this definition

Inclusion criteria describe evidence that can establish this activity. Exclusion criteria identify circumstances that do not establish it on that basis alone. The evaluation remains connected to its taxonomy version and supporting evidence.

Can establish this activity

Included when supported

Evidence may support involvement when it matches one or more of these inclusion criteria.

6 criteria
  1. 01Criterion

    Direct Transfer of Cluster Munitions

    Defined as: Entities that knowingly transfer or control a change in title, ownership, custody, or control of operational cluster munitions between parties, including state-to-state, grant, lease, donation, or other non-commercial transfers.

  2. 02Criterion

    Brokers or Dealers With a Cluster Munition Transfer Role

    Defined as: Licensed intermediaries that negotiate, arrange, or execute a change in title, ownership, custody, or control of operational cluster munitions. A sale, export, or transportation role without transfer responsibility is insufficient.

  3. 03Criterion

    Contractors With Transfer or Handover Authority

    Defined as: Entities authorized to coordinate or execute the handover of operational cluster munitions as part of a product-specific military assistance, lease, exchange, joint operation, or other transfer arrangement.

  4. 04Criterion

    State-Owned or Government-Authorized Transfer With Verified Activity

    Defined as: Government agencies, military units, state-owned enterprises, or other non-investable entities with entity-specific evidence of arranging or executing a cluster-munition transfer. Government status or approval authority alone is insufficient.

  5. 05Criterion

    Corroborated Cluster Munition Transfer Evidence

    Defined as: Entities for which an authoritative investigation, sanctions or enforcement record, treaty monitor, or other source provides an exact legal-entity, product, transfer role, and time attribution, corroborated by a primary source or another independent authoritative source. List membership alone is insufficient.

  6. 06Criterion

    Transfer of Delivery Systems With an Integrated Cluster Payload

    Defined as: Entities that transfer a rocket, missile, bomb, projectile, or other delivery system as a package containing or configured with a verified operational cluster-munition payload. Transfer of a generic or merely compatible platform is insufficient.

Does not establish this activity on its own

Excluded on this basis alone

These circumstances do not establish this activity unless separate evidence also meets an inclusion criterion.

6 criteria
  1. 01Criterion

    Producers or Exporters with No Transfer Role

    Defined as: Companies that manufacture or export cluster munitions but do not facilitate their transfer between end-users or other intermediaries.

  2. 02Criterion

    Logistics or Transport Firms Without Facilitation Role

    Defined as: Shipping or cargo companies that move goods without involvement in contractual, financial, or decision-making aspects of the weapons transfer.

  3. 03Criterion

    Transfers of Non-Cluster Weapons

    Defined as: Companies involved in transferring conventional weapons, missiles, or munitions not configured or intended to deploy submunitions.

  4. 04Criterion

    Historical-Only Cluster Munition Transfer

    Defined as: Entities with verified past transfer or brokerage of operational cluster munitions, explosive submunitions, explosive bomblets, or dedicated components, where reliable evidence establishes that the qualifying activity has fully ceased, been divested, transferred, dismantled, terminated, or otherwise ended and no current qualifying involvement remains. Historical-only activity does not qualify as current involvement. Preserve the historical record separately with the activity period, effective cessation or transfer date, relevant entity, product, programme, facility, or contract, and supporting evidence. Absence of recent evidence alone is not sufficient to establish cessation.

  5. 05Criterion

    Transfer of Inert or Training Devices

    Defined as: Transfers involving deactivated or non-functional cluster munitions used for display, education, or military training purposes without live ordnance.

  6. 06Criterion

    Financial Institutions or Legal Advisers

    Defined as: Firms providing financing or legal services for arms contracts, without operational involvement in the weapons transfer.

Evidence and evaluation methodology

How sources, entity pathways, decisions, qualifiers, and review history are handled.

Map screens to a client policy

How to choose provider screens, document coverage, and decide what happens after an outcome.

Other screens under Cluster Munitions

Taxonomy version 2026.08.21.2, published Aug 21, 2026. Material changes receive a new immutable release so earlier evaluations remain tied to the definitions and criteria used.

Cluster Munitions