History of Global Arms Transfer, 8 (2019), pp. 19-38

Can the Arms Trade Treaty Increase
Transparency in International Arms
Transfers?
By PAUL HOLTOM*
This article asks whether the Arms Trade Treaty (ATT) can achieve its purpose ofincreasing transparency in the international arms trade. After introducing theconcepts of intergovernmental and public transparency in international arms
transfers, the article provides examples of key transparency instruments with afocus on United Nations Register of Conventional Arms (UNROCA). The article
reviews ATT annual reports submitted during 2016-18, which provide information
on international transfers of conventional arms that took place during 2015-17 incomparison to UNROCA submissions for this period. The article concludes that
the ATT has the potential to increase the number of States that make informationon their arms transfers publicly available, especially if States Parties takeadvantage of the opportunities for capacity building that could be provided via
the ATT voluntary trust fund (VTF). Yet there are worrying signs that several ATTStates Parties are providing less detailed information in their ATT reports thanthey used to provide for UNROCA. Therefore, States Parties and nongovernmental organizations need to remain vigilant and highlight backsliding inreporting before obfuscation of information becomes a ‘norm’ in transparency ininternational transfers of conventional arms.
The first Article of the Arms Trade Treaty (ATT) declares that the Treaty’s purpose
includes: ‘promoting cooperation, transparency and responsible action by States Parties in
the international trade in conventional arms, thereby building confidence among States
Parties’.1 To achieve the aim of promoting transparency in international arms transfers,
ATT States Parties are legally obliged to provide to the ATT Secretariat an annual report on
authorizations and/or actual exports and imports of eight categories of conventional arms,
including small arms and light weapons (SALW).2 This article investigates the assumptionthat the ATT can increase transparency in the international arms trade. Specifically, it seeks
to address the question: ‘Has the ATT increased transparency in international arms
transfers?’. In order to do this, it uses reporting to the United Nations Register ofConventional Arms (UNROCA) to provide a baseline for assessing the impact of the ATT
on transparency in international arms transfers, examining both the level of reporting andthe quality of the information contained in ATT and UNROCA reports.
Providing data on arms exports and imports for other States and for the general public isviewed as a sensitive issue for many States, having potential implications for national* Author’s Affiliation: Paul Holtom, Senior Researcher, Small Arms Survey.
1 UNGA, Arms Trade Treaty, Article 1.
2 UNGA, Arms Trade Treaty, Article 13.3.

19

PAUL HOLTOM
defence and security. Yet, a norm in transparency in international arms transfers has been
established since the end of the Cold War, as States have exchanged official information
with other States on imports and exports of conventional arms and military equipment, as
well as making such information available for parliamentary and public scrutiny. However,since the start of the UN process towards an ATT, there has been a significant decline in thenumber of States providing information on their international transfers of conventionalarms to UNROCA. Does this suggest that the norm of transparency in international arms
transfers is under threat? Can the ATT reverse this negative tendency and increasetransparency in international arms transfers?
Section I of this article identifies intergovernmental and public transparency ininternational arms transfers. Section II gives an overview of transparency in internationalarms transfers for the period 1992-2015, with a focus on UNROCA reporting. It provides abaseline against which to assess the impact of the ATT on transparency in internationalarms transfers. The third section provides background information on the development of
ATT reporting forms and other guidance developed for use by ATT States Parties to enable
them to report annually on their exports and imports of conventional arms. Section IV
reviews the first three years of ATT annual reports submitted during 2016-18, providing
information on international transfers of conventional arms that took place during 2015-17,
and assesses this data to determine if the ATT has increased transparency in internationalarms transfers. The final section provides concluding remarks.

I
What is transparency? An Florini provides a negative definition for transparency,
suggesting it can simply be considered ‘the opposite of secrecy’.3 In a positive sense, it hascome to be understood as involving the ‘systematic provision of information’ with a viewto reducing ‘the risk of misunderstanding or miscalculation’. 4 Therefore, it is also usedsynonymously with ‘open government’ or ‘openness’. It should also be noted that States
and national governments can be transparent in some spheres and still retain secrets inother areas. Thus, a general division can be made, depending on the intended audience of
the information released, between intergovernmental transparency and public transparency.5
The confidential exchange of information on international transfers of conventional arms
between States is classified as intergovernmental transparency. This type of exchange of
information is not viewed as a goal, but as a means to build confidence and enhancecooperation between states that regard participation as being in line with their national andinternational security interests. There are two main objectives for multilateralintergovernmental mechanisms for reporting on arms exports and/or imports: (1) preventing
arms races and armed conflict between states that exchange information and (2) informing
arms export licensing decisions in order to prevent destabilizing accumulations of arms anddiversion to unauthorised illicit end users (i.e. terrorists, criminals, entities subject to UN
arms embargoes).
In the first category, it is assumed that the exchange of information can provide data thathelps to understand the intentions and capabilities of other States in order to prevent theexaggeration of threats, misinterpretations, and miscalculations that can lead to arms races
3 For example, see: Florini. ‘The end of secrecy’, p 50.
4 UNGA, A/46/301, para. 14.
5 Florini, ‘The end of secrecy’; Grigorescu, ‘International organizations’, pp. 643–67.

20

Can the Arms Trade Treaty Increase Transparency in International Arms Transfers?
and armed conflict.6 This was the rationale for the Treaty on Conventional Armed Forces in
Europe (CFE Treaty), signed on 19 November 1990 by 22 North Atlantic Treaty
Organisation (NATO) and Warsaw Treaty Organisation (WTO) states. States that participate
in the exchange of information on military holdings of five categories of major
conventional weapons under the CFE Treaty share this data in a confidential manner, withthe aim of building confidence and preventing conflict.7 The CFE Treaty is an example ofan intergovernmental transparency mechanism that seeks to prevent arms races and armed
conflict between the States that participate in the information exchange.
In the second category, information on arms export licences and/or deliveries of
conventional arms is shared between States in order to inform national decision-making onexports, ensuring that potential transfers will not contribute to destabilizing accumulations
and fuel armed conflict.8 The Wassenaar Arrangement on Export Controls for ConventionalArms and Dual-Use Goods and Technologies (Wassenaar Arrangement), established by 33
states in July 1996, is an example of such an intergovernmental transparency mechanism.
The Wassenaar Arrangement has two key objectives:•• promote greater transparency, cooperation and responsibility in transfers ofconventional arms, military equipment, and dual-use items and technologies; and•• prevent destabilizing accumulations and the diversion of controlled items to illicit end
users.9
The 42 Wassenaar Arrangement participating States are major arms producers or Stateswith significant involvement in the international arms trade. These States meet formally
twice a year to exchange information in confidence on exports and export licence denials.
The information exchanged between Wassenaar Arrangement participating States is notmade publicly available.
Public transparency, or government openness, in international arms transfers refers to thepractice of making information on a state’s preferences, intentions, and capabilities
available to the general public, including in other citizens of other States. It is generally
regarded as being linked to a government’s democratic accountability and commitment toparliamentary and public oversight.10 Public transparency with regard to international arms
transfers entails the public dissemination of information on laws, decision-making
procedures for exports and procurement, and information on authorizations and actual arms
exports and imports, as well as the refusal for licences to export or import conventionalarms. By making such information publicly available, it is expected that it will enable
parliamentarians and interested citizens to monitor and assess compliance with national andinternational legal obligations regarding international arms transfers, in particular Articles
6, 7 and 11 of the ATT.11 The possibility of being held to account for certain transfers that
could be viewed negatively by domestic publics ‘might motivate the authorities to give
6 UNGA, A/46/301, para 99-100.
7 The five categories of weapons to be reported upon are listed in Article 1 of the CFE Treaty: tanks, artillery,armoured combat vehicles, combat aircraft and attack helicopters.
8 UNGA, A/46/301, para 98 and 101.
9 The Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods andTechnologies is regarded to some extent as a successor to the Coordinating Committee for Multilateral Export
Controls (COCOM). COCOM was established in 1947 to prevent the transfer of arms and military equipmentfrom NATO members and Japan to WTO states. It was disbanded in 1994. The membership of the WA is broader
than that of COCOM, with former WTO members now participants (WA, ‘Website’).
10 Grigorescu, ‘International organizations’, p. 644.
11 Greene, Information exchange and transparency; and SAS, Survey 2007, pp. 73 and 81.

21

PAUL HOLTOM
even more careful consideration to all aspects of contemplated arms transfers before they
are carried out’.12 As of December 2018, 34 States had published at least one national
report on arms exports since 1990, providing information on national arms transfer control
systems and/or arms export authorizations or actual exports and. 13 Some States produce
reports that include descriptions of all equipment licensed for export, instances where an
export licence was denied, brokering licences authorized or denied, and transit licences.
The level of detail provided can vary considerably.
Although it is analytically useful to distinguish between intergovernmental and public
transparency in international arms transfers, there is a lot of the interplay between the twoforms in practice. While the data on international arms transfers shared between States
under the CFE Treaty and Wassenaar Arrangement is not made publicly available, there is a
growing tendency for information exchanged within intergovernmental frameworks to also
be made publicly available, thereby contributing to public transparency.14 Several regional
examples that support this argument are presented below. UNROCA is the most importantintergovernmental reporting mechanism on imports and exports of conventional arms,
which also makes information provided by States publicly. UNROCA was created toincrease intergovernmental transparency and build confidence between States and prevent
destabilizing accumulations of conventional arms that could fuel misperceptions andeventually lead to armed conflict. The UN Department for Disarmament Affairs interpreted
the UN General Assembly resolution that established UNROCA as providing for the
information supplied by UN Member States to be made available for, at first the interested
academic and research community, and subsequently for the public at large via a websitethat reproduces national submissions. 15 Therefore, UNROCA is not only anintergovernmental transparency mechanism but also contributes to public transparency. As
will be discussed below, the approach taken for UNROCA set an important precedent for
public reporting under the ATT. This article only assesses the way in which the ATT
contributes to public transparency in international arms transfers. It also notes that the
ATT’s reporting obligations did not necessarily introduce new commitments or practices
because many ATT States Parties were already politically or legally committed to providing
information on an annual basis on their authorizations and/or actual exports and imports.

II
The issue of transparency in international arms transfers is not new. States exchanged
information on their international arms transfers during the inter-war period of the 1920s
and 1930s under the auspices of the League of Nations, which produced a Statistical
Yearbook on Trade in Arms and Armaments using information provided by States.16 The
possibility of the UN collecting, collating and disseminating information on international
12 UNGA, A/46/301, para. 101.
13 The 34 states that have published at least one report on their arms exports since 1990 are: Albania, Australia,

Austria, Belgium, Bosnia and Herzegovina, Bulgaria, Canada, Croatia, Czech Republic, Denmark, Estonia,
Finland, France, Germany, Hungary, Ireland, Italy, Former Yugoslav Republic of Macedonia, Montenegro, The
Netherlands, Norway, Poland, Portugal, Romania, Serbia, Slovakia, Slovenia, South Africa, Spain, Sweden,
Switzerland, Ukraine, the United Kingdom and the United States. Although Belarus published a national reporton export control policy, exports of arms and military equipment for 2006, it did not contain any data on actual
transfers. A list of the published reports is at: http://www.sipri.org/contents/armstrad/atlinks_gov.html.
14 Grigorescu, ‘International organizations’, p. 649.
15 UNROCA, ‘Website’.
16 Stone, ‘Imperialism and sovereignty’, pp. 213-30. The League of Nation’s Yearbooks can be found at: www.
un.org/disarmament/convarms/Register/HTML/Register_Resources.html.

22

Can the Arms Trade Treaty Increase Transparency in International Arms Transfers?
arms transfers was also raised in the General Assembly on several occasions during theCold War. The genesis of UNROCA can be found in General Assembly resolution 43/75 of
7 December 1988, which requested the UN Secretary-General to establish a group of
governmental experts (GGE) to carry out a study on the ‘ways and means of promoting
transparency in international transfers of conventional arms on a universal and nondiscriminatory basis’.17 This study laid the foundations for the UNROCA of ConventionalArms (‘the Register’), providing recommendations for the instrument’s operation andscope.
UN General Assembly resolution 46/36 L of December 1991, on ‘Transparency inarmaments’ established the UNROCA ‘to prevent excessive and destabilizing accumulationof arms (…) in order to promote stability and strengthen regional or international peace andsecurity [and to] enhance confidence, promote stability, help states to exercise restraint,ease tensions and strengthen regional and international peace and security’.18 All UN
Member States are requested to provide information on their actual imports and exports
from the preceding calendar year for seven categories of conventional arms:
I.
Battle tanks;
II. Armoured combat vehicles;
III. Large-calibre artillery;
IV. Combat aircraft;
V. Attack helicopters;
VI. Warships; andVII. Missiles and missile launchers.
Descriptions for the seven categories are provided in an appendix to the resolution. The
description have been reviewed every three years by a group of governmental experts(GGE) appointed by the UN Secretary-General as part of a regular assessment of thecontinuing operation and further development of UNROCA. The GGEs can recommend
changes to the parameters of the descriptions, which are then put before the UN General
Assembly for adoption. 19 The last change to a category description took place following
the 2016 GGE on the UNROCA, which provided a description for unmanned combat aerial
vehicles (UCAV) to be reported in an amended category for combat aircraft. 20 Member
States determine on a national basis what constitutes an ‘export’ or ‘import’ and whichconventional arms to report.21 Since 2004, UN Member States have been invited to provide
information on international transfers of SALW,22 and were provided with a standardised
reporting form for reporting international transfers of SALW in 2006.23 The 2016 GGE on
the continuing operation and further development of the UNROCA recommended thatmember States report on international transfers of SALW on the same basis as the seven
17 UNGA, A/RES/43/75 I.
18 UNGA, A/RES/46/36 L.
19 For more information on the role of GGE’s in the development, or lack thereof, see: Holtom, ‘Nothing toreport’, pp. 61-87.
20 UNGA, A/71/259, para. 81.
21 Member States are only requested to provide information on international transfers of complete weaponssystems and not spare parts, components, upgrade kits, and military technology and equipment. UN General
Assembly resolution 46/36 L of December 1991 also invited Member States to provide background information
on procurement through national production, military holdings, and relevance policies.
22 UNGA, A/58/274, para. 113(e).
23 UNGA, A/61/261, para. 125.

23

PAUL HOLTOM
categories of conventional arms, thus creating a ‘seven plus one formula’ for reporting. 24
Since its inception the UNROCA has received reports from more than 170 states. The
level of reporting has varied significantly from year-to-year, from a high of 124 states in2002 for transfers that took place in calendar year 2001 to a low of just 50 states in 2016
for transfers that took place in 2015 (see Figure 1). The decline in reporting correspondswith the period in which the negotiations on the ATT took place, as well as the repeated
failure of several UN GGE to reach consensus on adding an eighth full category to the
UNROCA for reporting on international transfers of SALW. Nevertheless, reporting to the
UNROCA provides a useful baseline for assessing the contribution of the ATT fortransparency in international arms transfers. The GGEs tasked with accounting for the
decline in reporting have determined that the downward trajectory is largely due to the factthat the large number of Member States that provided nil reports during the period 2001-7
stopped reporting during 2008-18.25 More precisely, the factors that could have influenced
this downward trajectory are thought to include:•• ‘a reduction in follow-up efforts regarding reporting;•• an increasing burden on Member States with regard to reporting on conventional arms
issues;•• reporting fatigue felt by Member States that previously reported regularly;•• the limited relevance of the Register while small arms and light weapons were notincluded as a main category; and•• the focus on the Arms Trade Treaty process at the United Nations in recent years’.26

120
100
80

Total submissions

60

Information on SALW
transfers

40
20
0

1992
1994
1996
1998
2000
2002
2004
2006
2008
2010
2012
2014
2016

Number of UN Member States

140

Calendar year in which transfers took place

Figure 1. Submissions to the UNROCA of Conventional Arms, years in which transfers
took place, 1992-2017
Sources: UNODA, The UN Register; UNROCA.
24 UNGA, A/71/259, para. 75 and 83.
25 UNGA, A/68/140, para.17; UNGA, A/71/259, para. 20.
26 UNGA, A/68/140, para. 16.

24

Can the Arms Trade Treaty Increase Transparency in International Arms Transfers?
The UNROCA has not only served as a critical point of reference for the ATT, but has
also been an inspiration for regional confidence-building instruments and informationexchanges on international arms transfers. For example, since 1998 participating states of
the Organization of Security and Co-operation in Europe (OSCE) have exchanged annual
reports on their imports and exports of conventional arms using UNROCA descriptions forseven categories of conventional arms and using reporting templates that are identical tothose used for the UNROCA.27 A decision was taken in September 2016 for the informationexchanged on conventional arms transfers to be made publicly available on the OSCE
website.28 In June 1999, the Organization of American States (OAS) General Assembly
adopted the Inter-American Convention on Transparency in Conventional Weapons
Acquisitions (CITAAC), which entered into force in November 2002. The CITAAC
requires States Parties to submit annual reports on imports and exports of items fallingwithin the seven categories of the UNROCA, and to report on all acquisitions within 90
days of their incorporation into the armed forces, and provides that ‘States Parties shallguarantee the confidentiality of any information they receive, if requested to do so by theState Party providing the information’.29 In addition, European Union (EU) Member States
regularly exchange information on authorizations for export and brokering licences anddeliveries of conventional arms. This information is compiled in the publicly available EU
annual report produced in accordance with the legally binding Common Position 2008/944/
CFSP, which defines common rules governing control of exports of military technology
and equipment.30 Countries in south-eastern Europe have adopted the EU approach toexchanging information in a regional setting and making information on authorizations
and/or actual exports of conventional arms. Therefore, the Euro-Atlantic region and theAmericas have multiple political commitments and legal obligations for reporting on
international arms transfers.
In contrast to the public transparency on international arms transfers by States in the EU,
OAS, OSCE, and south-eastern Europe, there are several intergovernmental transparency
mechanisms on international transfers of SALW for which the results are not made publicly
available. Since 2001, OSCE participating states have exchanged information on theirimports and exports of small arms, but this information is not made publicly available.
States parties to the Economic Community of West African States (ECOWAS) Convention
on SALW, their Ammunition and Other Related Materials (ECOWAS Convention) and theCentral African Convention for the Control of Small Arms and Light Weapons, Their
Ammunition and all Parts and Components that can be used for their Manufacture, Repair
and Assembly (Kinshasa Convention) are legally obliged to report each year to theirrespective Secretariats on their SALW imports and exports, but these reports do not have to
be made public.31As a result of this opacity, the baseline for assessing the contribution of
the ATT to public transparency in international transfers of SALW relies on UNROCA
submissions and information provided in national and regional reports on arms exports.

27 OCSE, FSC.DEC/13/97.
28 OSCE, FSC.DEC/4/16/Corr.1.
29 OAS, CITAAC. Most national reports can be found online at: http://www.oea.org/csh/english/

conventionalweapons.asp.
30 CoEU, Council Common Position 2008/944/CFSP.
31 ECOWAS, Convention, Article 10; ECCAS, Convention, Articles 21 and 24.

25

PAUL HOLTOM

III
Article 13(3) of the ATT obliges ATT States Parties to provide an annual report to the ATT
Secretariat by 31 May each year on their conventional arms imports and exports during theprevious calendar year. 32 This section notes that while the treaty text provides some
guidance for reporting, the ATT working group on transparency and reporting, and nongovernmental organizations have developed tools and materials to support reporting by
ATT States Parties.
Article 13(3) does not explicitly state that ATT annual reports will be made publicly
available. At a glance, Article 13(3) resembles the UN General Assembly resolution that
established the UNROCA, which also did not contain provisions for national submissions
to the UNROCA to be made publicly available. However, it has been argued that there is an
implicit call for public reporting because of the placement of the comma in the sentence:‘Reports shall be made available, and distributed to States Parties by the Secretariat’.33 The
so-called ‘transparency comma’ is thus interpreted as distinguishing between making
reports publicly available in the first half of the sentence before the comma, and theintergovernmental transparency provided for in the second half of the sentence. One could
argue that the fact that Article 13(3) also notes that ‘reports may exclude commerciallysensitive or national security information’ suggests that it is the intention of the treaty toprovide for public transparency. Most of the ATT States Parties that have provide an annual
report on arms exports and imports have accepted this public transparency approach, yetseveral have also indicated that they have withheld information from the report due tocommercial sensitivities or national security.
Article 13(3) of the ATT also provides some flexibility for States Parties with regards tothe sources of information for their reports. UN Member States are requested to provide
information for UNROCA on their actual exports and imports of conventional arms. In
other words, the reports should contain data on deliveries that have taken place. ATT States
Parties can elect to provide such information in their ATT annual reports, in accordancewith the provisions in the Treaty to provide the same information for the ATT and
UNROCA. Alternatively, States Parties can provide information on authorizations, in otherwords on licences issued for exports or contracts signed for imports. This flexibility reflects
the fact that several Member States indicated that they use such sources for providing
information on international transfers of SALW for the UNROCA.34 It has recently been
revealed that UN Member States use information on authorizations for their UNROCA
submissions for other categories too.35
The ATT does not provide a form or template for reporting exports and imports of
conventional arms in the treaty nor in an annex to the treaty. Article 13(3) provides some
guidance in noting that a State Party can provide the same information in its ATT annual
report as it provides in its UNROCA submission, in order to address concerns that ATT
reporting provisions would introduce a new reporting burden for ATT States Parties. States
Parties decided in late 2014 to establish an informal working group on transparency andreporting, which was tasked with the development of standardized templates for both the
ATT initial reports on implementation measures and ATT annual reports on exports and
32 UNGA, Arms Trade Treaty, art. 13.3
33 Control Arms Secretariat, ATT monitor, p. 19.
34 Holtom, Transparency in transfers, pp. 23-6.
35 An analysis of information provided by UN Member States in their UNROCA submissions for calendar

years 2016 and 2017 indicates that 36 UN Member States provided information on actual exports and imports
comparted to four Member States that provided information on authorizations.

26

Can the Arms Trade Treaty Increase Transparency in International Arms Transfers?
imports of conventional arms. 36 The informal working group produced a draft annual
reporting template, which combined the UNROCA standardized form for reporting on
international transfers of conventional arms and the form for providing backgroundinformation on international transfers of SALW. The informal working group developed
ATT reporting templates that contained three key differences when compared to the
UNROCA standardized forms:•• First, the ATT annual reporting template provides space for States Parties to indicate
if the data provided relates to authorizations and/or actual exports and imports.
•• Second, it offers the option to report on the number of units exported or imported and/or their financial value.
•• Third, the UNROCA standardized form provides a column for ‘intermediate location’,
which is not included in the ATT annual reporting template.
The annual reporting template was not adopted at the first Conference of States Parties(CSP1) for the ATT in 2015.37 Following minor revisions in 2016, CSP2 endorsed thetemplate and recommended it for use by States Parties. However, it is not compulsory for
ATT States Parties to use the standardised reporting template. The Conference also decided
to keep the template and procedures for making reports publicly available ‘under review’.38
The ATT working group on reporting and transparency has continued to support ATT State
Party reporting on international transfers of conventional arms. Given the fact that ATT
States Parties can provide the same information for UNROCA and the ATT annual report,
the ATT working group on reporting and transparency and civil society organizations andresearch institutions have developed various tools to help reduce the reporting burden forStates.39 In preparation for the third conference of ATT States Parties, Belgium led on thedevelopment of guidance to help ATT States Parties better understand how to fulfil their
obligations under Article 13(3) of the ATT, in the form an FAQ guide entitled: Reporting
authorized or actual exports and imports of conventional arms under the ATT: questions
and answers.40 The FAQ approach taken for the guidance resembles the guidance document
prepared by the UNODA for UNROCA reporting.41 Also, like the UNROCA, the ATT
Secretariat has led the development of an online reporting tool, which has been introduced
for use for ATT States Parties reporting in 2019.

IV
ATT annual reports on exports and imports of conventional arms are the primary method
for assessing the application of the ATT and demonstrating that national systems are inplace that maintain records of actual or authorised exports and imports of conventionalarms. As noted above, the submission of annual reports to the ATT Secretariat is a legallybinding obligation, in contrast to the political commitment of participation in the
UNROCA. This section presents an overview of reporting for the first three years of ATT
annual reports, those submitted during 2016-18 and covering authorization or actual
36 ATT Secretariat, ATT/CSP1/2015/WP.4.
37 ATT Secretariat, ATT/CSP1/2015/6, para. 36.
38 ATT Secretariat, ATT/CSP2/2016/5, para. 25.
39 ATT-BAP, Reporting guidance; UNIDIR, Reporting on conventional arms.
40 ATT Secretariat, ATT/CSP3.WGTR/2017/CHAIR/159/Conf. Rep.
41 UNODA, The global reported arms trade.

27

PAUL HOLTOM
international transfers of conventional arms that took place during calendar years 2015-17.
The first ATT annual reports were due to be submitted to the ATT Secretariat by 31 May
2016, providing information on authorizations and/or actual exports and imports of theeight categories of conventional arms covered by Article 2(1) of the treaty that took place
during the calendar year 2015. Reporting for this first year gave a positive initial sign. A
total of 61 ATT States Parties were due to report by 31 May 2016. Twenty-eight States
Parties reported by this date, but a total of 51 ATT States Parties submitted an annual reporton conventional arms transfers that took place during the 2015 calendar year. Of these 51
States Parties, three submitted a report even though they were not due to submit their firstannual report until 31 May 2017. Thus, of the 61 ATT States Parties due to report, 48 didso, representing 79 per cent of the total reports due. While the number of annual reports
submitted on time and overall has increased year on year, the percentage of ATT States
Parties that are fulfilling their obligation to report is in decline (see Table 1). Thus, 68 percent of the 75 ATT States Parties due to report by 31 May 2017 fulfilled their reporting
obligation for calendar year 2016, dropping to 61 per cent of 89 States Parties due to reportfor 2017 by 31 May 2018.
Table 1. ATT Annual Reports for calendar years 2015-17

ATT State Party

RegionLevel ofFreedom ATT Annual
economic
House
Report (year ofdevelopment Scoretransfers)

Albania
Antigua and Barbuda
Argentina
Australia
Austria
BahamasBarbados
Belgium
BelizeBosnia and Herzegovina
Bulgaria
Burkina Faso
Cape VerdeCentral African Republic
Chad
Costa Rica
Cote d’Ivoire
Croatia
CyprusCzechia

EuropeAmericas
Americas
Oceania
EuropeAmericas
Americas
EuropeAmericas
EuropeEuropeAfricaAfricaAfricaAfricaAmericas
AfricaEuropeAsia
Europe

UMI
SIDS
UMI
HI
HI
HI (SIDS)
HI (SIDS)HI
UMI (SIDS)
UMI
UMI
LI
LMI (SIDS)
LI
LI
UMI
LMI
UMI
HI
HI

28

PF
F
F
F
F
F
F
F
F
PF
F
PF
F
NF
NF
F
PF
F
F
F

Last UN
Registersubmission(year oftransfers)

2015 2016 2017
2017



2010


 * 2017
2017



2017



2011
NRR 2003
2017

NRR 2010
2017



2017



2006

NRR NRR NRR NRR 1995
NA 19942008
NA 20022014
NRR NRR  * 2017
2017




Can the Arms Trade Treaty Increase Transparency in International Arms Transfers?
Denmark
Dominica
Dominican Republic
El Salvador
Estonia
FinlandFranceGeorgia
Germany
Ghana
GreeceGrenadaGuatemalaGuineaGuyanaHungary
Iceland
Ireland
Italy
JamaicaJapan
LatviaLesothoLiberia
Liechtenstein
Lithuania
Luxembourg
Madagascar
Mali
Malta
Mauritania
Mauritius
MexicoMoldova
MonacoMontenegro
Netherlands
New Zealand
Niger
Nigeria
NorwayPanamaParaguay
Peru
PolandPortugal

EuropeAmericas
Americas
Americas
EuropeEuropeEuropeAsia
EuropeAfricaEuropeAmericas
Americas
AfricaAmericas
EuropeEuropeEuropeEuropeAmericas
Asia
EuropeAfricaAfricaEuropeEuropeEuropeAfricaAfricaEuropeAfricaAfricaAmericas
EuropeEuropeEuropeEuropeOceania
AfricaAfricaEuropeAmericas
Americas
Americas
EuropeEuropeHI
SIDS
UMI (SIDS)
LMI
HI
HI
HI
LMI
HI
LMI
HI
SIDS
LMI
LI
UMI (SIDS)
HI
HI
HI
HI
UMI (SIDS)
HI
HI
LMI
LI
HI
HI
LI
LI
HI
LMI
UMI (SIDS)
UMI
LMI
UMI
HI
HI
LI
LMI
HI
UMI
UMI
UMI
HI
HI

F
F
PF
F
F
F
F
PF
F
F
F
F
PF
PF
F
F
F
F
F
F
F
F
PF
PF
F
F
F
PF
PF
F
NF
F
PF
PF
F
PF
F
F
PF
PF
F
F
PF
F
F
F




NRR 














NRR NRR 
NRR NRR NRR  ~  *NRR NRR 















NRR NRR ~ * 








NRR NRR  *
NRR NRR 




NRR 

NRR NRR 








NRR 



* 
~ 
NRR NRR 







2014
2010
2010
2015
2015
2017
2017
2007
2017
2007
2017
2014
2007
2010
2017
2013
2017
2017
2014
2017
2017
2005
2017
2017
2017
2010
2006
2012
1994
2012
2015
2017
2017
2016
2017
2009
2005
2014
2008
2006
2010
2017
2017

29

PAUL HOLTOM
Romania
EuropeSt Kitts and Nevis
Americas
St Lucia
Americas
St Vincent and theAmericas
Grenadines
Samoa
Oceania
San Marino
EuropeSenegalAfricaSerbiaEuropeSeychelles
AfricaSierra Leone
AfricaSlovakia
EuropeSlovenia
EuropeSouth Africa
AfricaSpain
EuropeSwedenEuropeSwitzerland
EuropeFYROM
EuropeTogo
AfricaTrinidad and Tobago
AmericasTuvaluOceaniaUK
EuropeUruguay
AmericasZambiaAfricaTOTAL REPORTS SUBMITTED
Reports not due but submitted
Total reports due
Reports due and submitted
Percentage of due reports submitted
Reports not due but submitted
Number of reports not made publicly
available

UMI(SIDS)(SIDS)

F
F
F


-


-


-

2017
2005
2006

(SIDS)

F

-

-

-

2008

UMI (SIDS)

F
F
F
F
PF
PF
F
F
F
F
F
F
PF
PF
F
F
F
F
PF


NRR 
* 



NRR NRR 


* 













~ 




NRR NRR NRR 






NRR NRR 51
52
54
3
1
0
61
75
89
48
51
54
79% 68% 61%
3
1
0

LI
UMI
(SIDS)
LI
HI
HI
UMI
HI
HI
HI
UMI
LI
HI (SIDS)(SIDS)
HI
HI
LMI

1

3

2011
2013
2017
2017
2008
2006
2017
2017
2016
2017
2017
2017
2017
2007
2014
2006
2017
2015
2006

4

Notes: For the column that indicates level of economic development: ‘HI’ indicates a ‘high income country’;‘UMI’ indicates a ‘upper-middle income country’; ‘LMI’ indicates a ‘lower-middle income country’; ‘LI’
indicates a ‘low income country’; (SIDS) indicates ‘small island developing state’.
For the column that indicates Freedom House score: ‘F’ indicates ‘Free’; ‘PF’ indicates ‘partly free’; ‘NF’
indicates ‘Not Free’.
‘’ indicates report submitted; ‘NRR’ indicates ‘no report required’; ‘-‘ indicates report due but not
submitted; ‘*’ indicates report not made publicly available; ‘~’ indicates report submitted but not required to
do soSources: ATT Secretariat, ‘Reporting: Status as of 16 April 2019’; Freedom House, ‘Freedom in the World’;
UN, WESP Report 2018; UNROCA.

Overall, 61 ATT States Parties have submitted at least one ATT annual report, of which
52 have submitted a report for every year for which they are obliged to report. Twentyeight States Parties that are due to report have never reported, of which 11 were due to30

Can the Arms Trade Treaty Increase Transparency in International Arms Transfers?
report for all three years. Japan is the only State Party in Asia due to report for the years
2015-17 and has reported every year. The three States Parties in Oceania due to report on
their 2015 activities all reported, but this dropped to two out of four for 2016 and then up
to three out of four for 2017. Of the three regions that represent most of the ATT States
Parties due to report, Europe has the highest level of participation with more than 90 per
cent of States Parties due to report in this region doing so each year. The level of reportingby States Parties in Africa and the Americas is largely comparable. More than half of States
Parties in these two regions submitted an annual report for 2015 but the percentage has
been in decline for the next two years for both regions to around a quarter of States Parties
in Africa reporting for 2017 and about a third for the Americas (see Table 1). The ATT
working group on transparency and reporting and the Arms Trade Treaty-Baseline
Assessment Project have separately distributed questionnaires to find the reasons for noncompliance with the reporting obligation, but the limited number of returns prevents one
from understanding the challenges and obstacles faced by all non-reporting States Parties.42
Therefore, this article has looked for reasons that could help to explain why some States
Parties are able to report. First, there is a strong correlation between ATT States Parties thatare participating States of the Wassenaar Arrangement and those that report – all 34 ATTStates Parties that are participating States of the Wassenaar Arrangement have submitted anannual report for every year due. All EU Member States and those located in South-Eastern
Europe that submit information for regional and sub-regional reports on arms exports also
submit ATT annual reports. There is not a particularly strong correlation between states
parties to CITAAC and ATT States Parties located in the Americas. So, while regional andmultilateral reporting instruments could help to explain reporting for the Euro-Atlantic
region and States with well-developed transfer control systems, this is not the only reason
for explaining why ATT States Parties report.
Robert J. Lemke and James J. Marquardt have argued that the nature of a state’s politicalsystem can help to determine whether it will submit a report to the UNROCA, by looking
at reporting records against Freedom House scores. 43 For the ATT, this approach does nothelp understand reporting or non-reporting as 73 per cent of the 46 ATT States Parties
identified as ‘free’ in Freedom House’s scores for 2018 have submitted an ATT annual
report compared to 70 per cent of the 16 States Parties assessed as ‘partly free’. None of
the three States Parties considered ‘not free’ have yet reported (see Table 1). James H.
Lebovic noted the weakness of this approach for analysing reporting to UNROCA anddetermined that ‘a state’s capacity’ is a key factor for explaining participation. 44
Therefore, this article sought to determine ‘state capacity’ by using the level of economic
developed as assessed by the 2018 World Economic Situation and Prospects (WESP)
report. Thirty-five of the 89 States Parties due to submit an ATT annual report for at least
one of the calendar years 2015-17 were classified as ‘high income countries’, compared to
21 ‘upper-middle income countries’, 11 ‘lower-middle income countries’, and 11 ‘low
income countries’ (see Table 1).45 Of these States, 89 per cent of ‘high income countries’
and 86 per cent of ‘upper-middle income countries’ submitted at least one annual report,
compared to 36 per cent of ‘lower-middle income countries’ and 45 per cent of ‘low
income countries’. Further, only 28 per cent of small island developing states (SIDS) havesubmitted at least one annual report. Therefore, the level of economic development of an
42 ATT Secretariat, ATT/CSP4.WGTR/2018/CHAIR/357/M2.SumRep, para. 33; ATT-BAP, ‘Lessons learned’
43 Lemke and Marquardt, ‘Freedom and transparency’, pp. 343-68.
44 Lebovic, ‘Democracies and transparency’, pp. 559-60.
45 UN, WESP Report, pp. 144-5.

31

PAUL HOLTOM
ATT State Party appears to be a good indicator for annual reporting. Therefore, this is an
issue that could be addressed to some extent by awareness-raising and capacity-building
activities, which could be supported via the Arms Trade Treaty Voluntary Trust Fund (ATTVTF).
In order to determine whether the ATT has increased transparency in international arms
transfers, this article compares the first three years of ATT annual reports with submissions
to the UN Register on international transfers of seven categories of conventional arms andinternational transfers of SALW. The United Nations Office for Disarmament Affairs(UNODA) indicated that 50 UN Member States reported to the UNROCA for calendar year
2015, 54 for 2016, and 56 for 2017.46 As far as can be discerned from available data, 30
Member States reported to both the ATT and UNROCA for 2015, 29 for 2016, and 35 for2017 (see Table 1). Therefore, for each of these years, around 20 ATT States Parties
submitted an ATT annual report but did not report to the UNROCA. There are no ATTStates Parties that reported to the UNROCA and did not provide an ATT annual reportduring these years. Only four ATT States Parties due to report for the calendar years 201517 have never reported to the Register,47 of which only Liberia has submitted an annual
report to the ATT Secretariat for 2015-17. Of the 23 ATT States Parties that did not reportto the UNROCA for the calendar years 2008-17, seven did submit at least one ATT annual
report for 2015-17. Therefore, in quantitative terms the ATT has increased transparency ininternational arms transfers compared to the Register, as UN Member States that havenever reported to the Register or which stopped reporting have submitted an ATT annual
report. Moreover, the fact that around 20 UN Member States are fulfilling their ATT
obligation to provide an annual report, but not reporting to the UNROCA, gives an increasein the number of States providing information on international transfers of conventionalarms for public review than would be found in UNROCA alone. Nevertheless, thecombined number of reports for the ATT and UNROCA is still not as high as the number of
UN Member States that reported to UNROCA during 2001-9.
At the same time, more than half of the ATT States Parties that have submitted an ATT
annual report are ‘regular reporters’ for the UNROCA or publish information in annual
national or regional reports on arms exports. The information provided by such States
Parties in their ATT annual reports is the same as information provided in UNROCA
submissions or other reports on arms transfers. While this is in line with the provisions
contained in ATT Article 13(3), under which the same information can be provided in an
ATT annual report and UNROCA submission, this means that the ATT is not providing
more information or increasing transparency in international arms transfers for such States.
However, as will be discussed below, of more concern is the fact that in several cases States
Parties appear to be providing less information in their ATT annual reports than they used
to in their UNROCA submissions, in particular aggregating data or omitting certain typesof information.
Non-governmental organizations expressed concerns during ATT Conferences of States
Parties and related events that ATT States Parties would submit their annual reports andindicate that these reports shall not be made available for the public. While the number ofStates Parties that have requested that their annual reports be restricted for access by otherStates Parties only is low, there is a worrying upwards trend in the number of States Parties
that are requesting that their annual reports are not made publicly available. While only
46 UNODA, The UN Register.
47 These four ATT States Parties are: Cabo Verde, Guinea, Liberia, and Nigeria.

32Can the Arms Trade Treaty Increase Transparency in International Arms Transfers?
Slovakia indicated that its ATT annual report for 2015 should be for States Parties only,
three States Parties selected this option for 2016 and four for 2017. It is worth noting thatno ATT State Party has yet requested more than one annual report to be restricted access –the only reports submitted by Cyprus and Madagascar are restricted access. Therefore, in
total, eight States Parties have indicated that one annual report should be made available
for States Parties only. However, the year for which Argentina, Cyprus, Greece, andSlovakia made their ATT annual reports available for States Parties only, these States also
reported to the UNROCA and their submissions were made publicly available on the
UNROCA website; while the restricted access ATT annual reports for Liberia, Madagascar,
Panama, and Senegal have no counterpart in the UNROCA. Liberia’s report for 2016 isrestricted access, while its 2015 report is publicly available and no report has been
submitted for 2017. Panama and Senegal have each submitted three annual reports,
restricting access to the submissions for 2016 only. No public explanations have been givenby these States Parties for why their reports are restricted access. The ATT Secretariat hassuggested that there is some confusion on the part of ATT States Parties regarding the tickbox on the annual reporting form for this issue and that some States Parties have mistakenly
indicated that the report should be restricted access. Therefore, it does not appear that theoption to restrict access to annual reports for States Parties only has had a positive impact
on reporting – i.e. States Parties are providing information in ATT annual reports but notfor the UNROCA because the latter makes the information publicly available. That said,
while 61 ATT States Parties have submitted at least one annual report to the ATT
Secretariat, the submissions for only 59 ATT States Parties can be assessed in this article
because Cyprus and Madagascar have not yet submitted a publicly available report.
Ten States Parties have indicated at least once that information has been withheld fromtheir ATT annual reports because it is considered commercially sensitive or related tonational security considerations.48 Five of these ATT States Parties have indicated that suchinformation is restricted access twice,49 and one has done it for all three reports.50 Australia,
for instance, indicates that information on imports for the Australian National Defence
Forces had been ‘withheld’, while Sweden provides information on the destinations of its
light weapons exports but did not indicate either the number of units or the value. Although
this indicates that these reports are not fully transparent, they are being open about thisissue in a way that they were not required to do so for their UNROCA submission.
On the other hand, there is aggregation of data and omission of data that indicates aworrying trend for transparency in international transfers. For example, Bosnia andHerzegovina and Jamaica aggregated the list of importers and exporters for each smallarms subcategory. Denmark and Norway identified only some of their export destinations
and import sources. Croatia identified importers by subcategory in its UNROCA
submissions for 2011–15 but has not identified importers, in any form, in its ATT annual
reports. Further, Italy has submitted a different format for its information each year,
gradually providing less and less information in each return – with its UNROCA
submission for 2017 also failing to conform with the minimum expected information.
Italy’s first annual report provided disaggregated information on number of items for eachcategory for each recipient state, helping it to achieve the status of one of the world’s most48 These ten States Parties are: Bulgaria, Croatia, Finland, Germany, Greece, Italy, Mauritius, Norway, South
Africa, and Sweden.
49 These five States Parties are: Bulgaria, Finland, Germany, Italy, and Norway.
50 Greece and Mauritius have only submitted one publicly available report.

33

PAUL HOLTOM
transparent exporters according to the Small Arms Survey.51 For its second and third ATTannual reports, Italy has provided aggregated totals for the number of items exported foreach category in the categories of the ATT and then an annex for SALW transfers thatprovides a list of partner States and an aggregated total of SALW exported and imported
for each State. For the third report, there is a distinction between small arms on one handand light weapons on the other. Therefore, there are concrete examples of where ATT States
Parties are becoming less open and transparent with regards to the quality of informationand level of detail provided in their ATT annual reports compared to their previous
reporting practices for the UNROCA. As noted in the examples above, this is particularly
the case for reporting on international transfers of SALW.
One key difference between the scope of the UNROCA and the ATT for reporting
purposes is the inclusion of SALW as an eighth category on the ATT reporting form. Sixtythree of the 89 States Parties due to report for calendar years 2015-17 have provided
information on international transfers of SALW at least once for the UNROCA. Of the 59
States Parties that have submitted a publicly available annual report, 50 have provided
information on international transfers of SALW to the Register at least once.52 Therefore,
nine States Parties have provided information on international transfers of SALW that did
not do so for the UNROCA. 53 In quantitative terms, it would seem that the ATT has
increased transparency in international transfers of SALW.
Forty-seven ATT States Parties have provided information on international transfers of
SALW using the sub-categories contained in the ATT reporting template. Austria andBelgium provided information on SALW using the definition provided by Category 1 of
the Wassenaar Arrangement Munitions List and EU Common Military List to define smallarms for their ATT annual reports, while Japan provided information on small arms
transfers disaggregated by Comtrade categories 9301, 9302, and 9303. In addition,
Australia uses the subcategories when reporting on small arms imports but did not use thesubcategories for reporting authorizations for firearms exports and Sweden utilizes the light
weapons subcategories contained in the ATT reporting template but also uses Category 1 of
the Wassenaar Arrangement Munitions List and EU Common Military List to define smallarms for its ATT annual reports. Switzerland provides different information on SALW
transfers in its ATT reports and submissions to the UNROCA because it provides onlytransfers to military end users for the UNROCA and for ‘private entities’ for the ATT.
However, this information is already made publicly available in the Swiss annual report on
the exports of SALW, which contains information not only on the number of units of
SALW authorised for export but also the value of the licence – information that is notincluded in the ATT report. Therefore, while Switzerland provides more information on
SALW exports in their ATT report compared to the UNROCA submission on internationaltransfers of SALW, Switzerland is providing information that is made publicly available
elsewhere already. 54 Therefore, the flexibility provided by the treaty for reporting on
51 Holtom and Pavesi, Sub-Saharan Africa in Focus, p. 39.
52 Twelve States Parties that have never submitted an ATT annual report have provided background information

on international transfers of SALW at least once to UNROCA: Antigua and Barbuda, Bahamas, Ghana, Grenada,
Guyana, Iceland, St Lucia, St Vincent and the Grenadines, San Marino, Swaziland, Togo, and Trinidad andTobago. Of the two States Parties that have only submitted restricted access ATT annual reports, Cyprus has
provided background information on international transfers of SALW to the UNROCA, while Madagascar hasnot.
53 These nine States Parties are: Burkina Faso, Costa Rica, Dominican Republic, Liberia, Mauritius, Paraguay,
Sierra Leone, South Africa, and Tuvalu.
54 See for example: Switzerland, Le contrôle à l’exportation.

34

Can the Arms Trade Treaty Increase Transparency in International Arms Transfers?
international transfers of SALW is being used by some ATT States Parties to provide more
information on international transfers of SALW in comparison to submissions to
UNROCA. At the same, time, more ATT States Parties seem to provide less detailed
information in their ATT annual reports compared to information provided in their
UNROCA submissions. There is cause for concern with regards to the quality of
information provided on such transfers in many ATT annual reports.

V
The title of this article asked if the ATT has the potential to increase transparency ininternational transfers of conventional arms. The first sections of this article indicated thatit does provide for opportunities to arrest the decline in reporting on international transfersof conventional arms, including SALW, to UNROCA. Reporting to UNROCA at the turn ofthe millennium seemed to show that the norm of transparency in international arms
transfers was fairly well-established, with 89 per cent of UN Member States reporting to
the UNROCA at least once and 65 per cent of UN Member States providing information in
2002. The first year of reporting on exports and imports of conventional arms under the
ATT corresponded to the lowest level of reporting to UNROCA, with around a quarter of
UN Member States participating in UNROCA. Therefore, it was hoped that the ATT could
reinvigorate the trend in reporting on international transfers of conventional arms.
The first year of ATT annual reports was very positive, with 79 per cent of ATT States
Parties due to report providing an annual report; and three States Parties providing a
voluntary report. While the number of ATT States Parties providing an annual report to the
ATT Secretariat has increased year-on-year, the percentage of ATT States Parties that are
fulfilling their annual report obligations is in decline. The preliminary analysis contained in
the section above suggests that rather than a ‘reporting burden’, States Parties that haveother obligations to report on international transfers of conventional arms to other
instruments and mechanisms are well-placed to fulfil their ATT reporting obligations.
Reporting could be a challenge for States Parties with low levels of economic development,
but this does not exclude the possibility that there are other reasons for non-compliancewith the reporting obligation. Therefore, use of the ATT VTF for capacity-building for
SIDS and States Parties with ‘low income’ and ‘lower-middle income’ could provide
benefits for these States.
While the quantitative analysis suggests that the ATT can increase transparency ininternational arms transfers by increasing the number of the States that report on imports
and exports of conventional arms, there are several worrying tendencies in ATT reporting
to date. First, although still at a low level, it is disconcerting that the number of States
Parties that choose to limit access to their reports to ATT States Parties only is increasing;and that two States Parties that reported for the first time in 2018 on their activities in 2017chose this option. Second, the way in which States Parties that previously reported
regularly and with detailed information on their imports and exports of conventional arms
have taken to aggregating their data and not providing information on exporting orimporting States. By not indicating the States to which conventional arms are being
exported to, or imported from, it is not possible to assess whether these States Parties haverecord-keeping systems in place or if their transfers are being undertaken in accordancewith Articles 6, 7, and 11 of the ATT. This is perhaps the most worrying negative tendency
in ATT reporting.

35

PAUL HOLTOM
The ATT can increase transparency in international transfers of conventional arms, but it
has had a rather inauspicious start. The positive tendencies in reporting by States Parties inregions that have not been regular reporters for UNROCA is welcome. This tendency
clearly shows the benefits of the ATT for increasing transparency, especially as more States
Parties from Africa and the Americas become obliged to report. Based on the current
situation, States Parties in these regions should be encouraged to seek ATT VTF funding tosupport capacity-building efforts to enable their reporting. On the other hand, the ATT
should not allow States Parties to take advantage of the flexible approach to reporting
contained in Article 13(3) to aggregate data and omit information from ATT annual reportsthat no longer makes it possible for other States Parties or interested stakeholders to use
their annual reports to assess compliance with Articles 6, 7, and 11 of the treaty. The ATT
can still fulfil its potential and increase transparency in the international arms trade in orderto build confidence between States Parties and foster peace, security, stability, andsustainable development. But it requires a willingness by States Parties to implement thetreaty’s reporting obligations in good faith, and for non-governmental organizations toremain vigilant and highlight backsliding in reporting before obfuscation of information
becomes a ‘norm’ in transparency in international transfers of conventional arms.
References
ATT-BAP (Arms Trade-Treaty-Baseline Assessment Project), Lessons learned from ATT reporting(Washington D.C., January 2019), http://www.armstrade.info/wp-content/uploads/2017/04/ATT-BAP_LESSONS-LEARNED-FROM-REPORTING_ATT.pdf.
Control Arms Secretariat, ATT monitor report 2017 (New York, 11 September 2017).
Florini. A., ‘The end of secrecy’, Foreign Policy, No. 111 (summer 1998), pp. 50-63.
Greene, O. with Batchelor, B., Information exchange and transparency: key elements of an international
action programme on small arms (Biting the Bullet Briefing 9, 2001).
Grigorescu, A., ‘International organizations and government transparency: linking the international anddomestic realms’, International Studies Quarterly, 47 (2003), pp. 643–67.
Holtom, P., Transparency in transfers of small arms and light weapons: reports to the United Nations
Register of Conventional Arms, 2003–2006 (Stockholm, SIPRI Policy Paper No. 22, 2008).
Holtom, P., ‘Nothing to report: The lost promise of the UN Register of Conventional Arms’, Contemporary
Security Policy, vol. 31, no. 1, (2010), pp. 61-87.
Holtom, P. and Pavesi, I., Trade update 2018: sub-Saharan Africa in focus (Geneva, 2018).
Lebovic, J.H., ‘Democracies and transparency: Country reports to the U.N. Register of Conventional Arms,
1992-2001’, Journal of Peace Research, 43, 5 (2006), pp. 543-62.
Lemke, R.J. and Marquardt, J.J., ‘Freedom and transparency: democracies, non-democracies andconventional arms transfers’, Democracy and Security, 3 (2007), pp. 343-68.
SAS (Small Arms Survey), ‘Probing the grey area: irresponsible small arms transfers’, Small Arms survey
2007: Guns and the city (Cambridge, 2007), pp. 72-115.
Stone, D. R., ‘Imperialism and sovereignty: The League of Nations drive to control the global arms trade’,
Journal of Contemporary History 35: 2, (2000), pp. 213-30.
UNIDIR (United Nations Institute for Disarmament Research), Reporting on conventional arms trade:
Synthesis handbook (Geneva, 2018), http://www.unidir.ch/files/publications/pdfs/reporting-onconventional-arms-trade-synthesis-handbook-en-699.pdf.
Official publications
ATT Secretariat (Arms Trade Treaty Secretariat), Reporting templates: Draft 4, ATT/CSP1/2015/WP.4(Cancun, 12 August 2015).
ATT Secretariat (Arms Trade Treaty Secretariat), Final report of the first conference of States Parties,
ATT/CSP1/2015/6 (Cancun, 27 August 2015).
ATT Secretariat (Arms Trade Treaty Secretariat), Final report of the second conference of States Parties,
ATT/CSP2/2016/5 (Geneva, 26 August 2016).

36

Can the Arms Trade Treaty Increase Transparency in International Arms Transfers?
ATT Secretariat (Arms Trade Treaty Secretariat), Reporting authorized or actual exports and imports of
conventional arms under the ATT: questions and answers, Annex D to the ATT working group on
transparency and reporting co-chairs’ draft report to CSP3, ATT/CSP3.WGTR/2017/CHAIR/159/Conf.
Rep (Geneva, 31 July 2017).
ATT Secretariat (Arms Trade Treaty Secretariat), ATT working group on transparency and reporting cochairs’ report of 31 May 2018 meeting, ATT/CSP4.WGTR/2018/CHAIR/357/M2.SumRep (Geneva, 20
July 2018).
ATT Secretariat (Arms Trade Treaty Secretariat), Reporting: Status: as of 16 April 2019.
CoEU (Council of the European Union), ‘Council Common Position 2008/944/CFSP of 8 December 2008
defining common rules governing control of exports of military technology and equipment’, Official
Journal of the European Union L335 (Brussels, 8 December 2008)
ECCAS (Economic Community of Central African States), Central African convention for the control ofsmall arms and light weapons, their ammunition and all parts and components that can be used for their
manufacture, repair and assembly.
ECOWAS (Economic Community of West African State), ECOWAS convention on small arms and light
weapons, their ammunition and other related materials.
OAS (Organization of American States), Inter-American convention on transparency in conventional
weapons acquisitions (CITAAC), http://www.oas.org/en/sla/dil/inter_american_treaties_A-64_
transparency_conventional_weapons_adquisitions.asp
OSCE (Organization for Security and Co-operation in Europe), Forum for Security Cooperation (FSC)
Decision No. 13/97, Further transparency in arms transfers, OSCE Document FSC.DEC/13/97 (Vienna,
16 July 1997).
OSCE (Organization for Security and Co-operation in Europe), Forum for Security Cooperation (FSC)
Decision No. 4/16, Enabling the publication of information exchanges in the field of small arms andlight weapons, conventional arms transfers and anti-personnel mines, OSCE Document FSC.DEC/4/16/
Corr.1, (Vienna, 21 September 2016), https://www.osce.org/fsc/268791?download=true
Switzerland, 2015: Le contrôle à l’exportation dans le domaine des armes légères et de petit calibre(ALPC) relevant de la législation sur le matériel de guerre. (Bern, 2016), https://www.seco.admin.ch/seco/fr/home/Aussenwirtschaftspolitik_Wirtschaftliche_Zusammenarbeit/Wirtschaftsbeziehungen/exportkontrollen-und-sanktionen/ruestungskontrolle-und-ruestungskontrollpolitik--bwrp-/zahlen-undstatistiken0/2015.html
UN (United Nations), World Economic Situation and Prospects (WESP) Report 2018 (New York, 2018),
https://www.un.org/development/desa/dpad/wp-content/uploads/sites/45/WESP2018_Full_Web-1.pdf
UNGA (United Nations General Assembly), International Arms Transfers, UN Document A/RES/43/75 I(New York, 7 December 1988).
UNGA (United Nations General Assembly), Study on ways and means of promoting transparency ininternational transfers of conventional arms, UN Document A/46/301, (New York, 9 September 1991).
UNGA (United Nations General Assembly), Transparency in armaments, UN Document A/RES/46/36 L(New York, 6 December 1991).
UNGA (United Nations General Assembly), Report on the continuing operation of the United Nations
Register of Conventional Arms and its further development, UN Document A/58/274 (New York, 13
August 2003).
UNGA (United Nations General Assembly), Report on the continuing operation of the United Nations
Register of Conventional Arms and its further development, UN Document A/61/261 (New York, 15
August 2006).
UNGA (United Nations General Assembly), Arms Trade Treaty (New York, 2013).
UNGA (United Nations General Assembly), Report on the continuing operation of the United Nations
Register of Conventional Arms and its further development, UN Document A/68/140 (New York, 15 July2013).
UNGA (United Nations General Assembly), Report on the continuing operation of the United Nations
Register of Conventional Arms and its further development, UN Document A/71/259 (New York, 29 July2016).
UNODA (United Nations Office for Disarmament Affairs), The global reported arms trade: transparency
in armaments through the United Nations Register of Conventional Arms: a guide to assist points ofcontact in submitting their national reports (New York, United Nations Office for Disarmament Affairs
Disarmament Study Series no. 36, November 2017).
UNODA (United Nations Office for Disarmament Affairs), The UN Register of Conventional Arms

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PAUL HOLTOM(UNROCA): developments, trends, challenges and opportunities, background paper by the United
Nations secretariat for the 2019 group of government experts on the United Nations Register ofConventional Arms, Rev.2 (New York, 2019)
Websites
ATT-BAP (Arms Trade-Treaty-Baseline Assessment Project), Reporting guidance, Accessed via the‘resources section’ of the website of the Arms Trade-Treaty-Baseline Assessment Project, http://www.
armstrade.info/resources-2/.
Freedom House, Freedom in the world 2018: table of country scores, https://freedomhouse.org/report/
freedom-world-2018-table-country-scores.
UNROCA (United Nations Register of Conventional Arms). n.d. UNROCA: transparency in the global
reported arms trade, http://disarmament.un.org/cab/register.html.
WA (Wassenaar Arrangement), n.d. Website of the Wassenaar Arrangement on Export Controls forConventional Arms and Dual-Use Goods and Technologies, http://www.wassenaar.org/.

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