A/HRC/41/35/Add.3 States to strengthen their existing frameworks. For example, while the United States has not fully incorporated the 2013 amendment to the Wassenaar Arrangement, the U.S. Commerce Department may “propose new export controls designed to protect human rights.” Furthermore, the “Commerce Department is simultaneously undertaking a broad review of export controls for new technologies” in light of “emerging technologies.” (Electronic Privacy Information Center, 2) In addition to implementing its obligations under the EU export control regime, the government of Germany states that it has also established “national legislation in order to control certain cyber-surveillance items,” including mandatory export license requirements for “companies which export certain products that are used for cyber-surveillance purposes in mobile radio and terrestrial networks.” (Germany, 1). It has also restricted the “supply of certain technical assistance by a German citizen in third countries,” which now requires an authorization. (Id.) The government of the United Kingdom has expressed its commitment to a strong export control regime, stating that it takes into consideration “[c]oncerns about internal repression, regional instability or other human rights violations, “concerns about the development of weapons of mass destruction,” “foreign policy and international treaty commitments including those resulting from the imposition of EU or United Nations trade sanctions or arms embargoes,” and the need to ensure the national and collective security of the UK and its allies.” (United Kingdom, 1) 28. Despite these examples, many submissions indicate that efforts to strengthen export controls are the exception rather than the rule and, in any case, have done little to alter the weak and fragmented state of export controls. In Latin America, for example, there is still an “overall lack of clear, precise, unambiguous and detailed laws, administrative regulations, judicial decisions and/or other policies to regulate the export, import and use of surveillance technology.” (AI Sur, 2) Membership in the Wassenaar Arrangement has had “little meaningful effect” on the surveillance practices of Argentina and Mexico. (Id.) Sanctions 29. In addition to the legal frameworks discussed above, sanctions have been used to control transfer of some surveillance technologies. For example, Council Regulation (EU) 36/2012 imposed a ban on the sale, supply, transfer or export of “surveillance equipment, technology or software whether or not originating in the Union, to any person, entity or body in Syria or for use in Syria.” (Privacy International, 3) Similar sanctions have been imposed on the sale of surveillance technologies to Iran. (Id.) V. Criticisms of existing frameworks Vague International Standards 30. Several submissions indicate that existing frameworks contain overbroad language that precludes effective regulation of the transfer of surveillance tools and creates potential loopholes for surveillance companies to exploit and circumvent licensing requirements. (RSF, 4; Amnesty International, 5) The issue may be that Wassenaar and the EU Framework were historically created for completely different items such as nuclear goods or components of weapons of mass destruction, and therefore it is difficult to come up with a balanced legal language that “fits for both surveillance technology and “traditional dual use items” (RSF, 4) 31. The lack of clear international standards leads States to adopt contradictory licensing decisions. Even within the EU, States may reach different decisions about certain technologies and which countries they may be exported to. (RSF, 5) The problem of inconsistent standards is further aggravated by the fact that the authorities often depend on non-public information gathered by the national intelligence agencies and for this reason, refuse to participate in intergovernmental intelligence sharing. (Id.) Inadequate Consideration of Human Rights 32. This lack of clarity also guides States away from human rights considerations, and towards highly subjective “geopolitical and strategic deliberations.” (RSF, 5) The close 8