Kazakhstan gets UK's OK for defense exports

The UK Foreign & Commonwealth Office has released its annual Strategic Export Controls report (PDF), in which it reports on military exports over the last year. It includes a few case studies, where it explains the decision-making process behind whether it allows or disallows a certain sale to be made, taking into account human rights, the risk to UK interests, risk that the equipment will be transferred to another country, and so on. This year they had a case study on Kazakhstan, and came to the conclusion that the sale would be OK:

In 2009, an export licence application was received for military rated radio jamming equipment. In view of the capacity of the equipment to jam satellite broadcasts, this application raised concerns regarding Kazakhstan’s human rights record, including internal repression of the media, and freedom of speech.

A detailed risk assessment of this licence application was carried out which included consultations with the FCO’s Human Rights and Democracy Department, on the capability of the goods, and a review of previous consultations with the British Embassy in Astana in respect of identical goods.

The technical assessment of the equipment revealed that, whilst the equipment could be used for satellite jamming, this would be technically difficult. The technical assessment also revealed the wide availability globally on the open market of a number of systems which could be used to jam satellites and which were cheaper and more effective at satellite jamming. It was therefore concluded that this equipment would not have been sourced for that purpose. In light of this assessment the application was approved because the goods were likely to be used for their stated end use and accordingly, there was no clear risk that they might be used for internal repression.

They reached a different conclusion about Turkmenistan the year before (PDF):

In 2008 an export licence was received for dual-use radio jamming equipment for the Turkmenistan Ministry of National Security. We were informed that the equipment was ordered by the Ministry of National Security for use by a military unit. Little further information on the end use of the equipment was provided. This application raised concerns with regards to Turkmenistan’s human rights record, clarity over the final end user and end use of the equipment. To judge the risk of this equipment being used in human rights abuses, we consulted our Embassy in Ashgabat, the geographical lead department on Turkmenistan and the Human Rights and Good Governance Group.

Post informed us that the goods were very similar to equipment already used on a daily basis by the Turkmen authorities in order to monitor the public. Separately, the Human Rights and Good Governance Department advised that there are severe restrictions on privacy and basic freedoms, with journalists who co-operate with foreign media being subject to harassment and arbitrary detention. A recent high profile example arose during the EU/Turkmen human rights dialogue in June 2008, when a journalist working for Radio Free Europe was picked up by the security services, moved from prison to prison and allegedly tortured. He was eventually released after international pressure.

With minimal information on the end user and without further clarity over the end use, the FCO assessed that, under the Consolidated Criteria, a clear risk existed that these goods could be used for internal repression, as the equipment had a clear application in intercepting calls and locating and tracking individuals, which the Turkmen authorities are known to employ. The application was therefore refused under Criterion 2.

As far as I know, the U.S. doesn't produce any report like this. Does anyone know of any other countries which do?