Few innovations have spread through conflict and organized crime as rapidly as drones. When police in Rio de Janeiro raided the Comando Vermelho gang in 2025, they were faced with a barrage of bombs dropped by drone. The craft are commonly used to smuggle drugs across India and Iran’s borders, and in 2022, Spanish police seized sea drones capable of carrying illicit loads of up to 200 kilograms. Mexican gangs use the technology for reconnaissance and contraband, and now deploy sophisticated counter-drone capabilities.  

Like the Kalashnikov rifle, drones have become ubiquitous worldwide, thanks to their low cost, accessibility and lethal potential. Yet if the international arms control system has struggled to curb the proliferation of AK-pattern weapons, it appears even less fit to tackle the rise of drone technology.  

The new weapon of choice

Organized crime groups across Europe have long benefited from the plentiful supply of AKs from the former Yugoslavia, and are similarly now adapting to the widespread availability of unmanned aerial vehicles diverted from the war in Ukraine. Seizures of illicit weapons in the region increasingly include both AK pattern rifles and drones. In July 2026, an Italian prosecutor warned that mafia groups were supplementing their stocks of ex-Yugoslav weapons with drones from the war’s black market.  

The comparison between drones and the AK-47 is a common one in the public imagination. In 2010, Denis MacShane, the former UK delegate to NATO, called for a European drone capability based on the Kalashnikov model: ‘robust, simple to make and easy to use’. China has also used the analogy, calling its CH-4 unmanned aerial vehicle an ‘AK-47 of drones’, with a ‘design philosophy’ focused on adaptability, reliability and cost. Similarly, military experts commonly refer to Iran’s rugged, cheap and low-tech Shahed drone as the ‘AK-47 of the skies’. 

The parallel has its limitations. Drones are less durable and often more technically demanding, and are widely used for legitimate civilian purposes, such as search and rescue operations or farming. More fundamentally, the comparison draws attention away from a larger issue: drones challenge the assumptions on which existing arms control frameworks were built.  

Old rules, new threats

The treaties and political instruments that govern conventional arms were largely developed in response to the proliferation challenges of the 20th century, for which the AK-47 became the defining symbol. They assume that weapons are identifiable, durable objects that move through military supply chains and can therefore be regulated through controls on their manufacture, transfer, marking and tracing.  

The Arms Trade Treaty, adopted in 2013 after decades of efforts to establish international standards, reflects many of these assumptions. It established important obligations for states to regulate transfers, assess export risks and maintain national control systems. These mechanisms were designed for weapons – such as the AK-47 – whose global spread historically occurred through state production, licensed manufacture, military exports and subsequent diversion into illicit markets.  

Drones, however, are not typically transferred as complete weapons systems. Motors, batteries, processors, flight controllers and communications modules may each be acquired lawfully from different suppliers before being assembled into a military capability. The Arms Trade Treaty’s focus on identifiable weapons and tangible components does not account for systems built from commercially available parts. 

The point is reinforced by the United Nations Programme of Action on Small Arms and Light Weapons, introduced in 2001 in response to growing concern over the extraordinary global spread of guns like the AK-47, and the more recent Global Framework for Through-life Conventional Ammunition Management. Both recognize that arms can remain in circulation long after manufacture, making stockpile security and diversion prevention essential. Drones require a similar approach, but one that extends beyond physical platforms to include less tangible elements such as software, firmware, technical knowledge and production capacity. 

Moreover, drone systems have no permanent identity. Airframes, flight controllers, communications modules, payloads and software may all be replaced independently during a platform’s operational life. Firearms such as the AK, by contrast, can be identified through their marked receiver, the core component bearing the weapon’s serial number, which enables their chain of custody to be traced across decades.  

The International Tracing Instrument was developed around this premise. Effective tracing requires a fundamentally different model that combines physical serial numbers with digital identifiers, firmware records, operator and controller records, procurement histories and communications data. Similarly, the Firearms Protocol of the UN’s Convention against Transnational Organized Crime (UNTOC) provides a model for internationally agreed offences covering illicit manufacture, trafficking, marking and record keeping. Future governance frameworks for drones, however, will need equivalent provisions for modification, brokering and the deliberate removal or manipulation of digital identifiers.  

On the ground, the same combination of commercial availability, technical expertise and criminal facilitation that sustained the circulation of AK-47s is increasingly evident in illicit drone markets. As the UNTOC emphasizes, successful disruption of these activities will depend on dismantling the networks responsible for financing, procuring, transporting and adapting illicit weapons.  

Existing arms control frameworks already contain many of the principles needed to address emerging technologies. For decades, however, legislation has focused on regulating the transfer of weapons, a model ill-suited to modular, digitally enabled, commercially sourced and continuously reconfigured drone technologies. The future of arms control will therefore depend on whether treaties designed for the Kalashnikov era can adapt to the drone age.  

Photo credit: U.S. National Guard photo by Joseph Siemandel.