Iran continues to obtain electronic components with military applications through Hong Kong-based shell companies. This brief examines the application of a novel U.S. policy designed to target this pipeline to a longstanding China-based Iranian procurement network.
Export Controls & Sanctions
The Wisconsin Project conducts research and advocacy to support robust controls on strategic goods and enforcement of autonomous and international sanctions. Export controls and sanctions are powerful means of inhibiting the spread of technologies used to make weapons of mass destruction. Listed below is a selection of the Wisconsin Project’s work in these areas, including analysis of export control enforcement cases, Iran sanctions violations, and commentary on U.S. export control policy.
The Cat’s Out of the Bag: Counterproliferation Lessons from the Curious Case of Limbach Engines
Shahed drones have been the iconic symbol of arms proliferation in recent years. This report traces the history of Iran’s and, subsequently, Russia’s efforts to procure and mass-produce the German-designed engines that power Shahed suicide drones and the role played by Chinese investors in making those engines available to them.
Sanctioned Sector Analysis: Russian Shipping
The Russian shipping sector is essential to the Kremlin’s oil and gas exports, military logistics, and weapons imports from Iran and North Korea.
Sanctioned Sector Analysis: Russian Private Military Companies (PMCs)
Russia uses PMCs internationally and domestically to support policy goals without committing conventional forces.
AUKUS Can Work Without Gutting U.S. Export Control Laws
The United States has the most comprehensive series of military export controls in the world, implemented through the International Traffic in Arms Regulations. Yet, this year those controls have faced their biggest challenge in a decade – an attempt from industry and some in Congress to tar it as a threat to U.S. national security, and a barrier to the AUKUS security partnership between the U.S., U.K., and Australia.
Red Flags in Real Cases: Enforcement and Evasion of Russia Sanctions
Illustrates common red flags using examples from U.S. export enforcement cases and other sanctions-related investigations.
Sidestepping Sanctions: How a Pakistani Procurement Network Circumvents Trade Restrictions
A network based in Pakistan and the UAE continues to acquire sensitive goods for Pakistan’s nuclear and missile programs.
Sweeping U.S. Lists Seek to Restrict Trade and Investment that Support the Chinese Military
Describes U.S. sanctions and regulatory tools targeting China’s military-industrial complex.
Hearing on “China’s Nuclear Forces”
On June 10, 2021, Valerie Lincy appeared before the U.S.-China Economic and Security Review Commission to deliver prepared testimony at their hearing on "China's Nuclear Forces." The Commission has asked her to comment on China's role in the proliferation of missile and nuclear technologies, both as a supplier and an end user, the Chinese entities that are involved in such activities, and the extent to which these activities have affected U.S. national security interests and the global nonproliferation regime.
DPRK Advisory: Seller Beware!
US government publishes advisory on North Korean missile procurement and provides list of missile-related items.