Comments on the U.S. Commerce Department’s Proposed Country Group C: Destinations of Diversion Concern

U.S. Department of Commerce
Bureau of Industry and Security
Regulatory Policy Division
Room H2705
14th Street and Pennsylvania Avenue, NW
Washington, DC 20230

RE: Comments on Advance Notice of Proposed Rulemaking – Country Group C: Destinations of Diversion Concern

Dear Sir or Madam,

The Wisconsin Project on Nuclear Arms Control submits the following comments in response to the Bureau of Industry and Security’s February 26, 2007, Advance Notice of Proposed Rulemaking (72 Fed. Reg. 8315), which proposes to designate Country Group C in the U.S. Export Administration Regulations for countries that are “Destinations of Diversion Concern.”

The Project is a non-profit organization that conducts outreach and public education to stop the proliferation of mass destruction weapons and their means of delivery. For more than twenty years, the Project has pursued its mission by advocating strong and effective export and transit controls worldwide. The Project commends the Commerce Department for considering whether to designate countries that are of diversion concern, and endorses such designations in principle.

There is no question that diversion of sensitive items compromises the effectiveness of U.S. export controls, undermines international counterproliferation efforts, and could help terrorists and their state sponsors. Particularly dangerous are transit hubs that do not check adequately what passes through their territory – through negligence or willful disregard. A stark example of this danger was provided recently by the revelations that the A. Q. Khan nuclear proliferation network trafficked its wares mostly through the United Arab Emirates (U.A.E.), which is one of the largest transit points in the world. The Wisconsin Project has documented more than two decades of diversions through the U.A.E. to India, Iran, Pakistan and other proliferant countries. This history is detailed in an article the Project published in the New York Times and in a chronology from the Project’s Risk Report database, both of which are enclosed. These diversions from the U.A.E. continue to the present day.

To read the complete letter, click here:  Comments on the U.S. Commerce Department’s Proposed Country Group C: Destinations of Diversion Concern