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Iran Nuclear Milestones: 1967-2017

1967: Start-up of the U.S.-supplied 5-megawatt Tehran Research Reactor (TRR).

1970: Iran signs the Nuclear Nonproliferation Treaty (NPT).

1974: Atomic Energy Organization of Iran (AEOI) is established.

1979: German construction of the Bushehr nuclear power reactors, begun in the mid-1970s, is suspended.

Mid-1980s: Iran conducts laboratory scale experiments to produce heavy water at the Esfahan Nuclear Technology Center (ENTC).

1981-93: Iran carries out bench scale preparation of UO2 (uranium dioxide) at ENTC, and bench scale preparation of several uranium compounds, including UF6 (uranium hexafluoride), at the Tehran Nuclear Research Centre (TNRC).

1985: Iran launches a centrifuge enrichment program.

1987: Iran receives an offer from a foreign intermediary that includes a disassembled P-1 centrifuge, drawings and specifications for centrifuge production and for a “complete plant,” and materials for 2,000 centrifuge machines; Iran claims to have received only drawings and some centrifuge components from the intermediary.

1987-88: Bushehr reactors are heavily damaged by Iraqi bombing raids.

1988: Iran approves a project for the production of polonium-210 in the Tehran Research Reactor; in conjunction with beryllium, polonium-210 can be used as a neutron initiator in some nuclear weapon designs.

1988: Iran signs an agreement with Argentina for the provision of fuel elements for the Tehran Research Reactor, containing 115.8 kg of uranium enriched to up to 20% U-235.

1988-93: Iran irradiates 7 kg of UO2 targets at the Tehran Research Reactor and extracts small quantities of plutonium from some of the targets.

1988-95: Iran conducts centrifuge research and development at TNRC.

1990: Iran signs a ten-year nuclear cooperation agreement with China.

1991: Iran illicitly imports 1,800 kg of uranium in the form of UF4 (uranium tetrafluoride), UF6, and UO2.

1991-2000: Iran’s secret laser enrichment program consumes 30 kg of undeclared uranium metal. Iran claims to have achieved an average enrichment level of 8-9% U-235, with some samples approaching 15% U-235.

1992: After a week-long inspection in Iran, an International Atomic Energy Agency (IAEA) team finds no evidence that Iran has a nuclear weapon program.

1993: The Central Intelligence Agency (CIA) says Iran is 8-10 years away from acquiring nuclear weapons and says foreign assistance will be critical to the effort.

1994: Iran signs a contract with China’s National Nuclear Corporation for the supply of two 300-megawatt power reactors.

1994-96: Iran receives drawings for the P-1 centrifuge, components for 500 P-1 machines, and drawings for the more advanced P-2 centrifuge.

1995: Iran signs a contract with Russia to complete one of the Bushehr reactors.

July 1995: Iran purifies some of the plutonium extracted between 1988 and 1993 at TNRC and prepares a disc from the solution.

Mid-1990s: Iran decides to construct a heavy water reactor.

October 1997: The U.S. reveals that, in “written, confidential communications” to U.S. officials, China has pledged that it will not engage in new nuclear cooperation with Iran. The pledge exempts two existing Chinese projects in Iran: a “Zero Power Reactor” and a “Zirconium Tube Factory.”

February 1998: American pressure forces Turboatom, a Ukrainian manufacturer of steam turbines, to abandon its $45 million deal to supply turbines to Bushehr.

March 1998: The CIA reports that Iran is “attempting to acquire fissile material and technology for weapons development” under the guise of establishing a nuclear fuel cycle for its civilian energy program.

April 1998: Russia proposes to build a research reactor in Iran fueled by 20% enriched uranium.

August 1998: Iran purifies additional plutonium extracted between 1988 and 1993 at TNRC and prepares a second disc from the solution.

1999-2002: Iran conducts a series of undeclared centrifuge tests at the Kalaye Electric Company. Using imported UF6, Iran achieves an enrichment level of 1.2% U-235.

April 1999: The Izhorskiye Zavod machine-building company of St. Petersburg begins production of equipment for the primary circuit at Bushehr, including the reactor vessel, steam generator casing, and internals.

2000: Construction begins on a uranium ore concentration plant at Gchine, known as “Project 5/15.”

March 2000: The Iran Nonproliferation Act is signed into law, authorizing the President to sanction foreign persons for proliferation-related transfers to Iran since January 1, 1999.

April 2000: The Czech government, under pressure from the United States, bans companies from supplying parts to Bushehr. The ZVVZ Milevsko company had planned to provide air conditioning equipment.

June 2000: Russia’s deputy minister for atomic energy says the Bushehr plant will be completed in 2002. Russia is expected to earn $1 billion from the project.

July 2000: Iran provides the IAEA with preliminary design information on the Uranium Conversion Facility (UCF) under construction at ENTC.

October 2000: The Director of the CIA’s Nonproliferation Center testifies before Congress that Iran is attempting to develop the capability to produce both plutonium and highly enriched uranium (HEU).

March 2001: After pressure from the United States, Russia reportedly cancels plans to sell Iran laser equipment that could be used to support uranium enrichment.

Early 2002: The AEOI contracts with a private company to develop the P-2 centrifuge. The company develops carbon composite rotors for the centrifuge and conducts some mechanical tests without nuclear material.

Early 2002: Iran’s Ministry of Defense allegedly begins a warhead development program that involves the design of a re-entry vehicle for the Shahab-3 missile; this re-entry vehicle is assessed by the IAEA as “quite likely” able to accommodate a nuclear warhead.

August 2002: The National Council of Resistance of Iran (NCRI), an Iranian opposition group, reveals the existence of a secret nuclear facility at Natanz and a heavy water facility at Arak. According to the NCRI, the two sites are operated under the cover of front companies, Kala-Electric and the Mesbah Energy Company.

September 2002: Iran announces at the IAEA General Conference that it has an “ambitious” plan to construct, within the next 20 years, nuclear power plants with a total capacity of 6,000 MW.

December 2002: The existence of nuclear facilities at Arak (heavy water production plant) and Natanz (fuel enrichment complex) is confirmed by commercial satellite photographs.

February 2003: During discussions held with the IAEA, Iranian authorities acknowledge that a workshop at Kalaye had been used to produce centrifuge components, but claim that it had not enriched any uranium.

9 February 2003: Iranian President Mohammad Khatami announces that Iran is preparing to exploit uranium deposits discovered near Yazd, is building a yellowcake production plant nearby, is building an enrichment plant near Kashan, has completed a uranium oxide plant in Isfahan, and plans to build a fuel production facility.

21-22 February 2003: IAEA Director General Mohamed ElBaradei visits two new uranium enrichment facilities under construction at Natanz: a pilot fuel enrichment plant (PFEP) intended to hold 1,000 centrifuges, and a commercial-scale fuel enrichment plant (FEP), intended to hold more than 50,000 centrifuges. Iran also confirms the construction of a heavy water production plant at Arak.

5 May 2003: Iran informs the IAEA of its intention to construct a heavy water research reactor, the 40 MW(th) Iran nuclear research reactor (IR-40), at Arak. Iran also declares its intention to begin construction of a fuel manufacturing plant at Esfahan.

27 May 2003: The NCRI claims that Iran is operating two nuclear enrichment “sub-stations” for its main site at Natanz. According to the NCRI, the two sites are located in the Hashtgerd region, at Ramandeh, and at Lashkar Abad.

25 June 2003: Iran introduces UF6 into the first centrifuge at Natanz.

9-12 August 2003: The IAEA informs Iran that sampling results from the pilot plant at Natanz reveal particles of two types of HEU, indicating the possible presence of undeclared nuclear material. Iran claims that the contamination came from imported centrifuge components.

19 August 2003: Iran begins testing a small ten-machine centrifuge cascade at Natanz with UF6. The IAEA reports that the centrifuges at Natanz have been recognized as “an early European design;” they are referred to in subsequent IAEA reports as P-1 or IR-1 centrifuges.

October 2003: The IAEA reports that Iran is finalizing the installation of a 164 machine cascade at the Natanz pilot plant.

21 October 2003: Foreign Ministers from Britain, France and Germany meet with Iranian officials and release a joint statement in which Iran agrees to adhere to the Additional Protocol and agrees voluntarily to suspend all uranium enrichment and reprocessing activities.

10 November 2003: Iran informs the IAEA that it will allow enhanced inspections under the Additional Protocol pending its entry into force, and that it will suspend all enrichment-related and reprocessing activities as of November 10.

18 December 2003: Iran signs the Additional Protocol.

1 February 2004: A senior Pakistani official tells journalists that A.Q. Khan has signed a detailed confession admitting that between 1989 and 1991 he provided Iran with designs, drawings, and components for the production of fuel for nuclear weapons.

24 February 2004: Iran informs the IAEA that it will stop manufacturing, testing, and assembling centrifuges as of March. However, Iran says that some centrifuge manufacturing will continue under existing contracts.

24 February 2004: The IAEA reports that Iran failed to declare its work on the more advanced P-2 centrifuge, and on efforts to produce polonium-210, which can be used as a neutron initiator in some nuclear weapons, and which took place between 1989 and 1993. In addition, environmental samples taken from Kalaye show greater than trace quantities of uranium enriched to 36% U-235.

29 March 2004: The head of the AEOI announces the suspension of centrifuge construction.

21 May 2004: Iran submits its initial declaration to the IAEA in compliance with the Additional Protocol. In the declaration, Iran provides information on the Gchine mine and mill, the Saghand mine, and the Ardakan Yellowcake Production Plant.

1 June 2004: In a report, the IAEA confirms Iran’s suspension of enrichment and reprocessing activities, and concludes that Iran produced milligram quantities of plutonium, rather than the 200 micrograms estimated by Iran.

28 June 2004: The IAEA takes environmental samples at the Lavisan-Shian site in Tehran, which has been linked to alleged undeclared nuclear activities. According to Iran, the site was razed by the Municipality of Tehran during a two to three month period beginning in December 2003.

July 2004: Iran removes seals from equipment and centrifuge components located at NatanzPars Trash, and Farayand Technique and returns the seals to the IAEA.

August 2004: Iran begins processing about 37 tons of yellowcake at the UCF.

1 September 2004: The IAEA reports that it found particles of 54% U-235, with U-236 contamination, in samples taken from the surfaces of imported centrifuge components, which supports Iran’s claim that the HEU contamination found at Kalaye and Natanz came from imported components. However, information from the country that provided the components indicates that not all Iranian HEU contamination may have originated in that country.

15 November 2004: The governments of France, Germany, and Britain, with the support of the European Union (E3/EU), reach an agreement with Iran in which Iran again agrees to suspend “all enrichment related and reprocessing activities” in return for the promise of nuclear, technological, and economic cooperation.

15 November 2004: The IAEA releases a report listing more than a dozen failures by Iran to meet its Safeguards obligations. The report reveals that uranium enriched to about 70% U-235 has been found in samples taken from Kalaye and on imported components stored at Natanz and Pars Trash.

17 November 2004: The NCRI accuses Iran of relocating nuclear activities from the Lavisan-Shian site to the Modern Defensive Readiness and Technology Center, both controlled by the Ministry of Defense.

18 November 2004: U.S. Secretary of State Colin Powell tells the media that the U.S. government has information suggesting that Iran is working on designs for mating a nuclear warhead to a missile.

22 November 2004: The IAEA installs seals and other tamper-indicating devices at the UCF to verify that no additional yellowcake is introduced into the uranium conversion process and that there is no further production of UF6.

18 February 2005: At the UCF, Iran completes conversion of 37 tons of yellowcake into ammonium uranyl carbonate (AUC), UF4 and UF6. The IAEA seals the UF4 and UF6 produced during this process and installs and seals cameras at UF6 withdrawal stations to ensure that there is no undeclared withdrawal of the UF6 remaining in the plant’s process lines.

27 February 2005: Tehran and Moscow reportedly sign an agreement in which Russia would supply fuel for the Bushehr reactor, and Iran would return all spent fuel to Russia.

March 2005: The IAEA confirms that construction on the heavy water reactor building at Arak has started.

11 March 2005: The United States decides to stop blocking Iran’s application to join the World Trade Organization and to consider on a case-by-case basis its attempts to buy spare parts for civilian aircraft, in support of European diplomacy with Iran.

May 2005: A U.S. National Intelligence Estimate on Iran assesses with “high confidence” that Iran is determined to develop nuclear weapons and that Iran could produce enough fissile material for a weapon by the end of the decade, if Iran progressed more rapidly than it has to date.

25 May 2005: Centrifuge components and uranium samples from Pakistan are reportedly received by the IAEA’s main laboratory, where they will be compared with traces of enriched uranium found in Iran.

13 June 2005: The IAEA reveals that Iran conducted plutonium separation experiments as recently as 1998, five years beyond the date previously cited by Iran.

28 July 2005: The NCRI alleges that Iran is using front companies to purchase maraging steel, which can be used to make solid rocket motor cases, propellant tanks, missile interstages, and centrifuge rotors.

5 August 2005: E3/EU offer Iran assured access to light-water reactor fuel, confirm support for Iranian accession to the WTO, and support the sale of civilian aircraft parts to Iran. In exchange, Iran must abandon its heavy water reactor at Arak and end fuel cycle activities other than the construction and operation of light water power and research stations, subject to future review.

8 August 2005: Iran rejects the European proposal, citing a disregard for Iran’s right to access nuclear fuel production and uranium enrichment. On the same day, Iran begins feeding yellowcake into the first part of the process line at the UCF.

2 September 2005: The IAEA reports that samples taken from centrifuge components received from a Member State support Iran’s claims about the foreign origin of most HEU contamination, but that it is not yet possible “to establish a definitive conclusion with respect to all of the contamination, particularly the LEU contamination.”

24 September 2005: The IAEA Board of Governors finds Iran in “non compliance” with its NPT Safeguards Agreement and refers Iran to the U.N. Security Council.

16 November 2005: Iran begins a new conversion campaign at the UCF using 150 drums of yellowcake.

18 November 2005: The IAEA reveals that Iran possesses a document with instructions on how to reduce UF6 to metal and how to cast and machine enriched, natural, and depleted uranium metal into hemispheres, a form used in nuclear weapon components.

January 2006: Iran removes IAEA seals at NatanzFarayand Technique, and Pars Trash and begins “substantial renovation” of the gas handling system at the Natanz pilot plant and quality control of centrifuge components and some rotor testing at Farayand Technique and Natanz.

31 January 2006: The IAEA reveals Iran’s alleged “Green Salt Project,” which involves work on the conversion of U02 into UF4 (“green salt”), tests related to high explosives, and designs for a missile re-entry vehicle, all of which appear to have administrative interconnections.

6 February 2006: Iran informs the IAEA that it will suspend implementation of the Additional Protocol.

11 February 2006: At the Natanz pilot plant, Iran begins feeding UF6 gas into a single P-1 machine, and four days later into a 10-machine cascade.

March 2006: Iran completes and begins testing the 164-machine cascade at Natanz using UF6.

29 March 2006: The U.N. Security Council issues a presidential statement calling on Iran to suspend all enrichment and reprocessing activities.

13 April 2006: Iran reports that it has enriched uranium to 3.6%, a level which IAEA sampling tends to confirm.

31 May 2006: U.S. Secretary of State Condoleezza Rice announces that the United States is willing to conduct direct talks with Iran “as soon as Iran fully and verifiably suspends its enrichment and reprocessing activities.”

June 2006: Iran again feeds UF6 into the first 164-centrifuge cascade at its Natanz pilot plant, claiming to achieve an enrichment level of 5% U-235.

31 July 2006: The U.N. Security Council adopts resolution 1696, which “demands that Iran suspend all enrichment-related and reprocessing activities” by August 31, or face possible sanctions.

26 August 2006: Iranian President Mahmoud Ahmadinejad inaugurates the heavy water facility at Arak. The AEOI reportedly claims that the facility is capable of producing heavy water with 99.8% purity.

13 October 2006: Iran begins injecting UF6 gas into the second 164-centrifuge cascade at its Natanz pilot plant.

23 December 2006: The U.N. Security Council adopts resolution 1737, imposing sanctions to prevent the transfer to Iran of materials, as well as technical or financial assistance, which might contribute to Iranian nuclear and ballistic missile development. The resolution also designates Iranian persons and entities for which financial resources are to be frozen.

31 January 2007: Iran transfers some 8.7 tons of UF6 to its commercial-scale Fuel Enrichment Plant (FEP) at Natanz.

9 February 2007: The IAEA decides to end or limit four of fifteen national technical cooperation projects in Iran, and eighteen of forty regional or interregional projects involving Iran, in accordance with U.N. Security Council resolution 1737.

17 February 2007: IAEA inspectors are informed that Iran has installed and is operating under vacuum two 164-centrifuge cascades at its FEP, and that two additional such cascades are under construction.

24 March 2007: The U.N. Security Council adopts resolution 1747, imposing further sanctions to prevent the transfer of arms and financial assistance to Iran, and designating additional Iranian persons and entities for which financial resources are to be frozen.

29 March 2007: Iran reverts to an arrangement under which design information on the construction of new nuclear facilities is provided to the IAEA “normally not later than 180 days” before the introduction of nuclear material; the IAEA contests the decision.

23 April 2007: The European Union adopts an arms embargo against Iran and freezes the assets of 23 Iranian entities linked to nuclear or missile proliferation.

13 May 2007: Iran is operating eight 164-centrifuge cascades at its FEP, with two additional cascades being vacuum tested and three more under construction. An enrichment level of 4.8% U-235 has been achieved at the plant, according to Iran.

21 August 2007: The IAEA and Iran agree to a “work plan” for the resolution of outstanding issues, which include: experiments involving plutonium and polonium-210; the acquisition of P-1 and P-2 centrifuge technology; the origin of uranium contamination; Iran’s possession of a document describing how to produce enriched uranium metal hemispheres; activities at the Gchine mine; and alleged studies involving uranium conversion, high explosive testing, and the design of a missile re-entry vehicle.

30 August 2007: The IAEA reports that questions regarding Iran’s past plutonium experiments have been resolved.

November 2007: In a U.S. National Intelligence Estimate, the intelligence community judges “with high confidence” that Iran halted its nuclear weapon program in fall 2003, but assesses “with moderate-to-high confidence” that Iran “at a minimum is keeping open the option to develop nuclear weapons.” The intelligence community further judges with “moderate confidence” that Iran would be capable of producing enough HEU for one nuclear weapon between 2010 and 2015.

3 November 2007: Iran is operating eighteen 164-centrifuge cascades with UF6 at the FEP; IAEA measurements indicate a maximum enrichment level of 4% U-235.

8 November 2007: Iran informs the IAEA that it is conducting mechanical tests on a “new generation of centrifuge design.”

15 November 2007: The IAEA concludes that Iran’s statements regarding the past acquisition of P-1 and P-2 centrifuge technology are largely consistent with Agency findings.

December 2007: The IAEA requests preliminary design information for the nuclear power plant to be built in Darkhovin.

12 December 2007: The IAEA verifies the inventory of uranium processed at the FEP: 1,670 kg of UF6 have been processed, yielding about 75 kg of low-enriched UF6.

January 2008: Iran installs a new subcritical centrifuge (IR-2) at the Natanz pilot plant, including a single machine and a 10-machine cascade; the single machine is tested with UF6.

February 2008: Iran receives fresh fuel assemblies (reportedly 82 tons) for its Bushehr reactor from Russia.

22 February 2008: The IAEA reports that questions regarding Iran’s polonium-210 experiments and the Gchine uranium mine and mill are “no longer outstanding at this stage.”  The IAEA also reports that Iran’s explanations regarding the source of uranium contamination found on equipment at a technical university and the nuclear procurement activities of a former head of the Physics Research Center (PHRC) are “not inconsistent” with the Agency’s current knowledge.

25 February 2008: IAEA Deputy Director General Olli Heinonen briefs member states, including Iran, on allegations of Iranian nuclear weapon development, including interconnected projects, overseen by Iran’s Ministry of Defense Armed Forces and Logistics (MODAFL), for converting UO2 to UF4 (Green Salt Project), for testing high power explosives, and for designing a missile re-entry vehicle.

3 March 2008: The U.N. Security Council adopts resolution 1803, extending travel restrictions and asset freezes – and in some cases instituting a travel ban – to additional Iranian entities, and barring Iran from buying almost all nuclear and missile-related technology.  The resolution also requests countries to inspect suspect cargoes to and from Iran, and to “exercise vigilance” over public financial support for business with Iran and transactions involving Iranian banks, particularly Bank Saderat and Bank Melli.

April 2008: Iran processes UF6 in a new sub-critical centrifuge (IR-3) installed at the Natanz pilot plant.

7 May 2008: At the FEP, Iran is operating 3,280 IR-1 centrifuges with UF6; 2,624 additional such machines are being installed.

June 2008: Iran receives a nuclear incentives proposal on behalf of Britain, China, France, Germany, Russia, and the United States (the P5+1). The proposal promises assistance with light-water reactors, guaranteed nuclear fuel supply, and, in the future, support for nuclear research and development.

23 June 2008: The European Union imposes financial sanctions on 26 Iranian entities linked to nuclear and missile work, including Bank Melli, its branches, and subsidiaries.

July 2008: A meeting between Iran and P5+1 countries ends in deadlock when Iran fails to respond to the “freeze for freeze” offer, under which no additional U.N. sanctions would be adopted if Iran refrained from increasing its uranium enrichment capacity.

September 2008: The U.N. Security Council adopts resolution 1835, which calls on Iran to comply with previous Security Council resolutions by freezing uranium enrichment but does not impose additional sanctions.

October 2008: Intelligence reports allege that Iran has tested ways of recovering highly enriched uranium from fuel used in the Tehran research reactor and converting the material into metal.

November 2008: Iran is reportedly using exclusively domestically mined, milled and converted uranium as the feedstock for its enrichment program, after overcoming difficulties at its Uranium Conversion Facility.

1 February 2009: An IAEA inventory at FEP reveals that Iran processed 9,956 kg of UF6 between February 2007 and November 2008, yielding 839 kg of low-enriched UF6.

9 February 2009: The process line for the production of heavy water reactor fuel is complete and fuel rods are being produced at the Fuel Manufacturing Plant.

25 February 2009: A pre-commissioning ceremony is held at the Bushehr Nuclear Power Plant. A test run of the plant marks the end of the construction phase.

March 2009: Iran allegedly receives over 100 Swiss-origin pressure transducers, with nuclear applications, via Chinese and Taiwanese companies.

March-May 2009: Iran begins testing several new centrifuges at the Natanz pilot plant, including a modified version of the IR-2 (the IR-2m) and the IR-4.

9 April 2009: Iranian President Mahmoud Ahmadinejad inaugurates the Fuel Manufacturing Plant, which Iran claims is able to produce, annually, 10 tons of natural uranium fuel for the 40 megawatt Arak heavy water reactor and 30 tons of low-enriched uranium fuel for use in light-water reactors.

June 2009: At the FEP, Iran is enriching uranium in 4,920 IR-1 centrifuges; 2,132 additional centrifuges are installed and under vacuum, and 169 centrifuges are installed.

10 August 2009: Iran estimates that it has produced about 366 tons of uranium in the form of UF6 at the UCF since March 2004; an IAEA inventory at the plant largely confirms this estimate.

9 September 2009: The U.S. envoy to the IAEA tells a meeting of the IAEA Board of Governors that the United States assesses that “Iran is now either very near or in possession already of sufficient low-enriched uranium to produce one nuclear weapon, if the decision were made to further enrich it to weapons-grade.”

22 September 2009: Iran submits a letter to the IAEA with preliminary design information for the Darkhovin nuclear power plant, which is described as a 360 MWe pressurized water reactor, the construction of which is scheduled to start in 2011.

25 September 2009: The United States, France, and Britain reveal that Iran has been building a secret uranium enrichment plant near Qum (the Fordow Fuel Enrichment Plant) whose size and configuration is “inconsistent” with a peaceful nuclear program.

1 October 2009: During nuclear talks with the P5+1, Iran agrees to allow the IAEA to inspect the Qum enrichment plant and agrees “in principle” to export its stockpiled low-enriched uranium so that the material can be processed into fuel for the Tehran Research Reactor.

2 October 2009: Leaked excerpts of a draft IAEA report, “Possible Military Dimensions of Iran’s Nuclear Program,” reveal that Iran may have a program to develop a nuclear payload for delivery on its Shahab-3 missile and that Iran may have developed a high explosive implosion system that could be used in a nuclear weapon. The IAEA assesses that Iran should be able to design and produce a workable implosion device fueled with highly enriched uranium.

19-21 October 2009: A draft technical agreement is concluded between Iran and France, Russia, and the United States, under which Iran’s low-enriched uranium would be converted into fuel for the Tehran research reactor.

25-28 October 2009: IAEA inspectors visit the recently disclosed Fordow (Fordo) uranium enrichment plant, located 20 km north of Qum, and verify that it is designed to house about 3,000 centrifuges and that it is “at an advanced stage of construction.” Iran claims that construction began in 2007 and that the plant will be operational in 2011; the Agency has evidence that construction began earlier.

2 November 2009: At the FEP, Iran is enriching uranium in 3,936 IR-1 centrifuges; 4,756 additional such centrifuges are installed.

4 November 2009: Satellite photographs reportedly suggest that Iran has increased the production rate at its Gchine uranium mine, near the city of Bandar Abbas.

15 November 2009: Iran completes clean out at UCF; 371 tons of UF6 have been produced at the plant between March 2004 and August 2009.

22 November 2009: Results of an IAEA inventory at the FEP reveal that Iran processed 21,140 kg of UF6 between February 2007 and November 2009, yielding a total of 1,808 kg of low enriched UF6.

27 November 2009: The IAEA Board of Governors adopts a resolution urging Iran immediately to suspend construction on the enrichment plant at Qom (the Fordow plant) and to comply with Security Council resolutions.

9 January 2010: The IAEA learns that Iran is conducting research and development work on the electrochemical production of uranium metal at the Jabr Ibn Hayan Multipurpose Research Laboratory (JHL) in Tehran.

9 February 2010: Iran begins the production of uranium enriched up to 20% U-235 in a single cascade of 164 IR-1 centrifuges at the Natanz pilot plant.

9 April 2010: Iran claims to have produced and tested a third generation centrifuge, which AEOI chief Ali Akbar Salehi says is six times more efficient than previous models.

May 2010: In a joint declaration with Brazil and Turkey, Iran agrees to send 1,200 kilograms of low-enriched uranium to Turkey in exchange for the provision of 120 kg of fuel for the Tehran Research Reactor.

9 June 2010: The U.N. Security Council adopts resolution 1929, imposing a fourth round of sanctions on Iran. This adds to previous sanctions by extending an asset freeze and travel ban to additional Iranian entities, including some within the Islamic Revolutionary Guard Corps and the Islamic Republic of Iran Shipping Lines, and by barring Iran from acquiring any interest in commercial nuclear activities abroad, and from importing most conventional arms.

23 June 2010: Iran has 17 kg of 20% enriched uranium and can produce up to 5 kg each month, according to AEOI chief Ali Akbar Salehi.

1 July 2010: U.S. President Barack Obama signs into law the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (H.R. 2194), or CISADA.  It targets firms that support Iran’s energy sector, do business with Iranian entities on the U.S. government blacklist, and sell telecommunication and other sensitive technology to Iran. The law also authorizes state and local governments to divest from firms involved in Iran’s energy sector.

13 July 2010: Iran begins enriching uranium to 20% U-235 in a second cascade of 164 IR-1 centrifuges at the Natanz pilot plant, interconnecting it with the first cascade.

July 2010: The European Union, Canada, and Australia adopt new autonomous sanctions against Iran, specifically targeting Iran’s energy, banking, and shipping sectors.

August 2010: Iran begins transferring fresh fuel to the Bushehr Nuclear Power Plant.

3 September 2010: Japan adopts new sanctions against Iran, specifically targeting Iran’s energy, banking, and shipping sectors; the assets of 15 Iranian banks are frozen.

8 September 2010: South Korea adopts new financial sanctions against 126 Iranian entities, including the Seoul branch of Bank Mellat, and announces a ban on investment in Iran’s energy sector.

18 September 2010: Iran has processed 352 kg of low-enriched UF6 at the Natanz pilot plant since February 2010, yielding 25.1 kg of UF6 enriched to 20% U-235.

17 October 2010: Results of an IAEA inventory at the FEP reveal that Iran processed 34,737 kg of natural UF6 between February 2007 and October 2010, yielding a total of 3,135 kg of low-enriched UF6.

5 November 2010: Of 54 cascades (8,426 IR-1 centrifuges) installed at the FEP, about 29 (4,816 centrifuges) are being fed with UF6. Each installed cascade originally comprised 164 centrifuges; Iran modified six cascades to contain 174 centrifuges.

Mid-November 2010: Iran briefly suspends all uranium enrichment at the FEP and then resumes enrichment in 28 centrifuge cascades on November 22.

29 November 2010: Iranian President Mahmoud Ahmadinejad says that “a cyberbug” may have created “problems for a limited number of our centrifuges.” Security researchers would later attribute these problems to the Stuxnet worm, which targets frequency converter drives that control high-speed motors, such as those used to spin centrifuges.

December 2010: Iran ships a consignment of domestically produced “yellowcake” from the Gachin (Gchine) mine to UCFAEOI chief Ali Akbar Salehi claims that Iran is no longer reliant on imported yellowcake.

January 2011: Norway and Switzerland impose more stringent sanctions on Iran, including restrictions on cooperation in the oil and gas sectors; the new measures bring both countries in line with E.U. legislation.

7 April 2011: The NCRI, an Iranian opposition group, says it has identified a secret industrial site in Tehran’s western suburbs used for manufacturing centrifuge parts. The “Iranian Cutting Tools Factory,” or TABA, produces casings, magnets, molecular pumps, composite tubes, bellows, and centrifuge bases, according to the NCRI.

12 April 2011: Iran confirms it is producing centrifuge components at TABA, but says the site is outside the IAEA’s jurisdiction.

24 May 2011: The European Union imposes sanctions against 77 persons or entities associated with Iran’s nuclear or ballistic missile programs, in addition to dozens of front companies operated by the Islamic Republic of Iran Shipping Lines (IRISL), Iran’s national shipping company.

24 May 2011: Referring to possible military dimensions to Iran’s nuclear program, the IAEA expresses concern over “experiments involving the explosive compression of uranium deuteride to produce a short burst of neutrons.”

27 August 2011: Iran’s Aerospace Industries Organization (AIO) inaugurates the country’s first carbon fiber production line. Carbon fiber composites can be used to make centrifuge rotors.

September 2011: The Bushehr Nuclear Power Plant joins the national power grid.

September 2011: Iran has processed 720.8 kg of low-enriched UF6 at the PFEP since February 2010, yielding 73.7 kg of UF6 enriched to 20% U-235, according to an IAEA inventory.

October 2011: Results of an annual IAEA inventory at the FEP confirm that Iran has processed 55,683 kg of natural UF6 between February 2007 and October 2011, yielding a total of 4,871 kg of low-enriched UF6.

November 2011: Iran’s Supreme Leader Ali Khameini reportedly authorizes secret direct talks with the United States over Iran’s nuclear program.

2 November 2011: Of 54 cascades (approximately 8,000 centrifuges) installed at the FEP, 37 cascades (6,208 centrifuges) are being fed with UF6.

8 November 2011: The IAEA expresses “serious concerns regarding possible military dimensions to Iran’s nuclear programme” and details what it calls “credible” information about weaponization-related activities.

21 November 2011: Canada prohibits the export of additional items that could be used in Iran’s nuclear program and sanctions additional entities of proliferation concern.

9 December 2011: Expressing “deep and increasing concerns” about Iran’s nuclear program, Japan freezes the assets of 106 entities, three banks, and one individual.

14 December 2011:  Iran begins enriching uranium at the underground Fordow Fuel Enrichment Plant (FFEP) near Qum, feeding low-enriched UF6 into 348 IR-1 centrifuges and producing 20% enriched uranium.

January 2012: Iran increases the number of centrifuges devoted to the production of 20% enriched uranium at the Fordow enrichment plant by 348.  A total of 696 IR-1 centrifuges are operating at the plant.

23 January 2012: The European Union announces new sanctions targeting sources of finance for Iran’s nuclear program, including a ban on imports of Iranian crude oil and petroleum and petrochemical products, an asset freeze on Iran’s Central Bank, and a prohibition on trade in gold, precious metals, and diamonds with Iranian public bodies.

February 2012: Iran irradiates domestically produced fuel assemblies at the Tehran Research Reactor, including fuel plates and fuel rods containing natural and enriched UO2 and 20% enriched uranium.

15 March 2012: The European Union announces new sanctions that prohibit companies, such as the Society for Worldwide Interbank Financial Telecommunication (SWIFT), from providing financial messaging services to EU-sanctioned Iranian banks, effectively shutting them out of the global banking system.

April 2012: Iran and the members of the P5+1 meet in Turkey to discuss Iran’s nuclear program, the first such meeting in some 15 months.

May 2012: Iran and members of the P5+1 meet in Baghdad to continue discussion about Iran’s nuclear program.  E.U. foreign policy chief Catherine Ashton says that the two sides found “some common ground,” but that “significant differences remain.”  P5+1 proposals focus on winning a suspension of enrichment to 20% and the export of Iran’s current stock of this material, in exchange for spare parts for Iran’s civilian aircraft and nuclear safety assistance.

June 2012:  Nuclear talks in Moscow between the P5+1 and Iran end without a breakthrough.

July 2012: A preliminary, working-level meeting is held in the secret nuclear talks between the United States and Iran in Oman.

1 July 2012: European Union sanctions targeting sources of finance for Iran’s nuclear program take effect, including a ban on imports of Iranian crude oil and a prohibition on providing insurance for the transport of Iranian oil.

30 August 2012: The IAEA reports that satellite imagery shows demolition of buildings at the Parchin military site and “significant ground scraping.” This site has been linked to nuclear weapon development.

1 September 2012: Iran and North Korea sign a science and technology cooperation agreement. Supreme Leader Ali Khameini declares that the two countries have “common enemies.”

15 September 2012: Iran has produced 129.1 kg of UF6 enriched to 20% U-235 at the PFEP, according to an IAEA inventory.

October 2012: The European Union expands export restrictions on Iran to include graphite, metals, and software for industrial processes, and adopts additional restrictive measures on Iran’s transport, financial, and energy sectors.

October 2012: Results of an annual IAEA inventory at the FEP confirm that Iran has processed 85,644 kg of natural UF6 between February 2007 and October 2012, yielding a total of 7,451 kg of low-enriched UF6.

10 November 2012: Of 61 fully installed cascades at the Natanz FEP (10,414 centrifuges), 54 are being fed with UF6. Preparatory installation work is completed for 28 other centrifuge cascades, and is ongoing in relation to 54 others. All the centrifuges are IR-1s.

November 2012:  The IAEA reports that Iran has completed centrifuge installation at the Fordow plant, which now holds 2,784 IR-1 machines, of which 696 are enriching uranium. The plant has produced an estimated 95.5 kg of UF6 enriched to 20% U-235 since the beginning of operations in December 2011.

11 December 2012: Canada expands sanctions against Iran, targeting 98 individuals and entities in oil and gas, mining, metals, and shipping.

21 December 2012: The European Union sanctions 18 entities and one individual because of their involvement in nuclear activities or their support for the Iranian government.

January 2013: The Bushehr reactor comes back online after a two month shutdown, during which the reactor’s fuel was removed from the core.

6 February 2013: Iran begins installing IR-2m centrifuges at the Natanz FEP. The IAEA notes this is “the first time that centrifuges more advanced than the IR-1 have been installed in FEP.”

10 February 2013: At the Fordow site, Iran estimates it has now produced 129.9 kg of UF6 enriched to 20% U-235.

23 February 2013: Iran announces the discovery of new uranium deposits and selects 16 sites for the construction of nuclear power plants.

27 February 2013: The P5+1 negotiating partners meet with Iran in Almaty, Kazakhstan and propose that Iran keep enough 20% enriched uranium to fuel a research reactor and that Iran suspend enrichment work at the Fordow plant rather than close the plant. No deal is reached.

March 2013: The United States and Iran hold three days of secret nuclear talks in Oman.  Deputy Secretary of State William Burns reportedly delivers a message from President Obama that the United States would be willing to accept a limited domestic uranium enrichment program in a final nuclear agreement with Iran.

2 April 2013: In an interview with the Associated Press, IAEA Director General Yukiya Amano says that the Agency has “information indicating that Iran was engaged in activities relevant to the development of nuclear explosive devices in the past and now.”

6 April 2013: Negotiations in Almaty, Kazakhstan between Iran and the P5+1 over Iran’s nuclear program end in failure.

9 April 2013: Iran starts production at two uranium mines – Saghand 1 and 2 – and at the Shahid Rezaeinejad yellowcake plant at Ardakan.

6 May 2013: The IAEA confirms that the reactor vessel has arrived at the Arak heavy water reactor site and that “major components” have been installed at the reactor.

15 May 2013: Of 79 IR-1 cascades (13,555 centrifuges) at the FEP, 53 cascades are being fed with UF6.  Preparatory installation work has been completed for 46 other cascades, and is ongoing for one other.  Four IR-2m cascades (689 centrifuges) are also installed at the FEP, though none are being fed with UF6.

22 May 2013: The IAEA reports that a “significant proportion” of the disputed Parchin military site has been covered with asphalt.

29 May 2013: Canada adopts a total ban on imports from and exports to Iran and adds 30 individuals and 82 entities to its blacklist because of their involvement in proliferation activities.  This list contains a total of 508 entities and 78 individuals.

9 June 2013: Iran installs the main reactor vessel at the Arak heavy water reactor.

14 June 2013: Hassan Rouhani, the former lead nuclear negotiator under President Mohammad Khatami, is elected President of Iran.

6 August 2013: In his first press conference, Iranian President Hassan Rouhani calls for the resumption of “serious and substantial” talks with the P5+1 over Iran’s nuclear program.

16 August 2013: Iranian President Hassan Rouhani appoints former Foreign Minister Ali Akbar Salehi as head of the Atomic Energy Organization of Iran (AEOI), replacing Fereydoun Abbasi-Davani.  Salehi previously served as the head of AEOI from 2009 to 2010.

24 August 2013: Of 89 IR-1 cascades (15,416) fully installed at the FEP, 54 cascades are being fed with UF6.  One other IR-1 cascade is partially installed, and preparatory installation work has been completed for 36 other IR-1 cascades.  Of six cascades of IR-2m centrifuges (1,008 centrifuges) fully installed at the FEP, none are being fed with natural uranium.  Preparatory installation work has been completed for 12 other 1R-2m cascades.

5 September 2013: Iranian President Hassan Rouhani appoints Foreign Minister Javad Zarif as the country’s chief nuclear negotiator.

23 September 2013: Iran takes control of the 1,000-megawatt Bushehr nuclear reactor from Russia.

26 September 2013: The foreign ministers of the P5+1 countries meet with Iranian Foreign Minister Javad Zarif on the sidelines of the U.N. General Assembly in New York.  U.S. Secretary of State John Kerry and Foreign Minister Zarif then meet separately in the highest level meeting between the two countries since 1979.

16 October 2013: Nuclear talks between Iran and the P5+1 in Geneva, Switzerland end with the parties announcing another round of talks on November 7 and 8.

9 November 2013: Negotiations in Geneva, Switzerland between Iran and the P5+1 end without a deal.

9 November 2013: Of 90 IR-1 cascades (15,420) fully installed at the FEP, 52 cascades are being fed with UF6.  Preparatory installation work has been completed for 36 other IR-1 cascades.  Of six cascades of IR-2m centrifuges (1,008 centrifuges) fully installed at the FEP, none are operating.  Preparatory installation work has been completed for 12 other 1R-2m cascades.

11 November 2013: Iran and the IAEA issue a Joint Statement on a Framework of Cooperation, aimed at resolving the IAEA’s outstanding questions about Iran’s nuclear program. The agreement will allow inspectors broader access to nuclear sites, including “managed access” within three months to the Gchine uranium mine and to a heavy water production plant that will supply the Arak reactor.

14 November 2013: The IAEA reports that Iran’s stockpile of 20% enriched UF6 slightly increased to 196 kilograms.

24 November 2013: Iran and the P5+1 reach an interim nuclear agreement, known as the Joint Plan of Action, which is intended to be the first step toward a comprehensive accord to be completed in six months.  Iran agrees to suspend uranium enrichment above 5%, dilute or convert its stockpile of 20% enriched uranium, and to limit other parts of its nuclear program.  In return, Iran will receive temporary relief from some economic sanctions and access to up to $7 billion in frozen assets.

8 December 2013: IAEA inspectors visit the Arak heavy water reactor, for the first time in over two years, as part of the November 2013 agreement between Iran and the IAEA.

20 January 2014: The Joint Plan of Action takes effect.  The IAEA confirms that Iran has suspended production of 20% enriched uranium and started to dilute or convert its uranium stockpile. In exchange, Iran receives limited sanctions relief for six months.

29 January 2014: An IAEA team conducts a “managed inspection” of Iran’s Gchine uranium mine near the city of Bandar Abbas.

17 April 2014: The IAEA confirms that Iran has diluted 104 kg of its stockpile of 20% enriched UF6, about half of the 209 kg Iran had as of January 20, 2014.

23 May 2014: The IAEA reports that Iran is complying with the terms of the interim nuclear agreement.  The Agency also discloses that Iran supplied data about work on “exploding bridge wire detonators” – which Iran said were for non-nuclear purposes – as part of the IAEA’s investigation into the possible military dimensions of Iran’s nuclear program.

18 July 2014: Iran and the P5+1 agree to extend talks on Iran’s nuclear program until November 24.  Under the extension, Iran will receive access to an additional $2.8 billion in frozen assets.

20 July 2014: The IAEA reports that Iran has converted 100 kg of 20% enriched UF6 into uranium oxide, leaving it with 0.6 kg of 20% enriched UF6.

5 September 2014: The IAEA reports that Iran has failed to address concerns about the possible military dimensions of its nuclear program by an August 25 deadline.  Specifically, Iran did not provide the IAEA with information regarding experimentation with high explosives and calculations on nuclear detonation yields.

11 November 2014: Iran and Russia sign an agreement for Russia to construct two new reactors at the Bushehr Nuclear Power Plant in the short term.  The agreement allows for two additional reactors to be built at Bushehr in the future and for the construction of four nuclear reactors at another location in Iran.  The fuel for all reactors will be supplied by Russia, and spent fuel will be returned to Russia.  Separately, Russia and Iran signed a Memorandum of Understanding for joint work on “the feasibility of assembling fuel bundles in Iran.”

24 November 2014: Nuclear talks between Iran and the P5+1 in Vienna are once again extended, with the intention of reaching the broad outlines of a deal by March 2015 and a final agreement by June 30, 2015.  The interim agreement, the Joint Plan of Action, will continue to be implemented.

19 February 2015: The IAEA reports that Iran continues to comply with the terms of the interim nuclear agreement but is still evading questions related to the Agency’s longstanding investigation of the possible military dimensions of Iran’s nuclear program.

2 April 2015: Iran and the P5+1 reach agreement on a framework for a comprehensive nuclear agreement, which will limit Iran’s nuclear program in exchange for the lifting of international sanctions.

22 May 2015: President Obama signs the Iran Nuclear Agreement Review Act into law.  The legislation, which passed both houses of Congress by veto-proof majorities, gives Congress a 60-day period to review a final nuclear agreement with Iran after it is transmitted to Congress.

24 June 2015: Iran’s Guardian Council ratifies legislation that bans international access to Iranian military sites and scientists, while permitting conventional inspections of declared nuclear sites in Iran.

14 July 2015: Iran and the P5+1 reach final agreement on an accord, known as the Joint Comprehensive Plan of Action (JCPOA), which imposes limits on Iran’s nuclear program in return for sanctions relief from the European Union, United States, and United Nations.

14 July 2015: Iran and the IAEA sign a “Road-Map” agreement intended to resolve all outstanding questions in the Agency’s investigation of the possible military dimensions to Iran’s nuclear program.

20 July 2015: The U.N. Security Council unanimously passes resolution 2231 that endorses the JCPOA and will lift many of the U.N. sanctions on Iran once the IAEA verifies that Iran has met its commitments under the deal.

12 August 2015: Switzerland officially lifts its sanctions against Iran, becoming the first country to remove its sanctions since the nuclear agreement was reached July 14.

10 September 2015: Democrats in the U.S. Senate block a vote on a resolution to disapprove the JCPOA.

11 September 2015: The U.S. House of Representatives votes to reject a resolution to approve the JCPOA.  The House declines to vote on a resolution of disapproval.

17 September 2015: The U.S. Senate votes to block an amendment that would have conditioned the lifting of U.S. sanctions on Iran to Iran’s recognition of the state of Israel and the freeing of U.S. prisoners in Iran.  The 60-day Congressional review ends without blocking the implementation of the nuclear agreement.

21 September 2015: IAEA Director General Yukiya Amano confirms that Iran has submitted environmental samples from the Parchin military base, which is a suspected site of nuclear weapons experimentation.  The samples were reportedly collected by Iranians under IAEA monitoring by video and still cameras and GPS tracking.

15 October 2015: The IAEA announces that it has completed its investigation into Iran’s alleged past nuclear weapons work.

18 October 2015: Iran and the P5+1 formally adopt the JCPOA.  The United States issues conditional sanctions waivers for Iran, which will take effect when the agreement is officially implemented.  Iran informs the IAEA that it will provisionally implement the Additional Protocol.

21 October 2015: Iran’s Supreme Leader, Ali Khamenei, conditionally endorses the Joint Comprehensive Plan of Action in a letter addressed to President Hassan Rouhani.

2 December 2015: The IAEA’s final report on Iran’s alleged efforts to develop a nuclear weapon concludes that Iran had a coordinated nuclear weapon-related program until 2003, and that some weapon-related activities continued through 2009.

15 December 2015: The IAEA Board of Governors votes unanimously to close the Agency’s investigation into Iran’s alleged past nuclear weapons work.

28 December 2015: Iran sends 25,000 pounds (11,000 kg) of low-enriched uranium (including all 20% enriched uranium not contained in fuel plates) to Russia, fulfilling a major requirement of the JCPOA.  In return, Iran receives 137 metric tons of natural uranium from Russia.  Separately, Kazakhstan, at the request of the Joint Commission, supplies 60 tons of natural uranium to Iran as additional compensation.

16 January 2016: Iran and the P5+1 officially implement the JCPOA after the IAEA verifies that Iran has shipped out 98% of its low-enriched uranium; dismantled about 13,000 centrifuges; removed the core of the Arak reactor and filled it with concrete; and sold off its excess heavy water supply.  The European Union lifts its nuclear-related economic and financial sanctions on Iran.  The United States ceases the application of the bulk of its secondary sanctions on non-U.S. persons engaged in Iran’s financial and energy sectors.  Under U.N. resolution 2231, the new U.N. restrictions on nuclear sales to Iran and on missiles and conventional arms take effect.  Previous U.N. resolutions 1696, 1737, 1747, 1803, 1835, 1929, and 2224 are terminated.

23 January 2016: Iran resumes uranium enrichment at the FEP.

24 February 2016: The IAEA confirms that 20 metric tons of heavy water has been shipped out of Iran, bringing the stock of heavy water in Iran to below 130 metric tons.

26 February 2016: 5,060 IR-1 centrifuges remain installed in 30 cascades at the FEP.  1,044 IR-1 centrifuges are maintained in six cascades at the Fordow Fuel Enrichment Plant.  All dismantled centrifuges and associated infrastructure are in storage under IAEA monitoring.

1 March 2016: The U.N. Security Council briefs Members States on the Procurement Working Group, which will oversee sales of nuclear-related items to Iran for ten years.

22 April 2016: The U.S. Department of Energy announces the purchase of 32 metric tons of heavy water for $8.6 million from a subsidiary of the Atomic Energy Organization of Iran (AEOI).

26 June 2016: Iran resumes manufacturing centrifuge rotor tubes.  The IAEA confirms that this production is included in the Agency’s ongoing monitoring and verification of Iran’s inventory of centrifuge rotor tubes, bellows, and related production equipment.

18 July 2016: The Associated Press obtains a confidential document submitted by Iran to the IAEA which details Iran’s long-term uranium enrichment plans.  According to the document, after the first ten years of the JCPOA, Iran will begin replacing currently installed centrifuges with a more powerful model.  Between 2027 and 2029, Iran plans to install 2,500 to 3,500 advanced centrifuges, estimated to be up to five times as efficient as the current model.

10 September 2016: Iran and Russia inaugurate the construction site for two new reactors at the Bushehr Nuclear Power Plant, based on an agreement signed in November 2014.

9 November 2016: The IAEA reports that Iran’s stockpile of heavy water is 130.1 metric tons, exceeding the 130 ton limit set by the JCPOA.  Iran tells the Agency that it plans to export five tons of heavy water.

6 December 2016: The IAEA verifies that Iran has shipped 11 metric tons of heavy water to Oman, bringing its heavy water stock below the 130 ton limit under the JCPOA.

13 December 2016: In response to the United States’ extension of the Iran Sanctions Act (ISA), Iranian President Hassan Rouhani orders the AEOI to begin research and development of nuclear fuel for naval propulsion.  President Rouhani also directs Foreign Minister Javad Zarif to file a formal complaint with the JCPOA Joint Commission regarding the ISA extension.

20 December 2016: An AEOI spokesman announces that Iran plans to export some 20 tons of heavy water per year, down from the 70 tons the country sold over the previous year.

21 December 2016: The IAEA makes public a series of decisions exempting Iran from some of the nuclear restrictions set forth in the JCPOA.  Enriched uranium contained in low-level solid, liquid, or sludge waste and 20% enriched uranium in laboratory contamination are deemed “unrecoverable.”  In addition, low-enriched uranium fuel irradiated or tested at the Tehran Research Reactor (TRR) under specific conditions does not count as part of Iran’s enriched uranium stockpile and Iran may continue to operate 19 hot cells with dimensions greater than the six cubic meter volume limit set by the JCPOA.  These decisions were taken by the JCPOA‘s Joint Commission between January and December 2016.

January 2017: The P5+1 approve a 116 metric ton shipment of natural uranium from Russia to Iran, the first such transfer since the implementation of the JCPOA.  The shipment serves as compensation to Iran for the country’s export of heavy water.

15 January 2017: IAEA Director General Yukiya Amano confirms that Iran has removed excess centrifuges and infrastructure from the Fordow Fuel Enrichment Plant, in compliance with its obligations under the JCPOA.

21 January 2017: Iran begins injecting UF6 gas into more powerful IR-8 centrifuges as part of its uranium enrichment research and development plan.  Iran claims that the enrichment capacity of the IR-8 is twenty times greater than that of the first-generation IR-1 centrifuge.

24 February 2017: The IAEA reports that Iran’s stock of low-enriched uranium is 101.7 kg, with some material, including 99.9 kg of enriched uranium stuck in the process lines in a plant at Esfahan, exempted by the JCPOA Joint Commission.  The Agency also reports that Iran’s stock of heavy water is 124.2 metric tons, which is below the 130 ton limit set by the JCPOA.

25 February 2017: Iran announces it will purchase 950 metric tons of yellowcake from Kazakhstan over the next three years.  The deal requires approval from the JCPOA Joint Commission.

3 March 2017: In a letter to the IAEA, Iran argues that it does not have to export heavy water in excess of the 130 metric ton limit set by the JCPOA until it has found a buyer.  The letter follows a U.S. statement asserting that heavy water above the limit must be shipped out of Iran.

14 March 2017: Iran and Russia begin construction of a new reactor at the Bushehr Nuclear Power Plant.

8 April 2017: Iran and Hungary sign a memorandum of understanding regarding nuclear cooperation.  The two countries agree to collaborate on designing small nuclear reactors.  In addition, Hungarian banks will invest €85 million in Iran to finance joint ventures.

18 April 2017: Iran and the European Commission sign a nuclear safety cooperation agreement.  The €2.5 million project includes a feasibility study for the Nuclear Safety Center envisioned in the JCPOA, support for the Iranian Nuclear Regulatory Authority (IRNA), help with Iran’s accession to international nuclear safety conventions, and help in reviewing the results of a stress test from the Bushehr Nuclear Power Plant.

23 April 2017: Iran and China sign a final agreement on the redesign and modernization of the Arak heavy water reactor, in line with the requirements of the JCPOA.  China will review the new design to confirm its compliance with IAEA and international safety standards.

2 June 2017: The IAEA reports that Iran’s stock of low-enriched uranium is 79.8 kg and that the country’s stock of heavy water reached 128.2 metric tons, which is below the 130 ton limit set by the JCPOA.  The Agency also announces that a heavy water production plant has been shut down for planned maintenance.

Podcast: Transparency in the Iran Nuclear Deal

Valerie Lincy, Executive Director of the Wisconsin Project on Nuclear Arms Control, and CSIS’ Sharon Squassoni discuss what the Joint Comprehensive Plan of Action has meant for the public’s knowledge of Iran’s nuclear program, the reporting mechanisms in the agreement, and approaches that could increase transparency under the deal. This podcast is part of a series of talks by the CSIS Proliferation Prevention Program about transparency and nuclear weapons.

To read the Iran Watch report on which this podcast is based, click here: Iran’s Nuclear Veil: How to Increase Transparency under the JCPOA

North Korea’s March Towards ICBM Capability

May 2017

Introduction

North Korea has hundreds of medium and short-range ballistic missiles available for use against regional targets. In addition, it is developing submarine-launched ballistic missiles (SLBMs) and intercontinental ballistic missiles (ICBMs). North Korea conducted several successful SLBM tests in 2016, already has tested several new missile systems in 2017, and may test an ICBM this year. It also is developing longer-range solid-fueled missiles, which are better suited for military purposes.

North Korea has been able to enhance its missile capabilities and transfer missile technology abroad despite international sanctions against its WMD programs. Such defiance is possible due to a mature domestic missile production establishment, a procurement/proliferation network spread throughout the world, and inadequate sanctions enforcement. This report surveys recent ballistic missile tests by Pyongyang, how these tests affect North Korea’s ability to deliver nuclear weapons, the sanctions that have been imposed in response to missile progress, and North Korea’s ongoing missile-related exports to Iran and Syria.

Missiles and Satellite Launchers

Short-range systems

The nuclear-capable Scud short-range ballistic missile is the oldest in North Korea’s arsenal. It dates back to the early 1980s, when it was acquired from Egypt. Since then, Pyongyang has produced its own versions of the Scud B and Scud C systems. The Scud B has an estimated range of 300 km, while the Scud C has an estimated range of 500 km. North Korea has also developed an extended-range version of the Scud B, designated by U.S. intelligence as the Scud ER. This missile has a range of 700-995 km. The Scud is a liquid-fueled missile, first developed by the Soviet Union.

North Korea’s arsenal also includes a number of shorter range nuclear-capable missiles, such as the KN-02 (Toksa). This road-mobile, solid-fueled missile is more accurate and has quicker deployment time than the liquid-fueled Scuds. The range of the original version of the KN-02 is 120 km. North Korea has an enhanced version of this missile, reportedly designated the KN-10, which can travel distances of up to 220 km.

North Korea also has another short-range system, a 300-mm multiple launch rocket (MLRS), which was tested in March 2016. This system may have been deployed at the end of 2016. It is not clear if MLRS will carry nuclear warheads, although it does resemble Pakistan’s nuclear-capable Nasr (Hatf-IX) rocket system.

At the annual military parade in Pyongyang in April 2017, which marks the birthday of late founder Kim Il Sung, North Korea displayed a new short-range missile, similar to the Scud, on a tracked vehicle. This missile, which is believed to be liquid-fueled, is equipped with fins on the nosecone, which would improve its accuracy. The off road capability of the tracked vehicles also makes the missile easier to conceal from preemptive strikes (although it is not known if this missile is nuclear-capable).

Medium/Intermediate-Range Ballistic Missiles

Currently, North Korea’s longest-range deployed ballistic missile is the medium-range liquid-fueled Nodong, which is based on Scud technology. While estimates of the number of Nodong missiles deployed are not available in open sources, the U.S. Department of Defense assessed in 2013 that North Korea had fewer than 50 launchers deployed for the Nodong. With a range of 1,250-1,300 km, this nuclear-capable, road-mobile missile is capable of reaching all of South Korea and parts of Japan. It is estimated to have a payload capacity of 700-750 kg. North Korea has conducted multiple tests of this missile in recent years, often in salvo mode.

In March 2016, North Korea conducted a ground test of a solid-fueled motor that analysts assess may be for the upper stage of a medium-range ballistic missile. Such a missile could one day replace the Nodong. Solid-fueled missiles are preferable because they are easier to conceal and take less time to prepare for launch than liquid-fueled types such as the Nodong.

The Musudan (Hwasong-10) intermediate-range ballistic missile underwent its first series of tests in 2016, with eight tests conducted that year. However, only one test, which was conducted in June, was successful. The Musudan is a single-stage road-mobile missile equipped with a liquid-fueled engine. It is believed to be derived from the Soviet SS-N-6 SLBM. It has an estimated range of 2,500-4,000 km, bringing U.S. bases in Guam and Okinawa within striking distance, and a payload capacity of 500-1,000 kg. Analysts at 38 North, however, assess that the missile’s range is only about 2,100 km with a nuclear payload. The difficulties Pyongyang has had in testing the Musudan show that more work is needed before it can be deployed.

Hwasong-12, May 2017 (Courtesy: Rodung Sinmun)

In May 2017, North Korea conducted the first test of the nuclear-capable Hwasong-12, which was first displayed one month earlier at an annual military parade. A single-stage, liquid-fueled intermediate-range ballistic missile, the Hwasong-12 flew 787 km during the test, reaching a maximum altitude of over 2,000 km over a flight time of approximately 30 minutes, before landing in the Sea of Japan. Because it was launched in a highly lofted trajectory, the range achieved during the test was likely much lower than the potential range of this missile over a standard trajectory, which could exceed 4,000 km.  Pictures released by state media prior to the launch showed the missile on a wheeled transporter, although it is not clear if it was fired from that vehicle. Analysts assess that the Hwasong-12 could be capable of targeting Alaska, in addition to U.S. bases in Guam and Okinawa. This missile will enhance North Korea’s ability to hit regional targets, and brings it a step closer to being able to target the U.S. mainland.

Submarine-Launched Ballistic Missiles and Land-Based Variant

Pyongyang has made progress in recent years in developing the KN-11 (Pukkuksong-1) SLBM, which is a two-stage missile. While range estimates vary, analysts reportedly set a range of nearly 450 km with a 1.5 ton payload, and over 600 km (enough to cover all of South Korea) with a 1 ton payload.

According to the U.N. Panel of Experts, North Korea began work on an SLBM as early as 2012. In May 2015, it conducted a missile ejection test from a submerged platform. Since then, Pyongyang has conducted a series of SLBM test launches.

The initial design of the KN-11, which is believed to have been based on the Soviet SS-N-6/R-27 SLBM, used liquid fuel. North Korea later redesigned the missile. The liquid-fueled engine was replaced with one using solid fuel, which is better suited for deployment on a submarine, while maintaining an exterior similar to the original. The first sea-based test of the KN-11 using solid fuel, which was conducted in April 2016, flew approximately 30 km. During a test of the solid-fueled KN-11 conducted in August of that year the missile flew 500 km before landing in the Sea of Japan, reportedly within Japan’s air defense identification zone.

North Korea is also building ballistic missile submarines at Sinpo shipyard. Sinpo houses North Korea’s only complete ballistic missile submarine, referred to as Gorae-class.

North Korea’s relative success with the KN-11 may have led to its decision to prioritize the development of a land-based variant. This new missile, known as the KN-15 (Pukkuksong-2), was tested for the first time in February 2017 and for the second time in May 2017. The KN-15 is a medium-range road-mobile, solid-fueled missile. In the February test, the missile flew approximately 500 km before landing in the Sea of Japan. Analysts assess that the missile has a range of roughly 1,250 km, although that range could be much shorter with a nuclear payload. After its most recent test, Pyongyang announced that the missile is ready for deployment and serial production.

Intercontinental Ballistic Missiles

North Korea displayed a new road-mobile ICBM (likely a mockup) during the annual military parade in April 2012. The missile is designated as KN-08 (Hwasong-13). It is a three-stage, liquid-fueled missile with a range of 11,500 km with a 500 kg warhead, theoretically capable of reaching most of the United States mainland.

In October 2015, North Korea displayed four modified KN-08 missiles during a military parade. This version has a reconfigured nosecone and is shorter in length when compared to the original. This modified version is referred to alternately as the KN-14 or the KN-08 Mod 2. It is a liquid-fueled missile assessed to be two stages and to have a 10,000 km range with a 500 kg warhead.

North Korea has made strides over the past several years in ICBM development. It is believed to have conducted a series of engine tests for the KN-08 in 2014. Then in April 2016, Pyongyang tested a “new type of high power engine” for the first stage of an ICBM. Analysts assess that the unit was a pair of liquid engines intended for the KN-08 or KN-14.

At the April 2017 parade, North Korea displayed two new canistered ICBM designs. They were rolled out on transporter erector launchers (TELs) capable of traveling on unpaved roads. The first design resembles Soviet and Chinese ICBMs, and is believed to be a variant of the KN-14. The second is believed to be another variant of the KN-11 SLBM, known as the Pukkuksong-3, a solid-fueled missile that uses cold launch technology. It is not clear how far along Pyongyang is in the development of these new technologies. But once deployed, the incorporation of canisters and cold launch systems will improve the survivability of North Korea’s ICBMs and shorten response time.

Recent statements by North Korean officials, including leader Kim Jong Un, indicate that the regime may test an ICBM sometime in 2017. However, North Korea must still master reentry vehicle technology, which is a critical component of a reliable ICBM.

Satellite Launch Vehicles

North Korea is progressing steadily in its development of satellite launchers. In December 2012, it successfully placed a satellite into orbit for the first time. The satellite was launched aboard the Taepodong-2 (Unha-3) rocket. Pyongyang successfully placed a second satellite into space in February 2016, reportedly using a rocket with an even longer range. The Taepodong-2 (TD-2) is liquid-fueled, using Scud and Nodong engines, and can be equipped with either two or three stages. North Korea tested a new, large rocket engine in September 2016, and another in March 2017. Analysts assess that these engines also use liquid fuel, and that the engine tested in September will likely be used for satellite launchers. U.S. officials told CNN, however, that the March test was part of a series of tests of engines that could eventually be used in an ICBM. The engine from the March test was also reportedly used in the Hwasong-12 launch in May 2017.

If the TD-2 were to be reconfigured as an ICBM, it could have a range of 10,000-15,000 km with a 500-1,000 kg warhead.

Warhead Miniaturization

Kim Jong Un announced in March 2016 that his country has successfully developed a miniaturized nuclear warhead capable of being mounted on a ballistic missile. Pyongyang also claimed that it confirmed its reentry vehicle capability in the May 2017 launch of the Hwasong-12, although that has not been confirmed. While Washington is skeptical of Pyongyang’s miniaturization claims, in March 2016 the head of the North American Aerospace Defense Command (NORAD) informed Congress that U.S. forces operate under the assumption that North Korea is capable of miniaturizing a nuclear warhead and mounting it onto an ICBM. He also assessed that North Korea has an ICBM technically capable of reaching the United States and Canada. He acknowledged, however, that if such a warhead were mated with an ICBM, the weapon’s reliability would be very low.

Procurement Network

Despite international sanctions, North Korea continues to procure items for its missile program from abroad. Korea Tangun Trading Corporation, a subsidiary of the Second Academy of Natural Sciences, oversees Pyongyang’s WMD-related procurements. Tangun was sanctioned by the Security Council in 2009.

North Korea uses shell companies all over the world to procure sensitive material for its nuclear and ballistic missile programs. This evasion technique is regularly employed by North Korea’s shipping sector. In 2014, Pyongyang’s Ocean Maritime Management Company (OMM) was sanctioned by the Security Council for its role in an illicit shipment of weapons from Cuba to North Korea. Prior to sanctions, OMM was one of North Korea’s largest shipping companies. Since then, it has transferred control of its fleet to an elaborate network of front companies scattered around the world, and has also renamed most of its vessels in an attempt to circumvent international sanctions. In addition, North Korea is believed to use embedded agents in foreign companies and as diplomatic personnel.

Private Chinese companies in particular are a source of sensitive missile technology. In 2015, a company based in Shenyang reportedly supplied North Korea with milling machines that can be used to manufacture missile components. In addition, North Korea is believed to have converted six lumber transporters supplied to it by a Chinese company in 2011 into TELs for ballistic missiles. Another Chinese company supplied Pyongyang with the truck used to transport the KN-11 SLBM in the annual military parade in April 2017. Also at the parade, one of the new ICBMs was reportedly rolled out on a vehicle jointly developed by a Russian and a North Korean company. The vehicle was later converted into a TEL by Pyongyang.

Components from the former Soviet Union, China, South Korea, Switzerland, the United Kingdom, and the United States were found in the debris from the December 2012 and February 2016 launches of the TD-2.  These items, many of which are un-restricted, included transmitters, electric cables, camera electromagnetic interference (EMI) filters, field programmable gate arrays, frequency converters, and a video decoder. These products are often imported via China or Taiwan.

These findings indicate that North Korea is able to build missiles without outside assistance, while it continues to rely on foreign sources for raw materials and technology. North Korean banks support illicit procurements as well, by providing financial services to blacklisted entities and handling money related to WMD programs.

Sanctions

In response to Pyongyang’s refusal to cease its nuclear and ballistic missile programs, the international community has imposed increasingly severe sanctions. In 2006, the U.N. Security Council passed Resolution 1695 (2006), which requires U.N. member states to block the sale to North Korea of materials that could be used in its ballistic missile program. Later that year, after the first nuclear test, the Security Council passed resolution 1718 (2006), imposing a range of sanctions, including prohibitions on the import to or export from North Korea of battle tanks, heavy artillery, combat aircraft systems, warships, items applicable to its nuclear or ballistic programs, and luxury goods. Since then, the Security Council has passed several additional rounds of sanctions.

The latest round of sanctions was imposed in November 2016 in response to the September nuclear test. Resolution 2321 (2016) places additional restrictions on North Korea’s access to the international banking system and dual-use and luxury items. The resolution places a cap on North Korea’s annual coal exports (its largest source of revenue), limits the number of bank accounts North Korean diplomatic/consular facilities and personnel can hold, prohibits North Korea’s export of certain minerals, and requires member states to “seize and dispose” restricted items bound for North Korea. It also places restrictions on North Korea’s shipping sector, requiring the de-registering of North Korean vessels and preventing access to insurance.

The Security Council resolutions additionally impose financial and travel restrictions against organizations and individuals connected to North Korea’s nuclear and ballistic missile programs. To date, 39 individuals and 42 organizations have been designated by the Security Council since North Korea conducted its first nuclear test in 2006.

These measures have targeted some of the main entities in charge of North Korea’s missile program. For example, the Munitions Industry Department, sanctioned by the Security Council in March 2016, develops the KN-08, and oversaw development of the TD-2. This department also oversees other entities involved in the missile program, including the Second Economic Committee and the Second Academy of Natural Sciences. The Second Economic Committee, also sanctioned in March 2016, oversees the production of North Korea’s ballistic missiles. The Second Academy, which was sanctioned by the Security Council in March 2013, oversees missile research and development. The Security Council has also targeted the Korean Committee for Space Technology (aka National Aerospace Development Administration), Pyongyang’s official space agency. This entity oversees the development of satellite launchers and carrier rockets.

Other important entities have yet to be targeted by the Security Council. One example is the Strategic Rocket Force Command. Since its unveiling in 2012, the Command has conducted numerous ballistic missile tests, including tests of Scuds and the Nodong. In addition, Korea Ryonhap (Yonhap) Trading Corporation, a Second Economic Committee subsidiary, has reportedly overseen the acquisition of technology for missile development and continues to trade in missile-related metals.

The following banks and financial institutions have also been sanctioned by the Security Council: Amroggang Development Banking Corporation, Bank of East Land, Daedong Credit Bank, Korea Kwangsong Banking Corporation, Ilsim International Bank, Korea Daesong Bank, Korea United Development Bank, and Tanchon Commercial Bank.

In recent months, Japan, the European Union, South Korea, and the United States have sought to increase pressure on Pyongyang by implementing or expanding autonomous sanctions. These measures further restrict North Korea’s access to foreign goods and currency.

International sanctions have been the main tool used to curtail Pyongyang’s nuclear weapon and ballistic missile efforts, but have had limited impact.  This is due in part to weak enforcement by China, North Korea’s largest trading partner and transit point for most of its WMD-related material. Recent developments suggest that this may be changing. In February 2017, Beijing reportedly announced that it will suspend all imports of coal from North Korea until the end of the year. In addition, it recently released a comprehensive list of dual-use products prohibited from export to North Korea.

Proliferation to Other Countries

North Korea also is a supplier of ballistic missile-related technology, in particular for Iran and Syria. The key organizations involved in this illicit supply network are Tanchon Commerical Bank (mentioned above), Korea Mining Development Trading Corporation (KOMID) (which is directed by the Second Economic Committee), Leader (Hong Kong) International, and Green Pine Associated Corporation. These entities have all been sanctioned by the Security Council. Green Pine, which produces submarines and missile systems, took over many of KOMID’s activities after the latter was sanctioned in 2009. Green Pine is now responsible for approximately half of North Korea’s weapons-related exports. According to the U.N. Panel of Experts, this entity operates a network of front companies based primarily in China.

Iran

According to the U.S. State Department, Pyongyang started exporting complete Scud missile systems to Tehran in the late 1980s. Missile-related collaboration has continued ever since. Iran’s Shahab-3 missile, for example, is based on the Nodong. Pyongyang collaborates with Tehran’s key missile-related entities in the development of ballistic missile technology, including the Shahid Hemmat Industrial Group (SHIG). North Korea supplies Iran with ballistic missile-related items, including valves, electronics, measuring equipment for missile tests, and likely jet vanes for ballistic missiles. Missile technicians from SHIG also recently collaborated with North Korea on the development of an 80-ton rocket booster.

Syria

Pyongyang has supplied Damascus with Scud missiles and related technology for ranges of 500-700 km. U.S. intelligence believes that Syria achieved its ability to produce missiles domestically in large part due to North Korean assistance. This assistance has come in the form of technical guidance and the supply of missile-related technology and equipment. Shipments intercepted in recent years contained items such as artillery shells, graphite cylinders used in ballistic missiles, and equipment that can be used to produce liquid propellant for Scuds. These shipments were sent primarily to front companies of the Syrian Scientific Studies and Research Center (SSRC), which oversees Syria’s missile program.

Other

North Korea signed an agreement with the Burmese government to develop medium-range liquid fueled ballistic missiles in November 2008, and the following year attempted to transfer equipment used for developing long-range ballistic missiles to Burma. North Korea continued to transfer items to Burmese defense entities until at least 2011-2012. North Korean entities also attempted to ship components for a Scud missile to Egypt in 2013.

Pakistan has also been a recipient of North Korean ballistic missile technology. Pakistan’s Ghauri (Hatf-5) medium-range ballistic missile is based on the Nodong, which was supplied by Pyongyang in the 1990s. In Yemen, Scud missiles believed to have been supplied by North Korea were allegedly used in combat by Houthi-backed militias. In 2015, as many as 20 Scud missiles were fired by Houthi militias into Saudi Arabia. North Korea is known to have shipped Scuds to Yemen in 2002.

Increasing Transparency under the JCPOA

Remarks at the Vienna Center for Disarmament and Non-Proliferation:  “Transparency and the NPT: New Goals and Norms”

Thank you for the invitation to speak today about the need for greater transparency with respect to the implementation of the Joint Comprehensive Plan of Action (JCPOA). The Wisconsin Project has been focused for some time on the proliferation threat posed by Iran, which is reflected on our Iran Watch website. My remarks today are based on a recent Iran Watch report about transparency under the JCPOA.

Courtesy of VCDNP

The agreement promised more information on Iran’s nuclear program and greater access to Iranian facilities. Such transparency was described as one of the primary benefits of the JCPOA by architects of the agreement and its supporters. However, this promise has not been fulfilled. Instead, a sort of diplomatic veil has been drawn over Iran’s nuclear status, obscuring important parts of it from view. Initially, the veil may have been drawn to preserve the agreement, but it is our view that the lack of transparency now raises questions about whether the monitoring, verification, and enforcement measures of the JCPOA are functioning properly.

In our report we look at where, specifically, transparency was expected but has been lacking, and how to increase transparency in these areas in a constructive manner—one that does not seek to upend the agreement or renegotiate its terms. To that end, we have identified two main areas of focus: International Atomic Energy Agency (IAEA) reporting and inspections and Joint Commission decision making. I will focus my remarks on these areas.

Decrease in Detailed IAEA Reporting

Since the implementation of the JCPOA in January 2016, there have been five IAEA reports that narrowly cover Iran’s compliance with the agreement. Each report is short and lacking in detail, which was a surprise, given the detailed nature of reports prior to the nuclear deal. This lack of detail makes independent assessments of Iran’s nuclear status more difficult. Our report includes a chart that compares the level of IAEA reporting before and after the agreement. Some key shortcomings include:

  • No precise inventory of Iran’s low-enriched uranium (LEU) stockpile, including production and flows.
  • No information on parts of the nuclear fuel cycle not covered by JCPOA restrictions, such as natural uranium hexafluoride (UF6) production.
  • Less detail on centrifuge operations, including the number operating and their output.
  • Minimal information on Iran’s research and development work on advanced centrifuges, and no information on how Iran is carrying out its long-term enrichment research and development plan, which it has submitted to the Agency.

On the last point, in the absence of official information from the IAEA, we are forced to make judgments based on incomplete and potentially incorrect information. The Iranian government has made a few public statements about its long-term plans for advanced centrifuges. And the Associated Press published a version of Iran’s enrichment plans. Outside of these disclosures, however, there is limited information on Iran’s plans and a great deal of speculation.

As a result of the JCPOA, Iran is provisionally applying the IAEA’s Additional Protocol and allowing inspectors access to a broader range of sites and information. So, the IAEA is collecting more information but reporting less. Why? Because of language in IAEA and U.N. Security Council resolutions.

As of Implementation Day, IAEA reporting is no longer driven by the Agency’s “absence of confidence that Iran’s nuclear program is exclusively for peaceful purposes.” Rather, a December 15, 2015 Board of Governors resolution decided that the IAEA is “seized of a separate agenda item covering JCPOA implementation and verification and monitoring in light of United Nations Security Council resolution 2231.” As IAEA Director General Yukiya Amano has explained, “as the basis [for reporting] is different, the consequences are different.”

It is possible to return to the IAEA’s previous level of reporting without renegotiating the JCPOA. Resolution 2231 sets the rule for IAEA reporting. It calls on the IAEA to “undertake the necessary verification and monitoring of Iran’s nuclear-related commitments . . . under the agreement,” and asks for “regular updates . . . on Iran’s implementation.”  So, resolution 2231 tells the IAEA what is necessary to inspect but not what is necessary to report. While there is nothing requiring the IAEA to report in detail, there is nothing preventing it either. The United States and its partners party to the JCPOA should push the IAEA to provide more detailed public reporting, despite Iran’s resistance. Greater public knowledge through detailed IAEA reporting is essential for the deal’s long-term success.

Transparency Surrounding Inspections

The JCPOA gives the IAEA much greater latitude in terms of where it can conduct inspections and undertake remote monitoring in Iran. It lays out parameters for accessing both declared nuclear sites and other sites in Iran, as well as containment and surveillance measures for nuclear material not inspected under standard safeguards.

However, once again little is publicly known about how the Agency is using this new latitude. Since Implementation Day, the IAEA reports only that it has conducted “complementary access under the Additional Protocol to sites and other locations in Iran.” In the past, the IAEA gave detailed narrative accounts of its inspections, naming specific sites visited, the dates of inspection, inspection methods, and sometimes even a list of specific equipment inspected and requests to interview Iranian personnel. The IAEA described the issues raised and explanations received by the inspectors, and listed any unresolved questions. This allowed the public to know the questions the IAEA was pursuing, the level of cooperation it was receiving from Iranian authorities, and whether questions were being resolved to the Agency’s satisfaction. Today we no longer get this texture about inspections from IAEA reports.

There is also the question of “challenge” inspections. The JCPOA provides a mechanism for mounting inspections of suspicious, undeclared sites in Iran. The agreement allows the IAEA to request access to a suspicious site and, if Iran refuses, to petition the Joint Commission for access. If five of the eight Commission members agree, then Iran must allow an inspection. This process, including adjudication by the Joint Commission, is meant to take up to 24 days. Since JCPOA implementation, it is unclear whether a single challenge inspection has been sought or mounted. We do not know if the adjudication process in the Joint Commission has been tested or if Iran would indeed allow inspectors access to undeclared sites, including to military sites alleged to be involved in nuclear work, which has been the case in the past.

The IAEA must establish clear modalities for managed access under challenge inspections immediately, perhaps through something resembling an inspection exercise. Both Iran and the inspectors could run through the requirements related to speed and breadth of access, the provision of supporting documents, and interviews with relevant personnel. The lack of transparency related to challenge inspections undermines one of the main mechanisms for ensuring that Iran is not conducting prohibited nuclear work at secret sites, and it must be addressed.

Problem of Confidentiality at the Joint Commission

The JCPOA established a multilateral Joint Commission to act as the dispute resolution and oversight body for the agreement. It includes representatives from each of the P5+1 countries (China, France, Germany, Russia, the United Kingdom, and the United States), Iran, and the European Union. The Joint Commission meets regularly at the working level and the ministerial level and has taken up issues such as nuclear exemptions requested by Iran and the pace of economic relief provided by the JCPOA. Unfortunately, the JCPOA specified that the work of the Commission is confidential, unless its members decide otherwise. And unlike the IAEA, the Commission does not issue even a broad public report, either quarterly or after its meetings. As a result, very little is officially known about these meetings. Outside groups must generally rely on leaked information.

For example, the news that the Joint Commission granted Iran a series of exemptions from nuclear restrictions of the agreement, including in advance of Implementation Day, only came to light because of a report by the Institute for Science and International Security in September 2016. In December 2016, the Commission ultimately released documents related to these exemptions, but the delay raised questions about whether the release covered all Commission decisions through that date.

The Joint Commission has the authority to issue exemptions in a number of sensitive areas, including:

  • Research and development on uranium metal-based fuel
  • Operation of additional or larger hot cells
  • Mechanical testing of new types of centrifuges
  • Uranium enrichment-related exports
  • Acquisition, development, or use of multi-point detonators

It is crucial that Joint Commission deliberations and decisions are presented publicly. The Joint Commission itself is empowered to change the rule imposing confidentiality and should do so in favor of more transparency.

More transparency would also benefit the Joint Commission’s various working groups, in particular the Procurement Working Group (PWG). The PWG reviews proposals for nuclear sales to Iran through an official channel, and it advises the Joint Commission and Security Council on such sales. While the JCPOA describes the procurement channel process, there has been very little information about how it has functioned over the past year. U.N. Secretary General and U.N. facilitator reports have provided useful information, but they are only issued every six months and lack important details. Based on these reports, we know that five proposed sales have been submitted: three were approved and two were under review. However, there is no description of the items, the end-user, or the declared end use. Our main source of information regarding these sales has again been media reports.

It would be useful to know the PWG criteria in reviewing procurement requests, as well as its decisions, both approvals and denials. One way of increasing transparency would to make public reports by the PWG coordinator, which are submitted to the Joint Commission every six months.

Filling the Transparency Gap

Transparency was supposed to be one of the primary benefits of the JCPOA. Indeed, the agreement itself, including technical annexes, was made public. However, there has been a marked decline in transparency since JCPOA implementation. Public reporting on Iran’s nuclear program has shrunk and become more general. Little is known about the various verification and monitoring mechanisms established by the JCPOA and how they are functioning, including Joint Commission decisions, challenge inspections, nuclear exemptions, and nuclear-related procurement requests.

We believe that increased transparency is essential to preserving the agreement. Transparency is a means of demonstrating whether the JCPOA is working, whether the monitoring and verification provisions of the agreement are functioning, and whether the supply-side constraints are respected. Specifically, transparency confirms to all those not party to the agreement that Iran remains at least one year away from being able to fuel one nuclear weapon for a period of 10-15 years at least, which is the JCPOA’s milestone achievement. If Iran is shown to be fulfilling the terms of the agreement, there will be more confidence in Iran’s peaceful intentions. If Iran is nibbling away at the edges of the deal’s restrictions and offering minimal cooperation, then this confidence is undercut.

To read VCDNP’s coverage of the event, click here.

To read the related Iran Watch report, click here: Iran’s Nuclear Veil: How to Increase Transparency under the JCPOA

Treasury Takes Aim at Staff of Key Syrian Proliferator

On April 24, 2017, the United States sanctioned 271 employees of Syria’s Scientific Studies and Research Center (SSRC) in response to the Assad government’s April 4 sarin gas attack in Khan Sheikhoun. These individuals were added to the Treasury Department’s Specially Designated Nationals (SDN) list under Executive Order 13582, which targets the Syrian government and its supporters. In addition to being expeditious – coming just weeks after the sarin attack – this action is noteworthy for the number of individuals designated at one time, and employed by a single entity. The designations aim to further punish SSRC itself, rather than the contribution of any single individual. As such, the action highlights SSRC’s central role in Syria’s non-conventional weapon programs.

SSRC is a Syrian government agency that oversees the development and production of chemical weapons.[1] It also is involved in the development of biological weapons, missiles, and reportedly was connected to Syria’s now-abandoned nuclear weapons program.[2] SSRC oversees the procurement of technology for these programs as well, operating a number of front companies for this purpose. In recent years, these front companies have imported or attempted to import a large number of weapons-related items, primarily from Iran and North Korea. Arms shipments have included graphite cylinders used in rocket nozzles and reentry vehicles,[3] propellant blocks used in Scud missiles,[4] and precursors for the nerve agent soman.[5] The SSRC continues to operate, despite the partial dismantlement of Syria’s chemical weapons program being overseen by the Organization for the Prohibition of Chemical Weapons. The Treasury Department continues to identify SSRC front companies and procurement agents.[6] Also, on April 26, 2017, France released a report confirming that SSRC’s sarin manufacturing process was used by the Syrian regime in the attack on Khan Sheikhoun.[7] The report also asserts that since 2014 Syria has attempted to acquire dozens of tons of isopropanol, a key component in the synthesization of sarin.[8]

SSRC’s role in Syria’s non-conventional weapon programs has made the organization and the individuals and companies associated with it the target of U.S. sanctions for some time. In fact, SSRC was one of eight entities originally designated in June 2005, when the George W. Bush administration issued E.O. 13382 as a means of targeting proliferators of weapons of mass destruction and their delivery systems.[9] Both E.O. 13382 and E.O. 13582, which was used to designate the 271 individuals this week,[10] impose the same restrictions: an asset freeze and a prohibition on transactions with U.S. parties.[11]

Earlier this year, pursuant to E.O. 13382, Treasury designated several SSRC officials for their specific actions related to the production and use of chemical weapons, including Brigadier General Ghassan Abbas who was involved in planning the August 2013 sarin gas attack in the Damascus suburb of Ghouta. And entities associated with SSRC have been regularly targeted by Treasury in previous years, notably in 2012, when five Damascus-based entities were designated for acting on behalf of SSRC by procuring chemical weapon material and missile technology. In addition, the United States has sanctioned a number of SSRC’s procurement agents in third countries, including Lebanon-based companies in 2015,[12] and several Dubai-based entities in 2016.[13]

SSRC is vulnerable to this net of ever-expanding sanctions. It continues to rely on overseas suppliers for weapons-related equipment and technology.[14] And the restrictive measures also aim to disrupt SSRC’s access to overseas bank accounts and its ability to transfer funds. The hundreds of individual SSRC employees sanctioned this week may have difficulty traveling overseas and conducting foreign transactions, now that they have been frozen out of a large portion of the world’s financial system.

Treasury Secretary Steven Mnuchin said that this week’s broad action is intended to “pursue and shut down the financial networks of all individuals involved with the production of chemical weapons.”[15] To achieve this end, the United States should encourage its partners to do the same. The European Union has already imposed restrictive measures on hundreds of entities supporting the Syrian regime’s violent repression of its civilian population, including SSRC and its associates.[16] And SSRC and a handful of its affiliates are on a Japanese government warning list.[17] Other countries should do the same, because no specific action against this organization is likely at the United Nations. A draft U.N. resolution introduced last February by 42 countries, including the United States, called for 20 Syrian entities to be blacklisted, including SSRC. The resolution was vetoed by Russia and China.[18]


Footnotes:

[1] “Treasury Targets Syrian Regime Financial and Weapons Networks,” Press Release, U.S. Department of the Treasury, March 31, 2015, available at http://www.treasury.gov/press-center/press-releases/Pages/JL10013.aspx, accessed on April 25, 2017; United Nations Security Council Draft Resolution, S/2017/172, February 28, 2017, pp. 9-10, available at http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF96FF9%7D/s_2017_172.pdf, accessed on April 6, 2017; “Fact Sheet: Increasing Sanctions Against Syria,” Office of Public Affairs, U.S. Department of the Treasury, July 18, 2012, available at http://www.treasury.gov/press-center/press-releases/Documents/Fact%20Sheet.pdf, accessed on April 25, 2017.

[2] “Fact Sheet: Increasing Sanctions Against Syria,” Office of Public Affairs, U.S. Department of the Treasury, July 18, 2012, available at http://www.treasury.gov/press-center/press-releases/Documents/Fact%20Sheet.pdf, accessed on April 25, 2017; Robin Hughes, “SSRC: Spectre at the Table,” Jane’s Defense Weekly, January 22, 2014, available via Jane’s Information Group (www.janes.com), accessed on April 25, 2017.

[3] “Report of the Panel of Experts established pursuant to resolution 1874 (2009),” United Nations, S/2013/337, June 11, 2013, pp. 23-24, available at http://www.un.org/en/ga/search/view_doc.asp?symbol=S/2013/337, accessed on April 25, 2017.

[4] “Report of the Panel of Experts established pursuant to resolution 1874 (2009),” United Nations, S/2012/422, June 14, 2012, p. 24, available at http://www.un.org/en/ga/search/view_doc.asp?symbol=S/2012/422, accessed on April 25, 2017.

[5] “Fact Sheet: Increasing Sanctions Against Syria,” Office of Public Affairs, U.S. Department of the Treasury, July 18, 2012, available at http://www.treasury.gov/press-center/press-releases/Documents/Fact%20Sheet.pdf, accessed on April 25, 2017.

[6] “Progress in the Elimination of the Syrian Chemical Weapons Program,” Organization for the Prohibition of Chemical Weapons, EC-85/DG.5, April 24, 2017, available at https://www.opcw.org/fileadmin/OPCW/EC/85/en/ec85dg05_e_.pdf, accessed on April 27, 2017; “Treasury Targets Syrian Regime Financial and Weapons Networks,” Press Release, U.S. Department of the Treasury, March 31, 2015, available at https://www.treasury.gov/press-center/press-releases/Pages/JL10013.aspx, accessed on April 25, 2017; “Treasury Sanctions Networks Providing Support to the Government of Syria,” Press Release, U.S. Department of the Treasury, July 21, 2016, available at https://www.treasury.gov/press-center/press-releases/Pages/jl0526.aspx, accessed on April 25, 2017.

[7] “National Evaluation – Chemical Attack of 4 April 2017,” French Ministry of Foreign Affairs and International Development, p. 4, available at http://www.diplomatie.gouv.fr/IMG/pdf/170425_-_evaluation_nationale_-_anglais_-_final_cle0dbf47-1.pdf, accessed on April 27, 2017.

[8] “National Evaluation – Chemical Attack of 4 April 2017,” French Ministry of Foreign Affairs and International Development, p. 5, available at http://www.diplomatie.gouv.fr/IMG/pdf/170425_-_evaluation_nationale_-_anglais_-_final_cle0dbf47-1.pdf, accessed on April 27, 2017.

[9] “Specially Designated Nationals and Blocked Persons List,” Office of Foreign Assets Control, U.S. Department of the Treasury, April 24, 2017, p. 257, available at https://www.treasury.gov/ofac/downloads/sdnlist.pdf, accessed on April 25, 2017; “Nonproliferation: What You Need to Know About Treasury Restrictions,” U.S. Department of the Treasury, Office of Foreign Assets Control, available at http://www.treasury.gov/resource-center/sanctions/Programs/Documents/wmd.pdf, accessed on April 25, 2017; “Fact Sheet: Increasing Sanctions Against Syria,” Office of Public Affairs, U.S. Department of the Treasury, July 18, 2012, available at http://www.treasury.gov/press-center/press-releases/Documents/Fact%20Sheet.pdf, accessed on April 25, 2017; “Syria Designations; Non-proliferation Designations,” U.S. Department of the Treasury, Office of Foreign Assets Control, July 18, 2012, available at https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20120718.aspx, accessed on April 25, 2017; “Treasury Sanctions Companies for Aiding the Syrian Regime,” Press Release, U.S. Department of the Treasury, July 9, 2014, available at https://www.treasury.gov/press-center/press-releases/Pages/jl2558.aspx, accessed on April 25, 2017; “Syria Designations; Non-proliferation Designations,” U.S. Department of the Treasury, Office of Foreign Assets Control, July 9, 2014, available at https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20140709.aspx, accessed on April 25, 2017.

[10] “Syria Designations,” U.S. Department of the Treasury, Office of Foreign Assets Control, April 24, 2017, available at https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20170424.aspx, accessed on April 25, 2017; “Executive Order 13582-Blocking Property of the Government of Syria and Prohibiting Certain Transactions With Respect to Syria, the White House, Federal Register, Volume 76, Number 162, August 17, 2011, pp. 52209-52211, available at https://www.treasury.gov/resource-center/sanctions/Programs/Documents/syria_eo_08182011.pdf, accessed on April 25, 2017; “Specially Designated Nationals and Blocked Persons List,” Office of Foreign Assets Control, U.S. Department of the Treasury, April 24, 2017, p. 1036, available at https://www.treasury.gov/ofac/downloads/sdnlist.pdf, accessed on April 25, 2017.

[11] “Nonproliferation: What You Need to Know About Treasury Restrictions,” U.S. Department of the Treasury, Office of Foreign Assets Control, available at http://www.treasury.gov/resource-center/sanctions/Programs/Documents/wmd.pdf, accessed on April 25, 2017; “Executive Order 13582-Blocking Property of the Government of Syria and Prohibiting Certain Transactions With Respect to Syria, the White House, Federal Register, Volume 76, Number 162, August 17, 2011, pp. 52209-52211, available at https://www.treasury.gov/resource-center/sanctions/Programs/Documents/syria_eo_08182011.pdf, accessed on April 25, 2017.

[12] “Treasury Targets Syrian Regime Financial and Weapons Networks,” Press Release, U.S. Department of the Treasury, March 31, 2015, available at https://www.treasury.gov/press-center/press-releases/Pages/JL10013.aspx, accessed on April 25, 2017.

[13] “Treasury Sanctions Networks Providing Support to the Government of Syria,” Press Release, U.S. Department of the Treasury, July 21, 2016, available at https://www.treasury.gov/press-center/press-releases/Pages/jl0526.aspx, accessed on April 25, 2017.

[14] “Report of the Panel of Experts established pursuant to resolution 1874 (2009),” United Nations, S/2016/157, February 26, 2016, pp. 29-30, available at http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF96FF9%7D/s_2016_157.pdf, accessed on April 25, 2017; “Treasury Sanctions Networks Providing Support to the Government of Syria,” Press Release, U.S. Department of the Treasury, July 21, 2016, available at https://www.treasury.gov/press-center/press-releases/Pages/jl0526.aspx, accessed on April 25, 2017; “Treasury Targets Syrian Regime Financial and Weapons Networks,” Press Release, U.S. Department of the Treasury, March 31, 2015, available at https://www.treasury.gov/press-center/press-releases/Pages/JL10013.aspx, accessed on April 25, 2017.

[15] “Treasury Sanctions 271 Syrian Scientific and Research Center Staff in Response to Sarin Attack on Khan Sheikhoun,” Press Release, U.S. Department of the Treasury, April 24, 2017, available at https://www.treasury.gov/press-center/press-releases/Pages/sm0056.aspx, accessed on April 25, 2017.

[16] Council Regulation (EU) No 36/2012 of 18 January 2012 concerning restrictive measures in view of the situation in Syria and repealing Regulation (EU) No 442/2011 (Consolidated Version March 21, 2017), available at http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02012R0036-20170321&rid=3, accessed on April 27, 2017.

[17] “End User List,” Japan’s Ministry of Economy, Trade and Industry (METI), March 29, 2016, pp. 24-25, available at http://www.meti.go.jp/policy/anpo/law_document/tutatu/kaisei/150415_user-list-tokekomashi.pdf, accessed on April 27, 2017.

[18] United Nations Security Council Draft Resolution, S/2017/172, February 28, 2017, available at http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF96FF9%7D/s_2017_172.pdf, accessed on April 27, 2017; Journal of the United Nations, No. 217/41, March 1, 2017, available at http://www.un.org/Docs/journal/En/20170301e.pdf, accessed on April 27, 2017.

Lesson Learned or Business as Usual?

Record U.S. penalties imposed on ZTE may not be enough to deter the Chinese telecom giant and others from violating Iran sanctions

Over a period of six years, Zhongxing Telecommunications Equipment Corporation (ZTE), China’s largest publicly traded telecommunications manufacturer and the fourth largest in the world,engaged in a scheme to ship more than 20 million U.S.-origin items to Iran. ZTE used multiple avenues to evade U.S. sanctions and export control regulations, including establishing shell companies, falsifying customs documents, and then actively misleading investigators when details of the conspiracy came to light. Top executives were instrumental in orchestrating the scheme and the attempted cover up.

ZTE recently reached a plea agreement and settled with the U.S. Department of Justice (DOJ), the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) for a combined penalty of $1.19 billion. The agreement was approved by a federal judge in Dallas on March 22 and ZTE and its subsidiary were removed from Commerce’s Entity List on March 29.

Media reports and government press releases about the case have focused on the size of the monetary penalty. It is OFAC’s largest settlement to date with a non-financial entity and the largest criminal fine ever for an International Emergency Economic Powers Act (IEEPA) violation. But does it go far enough? The fine and probationary measures may not be sufficient to deter ZTE and companies like it from pursuing similar illegal actions in the future.

ZTE’s orchestrated, company-wide, multi-year effort to circumvent U.S. export controls and sanctions landed it and some of its affiliates on the Commerce Department’s Entity List. However, ZTE and its China-based subsidiary ZTE Kangxun were almost immediately granted a temporary general license, thus exempting them from any U.S. trade restrictions. And at least two companies used by ZTE to supply U.S.-origin goods to Iran and North Korea were left off the Entity List entirely. In addition, the corporate compliance and oversight changes mandated in ZTE’s plea and settlement agreements may not be far-reaching enough to guarantee a change in behavior. Only a handful of officials directly implicated in the conspiracy were removed, while many other top officials likely aware of the illegal activity remain in place. Finally, an exemption in the plea agreement stipulates that ZTE, whose largest shareholder is a Chinese state-owned enterprise, may not be required to turn over documents that the Chinese government deems “state secrets.” This may allow the company to conceal evidence of U.S. export control and sanctions violations in the future.

To read the full report, click here:  Lesson Learned or Business as Usual?

United Arab Emirates Transshipment Chronology: 1971 – 2017

The United Arab Emirates has long served as a hub for international trade. It has the Persian Gulf’s largest seaport and airport and is the largest export market for the United States in the Middle East.  However, ongoing efforts to increase trade through the establishment and expansion of free trade zones bring with them vulnerability: the UAE has been exploited as a transshipment point for sensitive trade to countries of concern for proliferation, like Iran, Syria, and Pakistan. The UAE has sought to combat illicit trade, particularly since 2007, when it enacted a strategic trade control law that covers exports and re-exports of strategic goods.  Alongside this and other regulatory reforms, the UAE has endorsed the Proliferation Security Initiative (PSI) and supports the U.S. Customs and Border Protection’s Container Security Initiative (CSI).  It also has increased its interdiction of suspicious cargo since 2007.

The following chronology charts re-transfers or transshipments of sensitive items through the UAE, along with its efforts to curb such illicit trade.

1971: The UAE is formed by Abu Dhabi, Ajman, Dubai, Fujairah, Sharjah, and Umm al Quwain. Ras Al Khaimah joins the UAE in 1972.

1972: The UAE signs the Biological Weapons Convention.

1972: Port Zayed opens in Abu Dhabi. Port Rashid opens in Dubai.

1976: The UAE’s first container terminal opens in Port Khalid, Sharjah.

Jebel Ali Port in Dubai (Courtesy: The Maritime Standard)

1977: Saqr Port opens in Ras Al Khaimah.

1979: Jebel Ali Port, allegedly the largest man-made harbor in the world at the time, opens in Dubai.

1982: Fujairah Port opens.

1982: Alfred Hempel of West Germany sends seventy tons of heavy water from China to Dubai, from where sixty tons are forwarded to India and ten tons to Argentina. At this time India is pursuing and Argentina is interested in atomic weapons.

1983: Hempel delivers to India, via the UAE, fifteen tons of heavy water from Norway and 6.7 tons from the Soviet Union.

1983: Hank Slebos, of the Netherlands, reportedly tries to export a high-speed oscilloscope without a license to the UAE’s Assaf Electrical Establishment. The ultimate destination is believed to be Pakistan, and in 1985 Slebos is reportedly jailed for one year for exporting strategically sensitive material.

1985: Jebel Ali Free Zone is established in Dubai. Companies are exempt from all domestic capital and ownership requirements, import and export duties, and personal and corporate taxes.

1985: According to documents from Germany’s customs investigation unit, employees of Leybold-Heraeus manufacture uranium enrichment components that are sent to Dubai via Switzerland and France. French investigators reportedly allege the final recipient is Pakistan.

July – August 1985: Alfred Hempel sends to India, through the UAE, 6.8 tons of Soviet heavy water that could have been used to start the uninspected Dhruva reactor.

1987: Fujairah International Airport opens.

1987: Fujairah Free Zone is established adjacent to Fujairah Port and near to Fujairah International Airport. Companies in the zone are exempt from all domestic ownership requirements and import duties on goods for re-export.

1987: Iranian officials reportedly meet associates of Abdul Qadeer (A.Q.) Khan, a Pakistani citizen, in Dubai. Iran is reportedly offered a phased supply of centrifuge drawings, as many as 2,000 centrifuges and auxiliary items, including casting equipment for manufacturing a bomb core.

1988: Ajman Free Zone is established. Companies in the zone are exempt from all domestic capital and ownership requirements, income and corporate taxes, and import and export duties.

1988: Ahmed Bin Rashed Free Zone is established in Umm Al Quwain. Companies in the zone are exempt from corporate taxes as well as import and export duties.

March 1989: A firm owned by the Indian government reportedly ships sixty tons of thionyl chloride, which can be used to manufacture mustard gas and nerve agents, to Iran, via Dubai.

May – June 1989: One hundred metric tons of centrifuge-grade maraging steel are reportedly delivered from Belgium through Dubai to Iraq.

June 1989: Rheineisen Chemical Products arranges for 257 tons of thionyl chloride, a mustard gas and nerve agent precursor, to be shipped from India to Dubai’s Shatif Trading Company for transshipment to Iran. Rheineisen, a West German firm owned by an Iranian family, cancels the contract amid concerns about its legitimacy, and the chemical is returned from Dubai to India. Seyed Kharim Ali Sobhani, an Iranian diplomat who had brokered three shipments of thiodiglycol (a precursor of mustard gas) from the U.S to Iran between 1987 and 1988, is reportedly implicated in the deal.

1990: A Greek intermediary claiming to represent A.Q. Khan offers Iraq an atomic bomb design, promising that any required materials could be procured from Western countries and shipped via Dubai.

1991 – 1994: According to a U.S. indictment, seven persons conspire to export, without the required license, $500,000 of sensitive U.S. electronics to Iran. Controlled goods, including encryption devices, are allegedly shipped via Hanofeel General Trading Est. of Dubai to Iran’s Tak Neda Co. Ltd. Elham Abrishami, of Afshein, Inc. in the U.S., pleads guilty in 1997.

1991: The management of Port Rashid and Jebel Ali Port is combined under Dubai Ports Authority. Dubai Ports Authority is the sixteenth busiest container harbor in the world, with a capacity of over one million TEU (Twenty-foot Equivalent Units).

1993: The UAE signs the Chemical Weapons Convention.

1993: A third berth is commissioned for Sharjah’s Khorfakkan Container Terminal.

1994 – 1995: Bukary Syed Abu (B.S.A.) Tahir, a Sri Lankan based in Dubai, allegedly organizes the transshipment of two containers of centrifuge components through Dubai to Iran, on behalf of A.Q. Khan, for $3 million.

1995: Sharjah Airport International Free Zone (SAIF-Zone) is established. Companies in the zone are exempt from all domestic ownership and capital requirements, import and export duties, and personal and corporate taxes.

September 1995: The UAE signs the Nuclear Nonproliferation Treaty.

November 1995: Hamriyah Free Zone is established in Sharjah. Companies in the zone are exempt from all domestic ownership and capital requirements, import and export duties, and personal and corporate taxes.

1996: Ajman Free Zone is granted autonomous status by the ruler of Ajman.

1996: Dubai Airport Free Zone is established near the Dubai Cargo Village. Companies in the zone are exempt from all domestic capital and ownership requirements, import and export duties, and personal and corporate taxes.

1996: The German government warns its exporters that Iranian companies active in procurement for weapons programs are present in Dubai. Among the entities named are Iran’s State Purchasing Organization and Bonyad Mostazafan and Janbazan Foundation.

June 1996: Dubai’s Guide Oil Equipment Company is identified in a U.S. court as a corporation that ships impregnated alumina, which can be used in the manufacture of nerve gas, through Dubai or the United Kingdom to Iran. In 1998, Abdol Hamid Rashidian and Henry Joseph Trojack are convicted for conspiring to ship impregnated alumina to Iran.

1997 – 1998: Pars Company Inc. of the U.S. illegally exports two STX gas monitors via the UAE to Iran and is fined $10,000. The monitors can be used in chemical and biological weapons production. The U.S. Department of Commerce subsequently imposes a nine year denial of export privileges in 2002. The U.S. firm Industrial Scientific Corporation is also implicated and pays a $30,000 fine.

1998: According to the U.S. Department of Commerce, Jabal Damavand General Trading Company of Dubai transfers U.S.-origin ferrography laboratory equipment to Iran without authorization. In 2002, the U.S. bans Jabal Damavand for ten years from engaging in any activity subject to the Export Administration Regulations.

March 1998: According to later reporting by the U.S. government’s Iraq Survey Group (I.S.G.), the Iraqi Intelligence Service is using bribes to circumvent customs inspections in Dubai, which is a transshipment point for military equipment being sought from Romania.

May 1998: A new Sun Ultra Enterprise 1 Work Station is located in Iraq’s National Computer Center, which was involved in Iraq’s nuclear weapons program. Iraq claims to have imported workstations from the UAE and Jordan.

September 1998 – February 2001: NEC Engineers of India allegedly sends ten shipments of materials used in the manufacture of rocket propellant and missiles to Dubai and Jordan without the required export license. Indian court documents state that the consignments, shipped for $791,343, “appear to have been diverted to Iraq for assisting their weapon building programme,” violating the U.N. embargo. The Dubai companies Target General Land Transport and Indjo Trading are reportedly involved.

November 1998 – February 2000: Mohammad Farahbakhsh, co-owner and managing director of Dubai’s Diamond Technology LLC, allegedly tries to export U.S. computer items to Iran via Diamond Technology. The alleged purchaser is Shahid Hemmat Industrial Group (SHIG), which is a branch of the Iranian Ministry of Defence and subject to U.S. sanctions for its involvement in cruise and ballistic missile development.

1998 – 2000: Mazyar Gavidel and his company Homa International Trading Corp. violate the U.S. trade embargo against Iran by illegally transferring approximately $2 million of laundered money through Dubai. Gavidel and Homa International are convicted by the U.S. in August 2002.

January 1999: Abu Bakar Siddiqui, a British exporter of Pakistani origin and an alleged procurement agent for A.Q. Khan, allegedly attempts to ship special aluminum sheets to Dubai.

May 1999: British customs authorities reportedly seize up to 20 tons of components, including high-grade aluminum, believed to be ultimately destined for Pakistan. The cargo arrived from the U.S. and was allegedly about to be shipped to Dubai. The exporter is allegedly Siddiqui, who is convicted in the United Kingdom in 2001 for illegally exporting strategic materials to Pakistan, including high-strength aluminum bars.

2000: Ras Al Khaimah Free Trade Zone is established near Saqr Port. Companies in the zone are exempt from all domestic ownership and capital requirements, as well as income and corporate taxes.

2001: UAE companies act as intermediaries in the partial delivery of fiber-optic and military communications contracts from South Korea to Iraq, according to the I.S.G.

2001: Dubai’s Ports, Customs & Free Zone Corporation is established to take over customs operations from the Dubai Ports Authority and Jebel Ali Free Zone Authority.

2001: Trade with Iran exchanged through Dubai’s ports was 12 billion dirhams this year, an increase from 4.3 billion in 1997.

May 2001 – December 2005: According to the U.S. Department of Commerce, Mine Safety Appliances Company’s Abu Dhabi branch allegedly illegally re-exported U.S. safety and protection-related items from the UAE to Iran and Syria 107 times.

June 2001: Bef Corp. allegedly exports photo finishing equipment to SK of Dubai, which transships the equipment to Iran, in violation of U.S. sanctions.

September 2001: The UAE’s Advance Technical Systems (ATS) purchases $16,000 of military radar components from the U.S. and transships them to Pakistan after declaring that they were for the Bangladeshi Air Force. Tariq Ahmed, reported owner of ATS, and Yasmin Ahmed, ATS sales representative, plead guilty in June 2003 to conspiring to illegally export parts for howitzers, radars, and armored personnel carriers.

September 2001 – March 2003: According to the U.S. Department of Commerce, UAE-based Super Net Computers, L.L.C. orders super servers, motherboards, and computer chassis from the U.S. and forwards them to Iran.

October 2001: A UAE-based firm facilitates trade in ballistic missile-related goods from China to Iraq, according to the I.S.G.

December 2001 – March 2002: According to the U.S. Department of Commerce, Dubai’s Teepad Electronic General Trading exports controlled telecommunications devices from the U.S. to Iran.

February 2002 – November 2008: Mohammad Reza Vaghari and Mir Hossein Ghaemi, Iranians residing in the U.S., export laboratory equipment and fuel cell systems to Iran, via the UAE.

April 2002: According to the U.S. Department of Commerce, Tariq Ahmed attempts to illegally export components for an online chemical monitoring system from the U.S. to the Karachi Nuclear Power Plant (KANUPP) in Pakistan, via the UAE.

May 2002: The German government warns its exporters that since 1998 Iraq has been increasingly engaging in procurement activities through Dubai. Germany believes that North Korea has also increased its operations in Dubai.

August 2002: The U.S. firm Mercator, Inc. agrees to a $30,000 settlement with the U.S. Department of Commerce, which had alleged that Mercator exported chemicals to Dubai with the knowledge that they would be re-exported to Iran without prior authorization.

November 2002 – August 2004: According to the U.S. Department of Commerce, U.S.-based State of the Art, Inc. allegedly filed seven Shipper’s Export Declarations (SED) falsely reporting the ultimate destination of fixed resistors as the UAE, when India was the ultimate destination.

December 2002: The U.S. Navy accuses Dubai’s Naif Marine Services of smuggling to Iraq polymers that could be used to manufacture explosives.

2003: The UAE joins the IAEA Convention on the Physical Protection of Nuclear Material.

2003 – 2012: Harold Rinko and his company, Global Parts Supply, conspire with British national Ahmad Feras Diri and Syrian citizen Moawea Deri to export laboratory equipment, including items used to detect chemical warfare agents, from the United States to Syria, via Jordan, the United Kingdom, and the UAE.

2003: U.S.-based SparesGlobal, Inc. illegally exports to the UAE restricted graphite products that can be used in nuclear reactors and nose cones of ballistic missiles; the products are then forwarded to Pakistan.

January 2003: Spare parts for Mirage F-1 aircraft and Gazelle attack helicopters are transferred to Iraq. U.S. intelligence reportedly believes that parts were purchased from France by Dubai’s Al Tamoor Trading Co., and then smuggled to Iraq through a third country, reportedly Turkey.

May 2003 – February 2004: Mohammad Farahbakhsh allegedly exports a U.S. satellite communications system to Iran via UAE-based Diamond Technology LLC without the required license.

May 2003 – January 2004: According to the U.S. Department of Justice, John Nakkashian, then vice president at Air Shunt Instruments Inc., allegedly exports military components, including components for the J85 engine used on the F-5 fighter jet, from the U.S. to Dubai without the required licenses.

October 2003: Sixty-six triggered spark gaps, which can be used to detonate nuclear weapons, are shipped without the required license from the United States to Top-Cape Technology in South Africa. They are subsequently transshipped via Dubai to AJMC Lithographic Aid Society in Pakistan. In 2004, Asher Karni, an Israeli living in South Africa, pleads guilty to conspiring to export controlled commodities to Pakistan without validated export licenses. In 2005, the U.S. indicts Humayun Khan of the Pakistani company Pakland PME for violating export restrictions and being the ultimate purchaser.

October 2003: Five containers of centrifuge components, sent by B.S.A. Tahir and shipped through Dubai, are seized en route to Libya. The items are part of four shipments made by Malaysia’s Scomi Precision Engineering (SCOPE) between 2002 and 2003 to Dubai’s Aryash Trading Company.

October 2003: According to B.S.A. Tahir, the BBC China, the ship carrying the seized centrifuge components, was also transporting an aluminum casting and dynamo for Libya’s centrifuge workshop. The consignment was allegedly sent via Dubai by TUT Shipping on behalf of Gunas Jireh of Turkey.

October 2003: Two weeks after the seizure of the centrifuge components, B.S.A. Tahir arranges the transshipment to Libya, via Dubai, of an electrical cabinet and power supplier-voltage regulator on behalf of Selim Alguadis, an associate of A.Q. Khan.

December 2003: Hamid Fathaloloomy, principal of Dubai’s Akeed Trading Company, allegedly attempts to export U.S. pressure sensors to Iran.

2003 – 2006: According to the U.S. Department of Commerce, Engineering Physics Software Inc. is allegedly involved in sixteen exports of controlled engineering software programs to Iran via the UAE, without the required authorizations.

2004: Over 400 companies are operating in the Ras Al Khaimah Free Trade Zone, 38% of which are Indian. The Dubai Ports Authority’s capacity passes six million TEU.

January 2004 – November 2006: According to a U.S. indictment, Ali Akbar Yahya and Farrokh Nia Yaghmaei, managers of Mayrow General Trading, allegedly use the Mayrow, Majidco and Micatic companies to export electronic components that could be used in improvised explosive devices (IEDs) from the U.S. to the UAE, and then forward the components to Iran.

January 2004 – May 2008: According to a U.S. indictment, Baktash Fattahi and ten other defendants allegedly export military aircraft parts to Iran, via the UAE.

February 2004: According to the U.S. Department of Commerce, Proclad International Pipelines Ltd. allegedly attempts to export nickel alloy pipes from the U.S. to Iran via the UAE without the required authorization.

April 2004: Elmstone Service and Trading FZE is sanctioned for two years by the United States for transferring to Iran equipment and/or technology of proliferation significance since 1999.

Spring 2004 – Spring 2007: According to a U.S. indictment, Yousef Boushvash allegedly exports U.S. military aviation parts to Dubai without the required licenses.

June 2004: According to the U.S. Department of Commerce, Matthew Ayadpoor, based in the U.S., allegedly attempts to illegally export piston-type differential pressure gauges to Iran via the UAE.

August 2004: The U.S. indicts Khalid Mahmood, of Dubai, for breaking the U.S. embargo to Iran. Mahmood allegedly attempted to arrange the sale of forklift radiators from the U.S. to Iran by concealing the final destination in the sale.

September 2004: The I.S.G. lists twenty UAE firms that are suspected of having acted as intermediaries or front companies for Saddam Hussein’s Iraq, and says that the UAE was a transit location for prohibited goods.

September 2004: According to U.S. Immigration and Customs Enforcement, Mohammad Fazeli of Los Angeles allegedly orders 103 pressure sensors and attempts to export them from the U.S. to the UAE without the required authorization. The sensors are intended to be forwarded to Iran.

September 2004: German national Helmut R. is arrested for allegedly brokering a contract for the procurement of guided manipulators used to handle spent fuel rods between Societe d’Innovations Techniques, a French company, and Iranian Industrial Development and Renovation Organization. The cargo was intended to be shipped through the UAE.

December 2004: The UAE agrees to join the U.S. Container Security Initiative (C.S.I.). U.S. customs officials will be stationed in Dubai to help target and screen suspect cargo bound for the United States.

2005: More than 300 Iranian companies are known to have operated in Dubai’s Jebel Ali Free Zone.

2005: Dubai is the sixth largest port in the world for container traffic.

2005: The UAE joins the UN International Convention for the Suppression of Acts of Nuclear Terrorism.

2005 – 2012: According to the FBI, Borna Faizy and Touraj Ghavidel conspire to export U.S.-origin computers and computer equipment to Iran, falsely listing the UAE as the destination and using a UAE-based freight forwarding company to ship the equipment to Iran.

January 2005: According to the U.S. Department of Commerce, U.S.-based Select Engineering, Inc. allegedly sold and/or caused to be transported medical equipment from the U.S. to Iran, via the UAE, without the required authorization.

February 2005: The Jebel Ali Free Zone Authority launches an expansion project to develop its manufacturing in industry specific sectors, including medical products, food processing and the chemicals sector.

March 2005: Dubai’s participation in the C.S.I. becomes operational.

April 2005 – March 2007: According to the U.S. Department of Justice, George Frank Myles, Jr. illicitly supplies military aviation parts to an Iranian national, who picks up some of the parts in Dubai.

May 2005: Dubai signs a Memorandum of Understanding with the U.S. to join the Megaports Initiative, which is intended to detect and seize shipments of radioactive material.

July 2005: The German government warns its exporters that trading companies in Dubai are being used in proliferation activities, especially with Iran.

Fall 2005: According to the U.S. Department of Justice, U.S. resident Mojtada Maleki-Gomi attempted to evade the U.S. embargo against Iran by shipping textile machinery from the U.S. to Iran, via Dubai.

October 2005 – October 2007: Robert Kraaipoel and his son, Robert Neils Kraaipoel, both Dutch citizens, use their company, Aviation Services International, to ship U.S.-origin aviation parts to Iran via third countries, including the Netherlands, Cyprus, and the UAE.

October 2005 – March 2010: Pakistani national Nadeem Akhtar and his co-conspirators procure and use his company Computer Communication USA to illegally export nuclear-related items to Pakistan via the UAE. Among the end-users are the Pakistan Atomic Energy Commission, Chashma Nuclear Power Plant, and Space and Upper Atmosphere Research Commission.

2006 – The UAE joins the Proliferation Security Initiative (PSI).

August 2006 – February 2007: According to a U.S. indictment, Ireland-based Mac Aviation allegedly arranges the export of U.S.-origin aircraft parts to Dubai with invoices indicating that their final destination is Iran.

October 2006 – June 2007: Naturalized U.S. citizens Hassan Saied Keshari and Traian Bujduveanu allegedly procure U.S.-made military aircraft parts and cause them to be exported to Dubai and then forwarded to Iran.

October 2006 – June 2008: Mark Mason Alexander, also known as Musa Mahmood Ahmed, conspires with two Iranian businessmen to ship water-jet cutting systems to customers in Iran, transshipping them via his UAE-based company, Hydrajet Mena, to conceal the true end-user.

May 2007: Reza Tabib is sentenced by the U.S. government for illegally exporting U.S. military aircraft parts to Iran via associates in Germany and the UAE.

August 2007: The UAE enacts a law for the control of exports and re-exports of strategic goods, including military equipment, chemical and biological materials, and dual-use items. The law also establishes a National Commission for oversight.

October 2007 – June 2011: According to the FBI, Susan Yip, a citizen of Taiwan, Mehrdad Foomanie, of Iran, and Merdad Ansari, of the UAE, operate a scheme to procure over 105,000 parts and transship them to Iran through Ansari’s Dubai-based company.

December 2007 – November 2008: Jirair Avanessian conducts at least seven shipments of vacuum pump equipment, which can be used to enrich uranium, to Iran via a free trade zone in the UAE.

2008 – 2012: Iranian company Business Machinery World Wide exports U.S.-origin computer equipment to Iran, transshipping the items through its Dubai-based subsidiaries, Servex DWC LLC and Ariana General Trading.

March – April 2008: Murat Taskiran, a Turkish citizen, and Hamid Reza Hashemi, a dual U.S.-Iranian citizen, illegally export carbon fiber from the United States to Iran, via Europe and Dubai.

March 2008: UAE authorities reportedly disrupt the import and re-export of 240 kg of zirconium.

May 2008: Afshin Rezaei is sentenced by the U.S. government for the unlicensed export of computers from the U.S. to Iran, via the UAE.

August 2008: UAE authorities impound a Malaysian shipment of specialized aluminum tubes that can be used for aeronautical and military purposes. UAE authorities also seize a Chinese shipment of titanium sheets bound for Iran.

September 2008: Based on U.S. intelligence, UAE authorities impound a Chinese shipment of specialized aluminum sheets that can be used for ballistic missiles.

November 2008 – January 2010: Michael Todd, Syed Amir Ahmed Najfi, and others export military aircraft parts from the United States to Iran. Dubai-based Aletra General Trading is involved in the conspiracy.

2009 – September 2012: Randy Dale Barber, John Alexander Talley, and Talley’s company Talleyho Peripherals export sophisticated computer equipment from the United States to Iran via the UAE. According to the U.S. Department of Justice, Iranian nationals Mahmood Akbari and Reza Hajigholamali and three UAE-based front companies, Patco Group Ltd, Managed Systems and Services (FZC), and TGO General Trading LLC are also part of the conspiracy.

2009 – 2015: Ali Reza Parsa, a Canadian-Iranian national, procures high-tech dual-use equipment, some used in the production of missiles, from U.S. companies on behalf of Iranian clients, and has them shipped to Iran via Canada and the UAE.

January 2009: Hassan Keshari pleads guilty to charges of conspiracy to export military and commercial aircraft components to Iran, via Dubai.

February 2009: The UAE Committee on Commodities Subject to Import and Export Control is reportedly created to strengthen and develop implementation of the UAE’s Federal Export Control Law. The Committee holds its first meeting in May.

February 2009 – August 2009: Belgian national Jacques Monsieur conspires with Iranian national Dara Fatouhi to export engines for F-5 fighter jets and C-130 transport aircraft to Iran, via Colombia and the UAE.

March 2009: The International Atomic Energy Agency (IAEA) reportedly approves the UAE’s ratification of the Additional Protocol, allowing additional nuclear inspection measures in the country.

April 2009: Canadian authorities charge Toronto resident Mahmoud Yadegari with attempting to ship ten U.S. pressure transducers, which can be used for uranium enrichment, from the U.S. to Iran, via Dubai.

April 2009: Baktash Fattahi, an Iranian national and legal U.S. resident is arrested in California. He and 10 other defendants are indicted in Florida for exporting U.S.-origin parts for fighter jets and military helicopters to Iran, via Dubai. Fattahi later pleads guilty and is sentenced to 35 months in prison.

June 2009: UAE-based Elia General Trading attempts to provide German-made specialty alloys to Iran’s Kian Metals Company.

July 2009: UAE authorities seize a North Korean military shipment bound for Iran aboard the ANL Australia. The shipper is the Pyongyang office of OTIM SPA, an Italian company.

August – September 2009: Andre Telemi and Davoud Baniameri attempt to export U.S.-origin missile components to Iran, via the UAE.

September 2009: Netherlands based Aviation Services International (ASI), its owner Robert Kraaipoel, and his son Robert Neils Kraaipoel, plead guilty to ordering aircraft components on behalf of Iranian companies and transshipping them via the Netherlands, Cyprus, and the UAE.

November 2009: Belgian national Jacques Monsieur pleads guilty to conspiring to export F-5 fighter jet engines from the United States to Iran via the UAE and Colombia.

November 2009 – 2013: Ali Saboonchi, a U.S. citizen, and Arash Rashti Mohammad, an Iranian national, conspire with others to export U.S.-origin industrial goods and services to Iran through entities in China and the UAE.

February 2010 – September 2011: Omidreza Khademi, an Iranian national and a resident of the UAE, conspires on at least four occasions to ship computer-related items to Iran, using Omid General Trading, his Dubai-based company.

July 2010: Jirair Avanessian pleads guilty to conspiring to ship vacuum pumps and related equipment, including items with applications in uranium enrichment, to Iran through a free trade zone in the UAE, falsely listing the UAE as the final destination of the goods.

December 2010 – February 2011: UAE freight forwarding company Aramex Emirates facilitates the re-export of U.S.-origin network devices and software to Syria.

Early 2011: Iranian government-controlled Execution of Imam Khomeini’s Order transfers money to one of its German affiliates through Dubai-based Golden Resources Trading Company L.L.C.

January 2011: Mehrdad Yasrebi and his Oregon-based charity, Child Foundation, plead guilty to transferring money disguised as embargo-exempt food commodity transaction funds to Iran, via Dubai.

February 2011: Mohammad Reza Vaghari is convicted by the U.S. government of delivering laboratory equipment, including centrifuges, to Iran, via the UAE, using his Pennsylvania-based Saamen Company. His co-conspirator, Mir Hossein Ghaemi, pleads guilty in November 2012.

May 2011: Davoud Baniameri pleads guilty to conspiring to export radio test sets and TOW missile components to Iran, via Dubai.

June 2011: UAE-based Aletra General Trading, doing business as Erman & Sultan Trading Company, is indicted by the U.S. government for involvement in shipping restricted components for fighter aircraft and attack helicopters to Iran. The conspiracy allegedly involved seven individuals and five companies based in the U.S., France, and the UAE.

September 2011: Pakistani national Nadeem Akhtar pleads guilty to charges relating to illegally exporting nuclear-related items to Pakistan through the UAE.

July 2012: Susan Yip of Taiwan pleads guilty to charges of conspiracy related to transshipping dual-use items from the United States to Iran, via Dubai.

July 2012: Andro Telemi, a naturalized U.S. citizen from Iran, pleads guilty in Illinois to attempting to export TOW and TOW 2 missile components to Iran, via Dubai. Co-conspirators include Davoud Baniameri and Syed Majid Mousavi.

December 2012 – June 2013: Arash Ghahreman, a naturalized U.S. citizen from Iran, attempts to acquire and export fiber optic gyrocompasses, electron tubes, and other sensitive technologies from the United States to Iran, using a front company and banks in the UAE for transshipment and money laundering.

January 2013: The Spanish National Police arrest two individuals suspected of attempting to ship valves suitable in nuclear programs, including Inconel 625 valves, to Iran, via the UAE, using the company Fluval Spain S.L.

May 2013: The U.S. Department of the Treasury designates UAE-based Al Hilal Exchange and Al Fida International General Trading for providing services to Iran’s Bank Mellat. Additionally, the Central Bank of the UAE revokes Al Hilal’s license for anti-money laundering violations.

May 2013: The U.S. Department of the Treasury designates DFS Worldwide, which has offices in multiple countries, including the UAE, for shipping goods from Dubai to Tehran on behalf of the Islamic Revolutionary Guard Corps Qods Force (IRGC-QF).

May 2013: Seyed Amin Ghorashi Sarvestani, an Iranian national, pleads guilty in New York to charges of using his UAE-based companies to transship satellite technology from the United States to Iran.

May 2013: Omidreza Khademi, an Iranian national living in the UAE, pleads guilty in the District of Columbia to the unlicensed export of laptops and an underwater acoustic transducer from the United States to Iran, via his UAE-based company Omid General Trading Company LLC.

July 2013: Hamid Reza Hashemi, an Iranian national, pleads guilty in New York to conspiring to export carbon fiber from the United States to Iran, via Europe and the UAE.

August 2013: Iranian company Business Machinery World Wide and its two Dubai-based subsidiaries, Servex DWC LLC, and Ariana General Trading, plead guilty to charges related to exporting more than $30 million in computer components to Iran, via Dubai.

September 2013: John Alexander Talley and his company Tallyho Peripherals plead guilty to conspiring to export sophisticated computer equipment from the United States to Iran, via the UAE.

September 2013: Iranian nationals Mahmood Akbari and Reza Hajigholamali, as well as UAE companies Patco Group Ltd, Managed Systems and Services FZC, and TGO General Trading LLC, are indicted by the U.S. Department of Justice in connection with a conspiracy to export IT equipment and services to Iran via the UAE.

September 2013: Mark Mason Alexander, is found guilty on charges related to selling and shipping water-jet cutting systems to clients in Iran and the Middle East, using his UAE-based company, Hydra Mena, to transship the items.

February 2014: Randy Dale Barber pleads guilty to conspiracy charges related to the export of computers to Iran, via the UAE.

August 2014: Ali Saboonchi is convicted by a U.S. federal jury for his involvement in exporting industrial goods to Iran, using companies in China and the UAE.

September 2014: Borna Faizy and Touraj Ghavidel plead guilty to charges related to illegally shipping $12 million worth of computer equipment to Iran, using freight-forwarding companies in Dubai.

September 2014: Harold Rinko, owner of Global Parts Supply, pleads guilty in Pennsylvania to transshipping laboratory equipment, including items for the detection of chemical warfare agents, to Syria, via Jordan, the U.K., and the UAE.

December 2014: The U.S. Department of the Treasury announces that the Iranian government has obtained hundreds of millions of dollars in cash that was reportedly carried on flights from Dubai or Turkey after passing through front companies in Iraq or the UAE.

2015: Hossein Pournaghshband and his UAE-based company, Mabrooka Trading, procure material and equipment, including items related to the production of carbon fiber, on behalf of Iran’s Navid Composite Material Company.

April 2015: Arash Ghareman is convicted by a U.S. grand jury for his role in an Iranian procurement network that used a front company and banks in Dubai to transfer gyrocompasses for use in marine navigation devices from the United States to Iran, via the UAE.

January 2016: Ali Reza Parsa, a Canadian-Iranian dual citizen, pleads guilty in New York to procuring and exporting sensitive electronic components from the United States to Iran, via Canada and the UAE.

March 2016: A network of individuals and companies overseen by Frank Genin is added to the U.S. Department of Commerce’s Entity List for supplying U.S.-origin items to an entity associated with the Iranian defense industry. Many of the companies and individuals are located in the UAE.

May 2016: Ahmad Feras Diri pleads guilty to charges related to the illegal export of laboratory equipment, including items used to detect chemical warfare agents, to Syria, via Jordan, the U.K., and the UAE.

February 2017: UAE-based Royal Pearl General Trading is identified by the U.S. Treasury Department as a front company being used to procure items for Shahid Bagheri Industrial Group (SBIG) and Aerospace Industries Organization (AIO) in support of Iran’s ballistic missile program. Company CEO Kambiz Rostamiam is also identified for his role in the procurement efforts.

Pyongyang’s Growing Nuclear Arsenal

Introduction

North Korea conducted its fifth nuclear weapons test in September 2016, which was its strongest to date.
At the same time, operations continue at the Yongbyon Nuclear Research Center, North Korea’s primary fissile material production facility. Pyongyang is producing both plutonium and highly enriched uranium (HEU) at Yongbyon, and is expanding operations there. Pyongyang is also enhancing its ballistic missile capability, and is in the final stages of developing an intercontinental ballistic missile that may be capable of reaching the United States mainland. These developments underscore North Korea’s determination to deploy a robust nuclear arsenal, with the capability of striking both regional and global targets. They also reflect the ineffectiveness of international sanctions to date in halting these efforts.

Nuclear Tests

North Korea conducted two nuclear tests in 2016. These were its fourth and fifth tests overall. Pyongyang claimed that the first test of 2016, conducted in January in Punggye-ri, was of a thermonuclear (hydrogen) bomb. The U.S. Director of National Intelligence (DNI) reported to Congress shortly after that test that the low-yield (6-10 kilotons) “is not consistent with a successful test” of a hydrogen bomb. However, another U.S. official familiar with the evidence told CNN that the device likely contained components associated with a hydrogen bomb. North Korea is also believed to have access to lithium-6 (Li-6), which is used to produce tritium in boosted and single-stage thermonuclear weapons.

The second 2016 test was conducted in September, again at the Punggye-ri site. The yield was Pyongyang’s most powerful to date, with estimates ranging from 10-20 kilotons. Following the test, North Korea claimed that it had “standardized” its nuclear warheads, and is able to mount them onto ballistic missiles. Earlier nuclear tests were conducted in February 2013, May 2009, and October 2006. North Korea’s first two tests are believed to have been of plutonium-based devices. It is not known whether the later tests were of devices fueled with HEU or plutonium.

Stockpile and Capabilities

Assessments of the current size of Pyongyang’s arsenal of nuclear warheads vary, due in large part to differences regarding the assumed amount of fissile material used per weapon. In any case, North Korea likely has had a stockpile of nuclear warheads for some time. In 2004, U.S. intelligence agencies reportedly assessed that it had anywhere from “possibly two to at least eight” nuclear warheads.

Stockholm International Peace Research Institute (SIPRI) estimates that North Korea has approximately ten nuclear warheads. SIPRI further estimates that North Korea uses five kilograms (kg) of plutonium per warhead. These estimates were published in June 2016. Also in June 2016, the Institute for Science and International Security (ISIS) estimated that Pyongyang had 12-20 warheads, assuming two to four kg of plutonium per warhead and 15-25 kg of weapons grade HEU per warhead. The Nonproliferation Policy Education Center (NPEC) assessed in early 2016 that the warheads could number anywhere from four to over 20, assuming eight kg of plutonium per warhead and 25 kg of HEU per warhead. A Chinese nuclear expert associated with the China Institute of International Studies reportedly indicated in 2015 that North Korea may have as many as 20 warheads, and that it could double its arsenal within a year’s time.

Estimates of North Korea’s stockpile of fissile material vary as well. The most recent estimate comes from the South Korean Ministry of Defense, which assesses that North Korea had 50 kg of plutonium as of the end of 2016, enough for 10 nuclear weapons. In two reports published in 2016, Dr. Siegfried S. Hecker, former director of Los Alamos National Laboratory, estimated North Korea to have 32 to 54 kg of plutonium and 300-400 kg of HEU. He also suggested that North Korea could be producing up to 150 kg of HEU annually if it is operating covert enrichment facilities covertly. In 2015, ISIS estimated North Korea’s separated plutonium stockpile at 30-34 kg and its HEU stockpile at between 100-240 kg. The International Panel on Fissile Materials (IPFM) estimated that Pyongyang has produced approximately 30 kg of separated plutonium by the end of 2014, and assesses that the enrichment facility at Yongbyon is capable of producing HEU.

North Korean leader King Jong Un announced in March 2016 that his country successfully developed a miniaturized nuclear warhead capable of being mounted on a ballistic missile. That month, North Korean state media also released images of Kim inspecting what is believed to be a mock-up of a miniaturized warhead. Washington is skeptical of Pyongyang’s miniaturization claims. Still, the head of North American Aerospace Defense Command (NORAD) informed Congress in March 2016 that “it’s the prudent decision on my part to assume that [North Korea] has the capability to…miniaturize a nuclear weapon and put it on an ICBM.” South Korea reportedly assesses that it will take several years before Pyongyang masters miniaturization technology.

Currently, North Korea’s longest-range deployed ballistic missile is the Nodong. With a maximum range of 1,250-1,300 km (approximately 775-800 miles), the Nodong is capable of reaching all of South Korea and parts of Japan.

Fissile Material Production Facilities

Yongbyon

The Yongbyon Nuclear Research Center, located approximately 90 km (54 miles) north of Pyongyang, is North Korea’s main nuclear complex. It houses all of its key (known) facilities, including its plutonium production reactor, reprocessing center, and enrichment plant. Yongbyon will remain a reliable source of both the plutonium and HEU North Korea needs to expand its nuclear arsenal. The 5 MW(e) reactor is producing recoverable plutonium, the reprocessing facility is functioning, and the enrichment facility is online.

Below is a list of the major facilities located at Yongbyon:

5 MW(e) Experimental Nuclear Power Plant: a graphite-moderated reactor. This reactor has been in operation since 1986 and provides North Korea with a source of plutonium. It was shut down between 2007 and 2013. In April 2013, North Korea announced that it would restart the reactor, which appears to have operated intermittently since then. According to the International Atomic Energy Agency (IAEA), the reactor appeared to be shut down from October to December of 2015, likely to remove spent fuel for reprocessing.

Radiochemical Laboratory: a reprocessing facility, where plutonium and uranium are extracted from irradiated (spent) nuclear fuel. It has a production capacity of 100-150 tons of heavy metal per year. North Korea reprocessed 8,000 spent fuel rods here after expelling international inspectors in 2009. According to the IAEA, the facility appeared to be operating from early 2016 to July 2016. ISIS estimates that North Korea separated approximately 5.5 – 8 kg of plutonium during this time, enough for approximately 1 – 4 additional nuclear weapons. In August 2016, an official from North Korea’s Atomic Energy Institute claimed that Pyongyang had resumed spent fuel reprocessing.

Uranium Enrichment Plant: reportedly contains 2,000 centrifuges in six cascades with an enrichment capacity of 8,000 kg seperative work units (SWU) per year. The DNI assessed in 2014 that North Korea was expanding this facility, an assessment confirmed by satellite imagery. According to a 2014 report, North Korea may be adding as many as 2,000 centrifuges, thus doubling its enrichment capacity. In August 2016, an official from North Korea’s Atomic Energy Institute claimed that Pyongyang was producing HEU. The IAEA has stated that the enrichment facility appears to be in operation.

Nuclear Fuel Fabrication Plant: used to convert uranium oxide (U3O8 or “yellowcake”) into uranium metal, and has housed uranium dioxide (UO2) powder, fuel rods, and fuel rod cores.

Light-water reactor (under construction): reportedly has a capacity of 100 MW(th) (25 to 30 MW(e)). In its August 2012 safeguards report, the IAEA indicated that North Korea had made “significant progress” in the construction of the light water reactor at Yongbyon. The facility was reportedly still under construction as of August 2016.

Nuclear fuel rod storage facility.

Mines and Mills

North Korea has two known uranium mines: Wolbisan and Pyongsan. In addition, it has two known uranium mills: Pakchon Uranium Concentrate Plant and Pyongsan Uranium Concentrate Plant. The IAEA has not visited these sites since 1992, relying on satellite imagery to monitor activity there. Satellite imagery analysis by private experts has concluded that the Pyongsan mill is undergoing “significant refurbishment,” suggesting that North Korea plans to mine and mill a “significant amount” of uranium from the Pyongsan mine and possibly other locations.

Sanctions

North Korea withdrew from the Nuclear Nonproliferation Treaty (NPT) in 2003, and expelled international inspectors from the country in 2009, after the collapse of the six party talks. In response to Pyongyang’s refusal to cease its nuclear and ballistic missile programs, the international community has imposed sanctions. After the first nuclear test in 2006, the U.N. Security Council adopted resolution 1718. Among other measures, the resolution prohibits the import to or export from North Korea of battle tanks, heavy artillery, combat aircraft systems, warships, items applicable to its nuclear or ballistic missile programs, and luxury goods. After each subsequent test, the Security Council adopted additional sanctions, further restricting North Korea’s access to sensitive or restricted materials and technology, and to the global economy.

The Security Council enacted additional sanctions against North Korea in response to each of the two tests conducted in 2016, further restricting access to the international banking system, the shipping sector, and to dual-use and luxury items. Resolution 2270 (March 2016) requires the inspection of all cargo going to or coming from North Korea or being shipped by a North Korean national, and imposes other prohibitions on North Korean vessels and aircraft. Resolution 2321 (November 2016) places a cap on North Korea’s annual coal exports, in addition to other measures. Pyongyang reportedly collects over $1 billion annually from its exports of coal—its largest source of revenue. Much of this money is funneled into its nuclear and ballistic missile programs.

The Security Council resolutions also impose restrictive measures, including an asset freeze, transaction prohibition, and travel ban, against designated organizations and individuals connected to North Korea’s nuclear, missile, and military programs. To date, 39 individuals and 42 organizations have been designated by the Security Council.

These measures have targeted some of the main entities in charge of North Korea’s nuclear program. For example, the Ministry of Atomic Energy Industry (aka General Bureau of Atomic Energy*), which was designated in 2009, oversees North Korea’s nuclear program, including activities at Yongbyon. In 2013, it was put in charge of modernizing the country’s atomic energy industry. It is currently in charge of the day-to-day operations of the nuclear weapons program and oversees a number of nuclear-related organizations and research centers. Another entity, the Munitions Industry Department (MID), which was designated in 2016, oversees North Korea’s weapons production and R&D programs. MID planned and prepared the January 2016 nuclear warhead test. According to a 2010 UN Panel of Experts on North Korea report, it has also been involved in overseeing operations at Yongbyon.

The Security Council has also designated producers of machinery and components for the nuclear program. One such entity is Korea Ryonha Machinery Joint Venture Corporation, which was targeted in 2013. Ryonha is North Korea’s primary producer of computer numerically controlled (CNC) machines, including multi-axis CNC machines, which are important for the production of nuclear weapons. Another production entity designated by the Security Council is Korea Hyoksin Trading Corporation. Hyoksin, which was targeted in 2009, is involved in the development of unconventional weapons. It produces electronics and instruments for measuring and testing.

Other entities supporting North Korea’s nuclear program have not been designated. One example is Kim Chaek University of Technology. This institute produces concentrated nitric acid (CNA)- resistant low-carbon stainless steel, which is used in plutonium extraction equipment and spent fuel storage vessels. The University has also trained personnel at Yongbyon.

In recent months, individual countries have sought to increase pressure on Pyongyang and to enforce the sanctions already in place. The United States, Japan, and South Korea implemented another round of autonomous sanctions shortly after the passing of Resolution 2321. Also, in November 2016, the U.S. Treasury Department issued new regulations designed to prevent North Korean banks from accessing the U.S. financial system covertly through correspondent accounts in the United States and other countries. And a number of governments have reportedly either suspended or restricted trade with North Korea in response to international sanctions. These autonomous measures, combined with Security Council resolutions, restrict North Korea’s access to foreign goods and currency.

However, the sanctions regime has failed to change Pyongyang’s behavior or sufficiently hinder its activities abroad, a situation highlighted by the U.N. Panel of Experts. In its latest report from February 2017, the Panel indicates that, despite the strength of existing measures, Pyongyang has still managed to effectively evade sanctions, trade in restricted items, and access the international banking system. North Korea is able to conduct illicit activities due to its sophisticated evasion methods as well as the “insufficient and highly inconsistent” sanctions implementation by U.N. member states.

Sanctions Evasion and Illicit Procurement

North Korea uses shell companies all over the world to procure sensitive material for its nuclear program and other programs of concern. This evasion technique is regularly employed by North Korea’s shipping sector. In 2014, Pyongyang’s Ocean Maritime Management Company (OMM) was designated by the Security Council for its role in an illicit shipment of weapons from Cuba to North Korea. Prior to its designation, OMM was one of North Korea’s largest shipping companies. Since then, it has transferred control of its fleet to an elaborate network of front companies scattered around the world, and has also renamed most of its vessels in an attempt to circumvent international sanctions.

North Korea is also believed to use embedded agents in foreign companies and diplomatic personnel in order to trade in prohibited items. In addition, North Korean state trading companies based in China are reportedly an important channel for Pyongyang to smuggle sensitive equipment and materials. These companies are believed to operate in partnership with private Chinese companies, with many of the larger ventures operating inside of China. In recent years, a number of Taiwanese companies have also exported sensitive equipment to North Korea, including CNC machine tools, a horizontal machining center, advanced industrial computers, and stainless steel tubes.

The Chinese government’s weak enforcement of U.N. sanctions has allowed North Korea’s procurement networks to operate. The New York Times reported in March 2016 that many of the new restrictions against North Korea, including the requirement to inspect all of its cargo, are largely ignored in the Chinese border city of Dandong, through which approximately half of China’s trade with North Korea flows. The report adds that North Korean procurement officials operate freely in the city.

North Korean banks play an important role in the evasion of sanctions, processing payments for illegal transactions and blacklisted end users. One such institution is Daedong Credit Bank, which was designated by the Security Council in 2016. Daedong held over $25 million in Macau-based Banco Delta Asia for financing North Korea’s nuclear weapons program, illicitly gained through narcotics sales and counterfeiting. Another institution is the Korea Kwangsong Banking Corporation, which was also designated by the Security Council in 2016. Kwangson has provided financial services to U.N.-sanctioned entities connected to North Korea’s unconventional weapons programs. And Pyongyang’s Foreign Trade Bank has been used to facilitate transactions on behalf of entities linked to North Korea’s proliferation network. In response to such activities, Resolutions 2270 and 2321 restrict the ability of North Korea’s banks to operate abroad. How effective these restrictions are remains to be seen.

Proliferation to Other Countries

North Korea’s most well-known nuclear client is Syria. Until 2007, Pyongyang was helping Damascus build the Al Kibar nuclear reactor, a covert facility in Dair Alzour, which was to be used for producing plutonium. This assistance came to a halt in September of that year, when Israeli fighters destroyed the facility. Unconfirmed reports indicate that North Korea also supplied Syria with 45 tons of yellowcake for Al Kibar, enough for 89 to 130 kilograms of weapons grade HEU upon further processing and enrichment.

North Korea’s involvement in nuclear activities in other countries is less clear, but it remains willing to export its expertise and technology. In 2016, a North Korean company posted an advertisement online for the sale of Lithium-6. In addition, according to some reports, Iranian scientists were present to observe North Korea’s 2013 nuclear test.

Conclusion

The steady progress North Korea is making in its nuclear program is a testament to the determination of its government and the success of its illicit procurement networks. The latest round of U.N. sanctions has the potential to disrupt these efforts. However, this potential can only be realized if the sanctions are strictly enforced by U.N. member states, especially China.

* The MAEI and GBAE are sanctioned as separate entities by the UN Security Council and the US Treasury Department. Here they are treated as the same entity, per the recommendation of the UN Panel of Experts in its 2015 report.

Iran’s Nuclear Veil

How to increase transparency under the Joint Comprehensive Plan of Action

Introduction

The day is fast approaching when the new American administration, led by President Donald J. Trump, will conduct an unfriendly review of the nuclear pact with Iran reached in 2015. No one knows what this review will produce. If the President decides to “enforce the terms of the […] deal to hold Iran totally accountable,” as he promised during his campaign, a first step should be to make Iran’s nuclear status more transparent.[1]  Transparency is a benefit that the Joint Comprehensive Plan of Action (JCPOA) was supposed to deliver, but did not.  Instead, a sort of diplomatic veil has been drawn around Iran’s nuclear status, obscuring important parts of it from public view.  As a result, it is difficult to know whether the limits on Iran’s nuclear progress are being maintained and the verification procedures established by the deal are functioning properly.

President Obama claimed the deal would furnish “the most robust and intrusive inspections and transparency regime ever negotiated for any nuclear program in history.”[2]  However, the promised transparency has not materialized.

There are two reasons for this opacity:  first, the terms of the JCPOA[3], which provide expressly that the work of the bodies set up to implement it shall be confidential; second, new resolutions by the U.N. Security Council[4] and the International Atomic Energy Organization (IAEA)[5], which replace a series of punitive resolutions from both bodies.  The nuclear deal and the new resolutions were negotiated by the Obama administration, which wished to enshrine the agreement as a foreign policy victory and avoid scrutiny that might draw attention to its flaws.

The lack of transparency is most evident in the work of the multilateral Joint Commission, set up under the deal to resolve disputes.  Its deliberations and even its final decisions are confidential.  Thus the public may never find out, for example, if Iran had limited inspectors’ access to a suspect site, or was importing sensitive nuclear items, or was dispensed from respecting one of the many nuclear material or activity caps enshrined in the agreement.   And the IAEA, long the major source of reliable data on Iran’s nuclear progress, is now issuing reports with a fraction of the information it provided in the past.  As a result, there is uncertainty about whether Iran remains at least one year away from being able to fuel a nuclear weapon—the deal’s milestone achievement.

The new administration, free of any political bias in favor of the deal, should be willing to drop the veil and let the public see as deeply into the deal as originally promised.  This increased transparency would be welcomed by both critics and supporters of the agreement.  It could be accomplished by reinterpreting the scope of the IAEA’s public reporting and changing the rules that govern the Joint Commission.  Neither would require renegotiating the deal itself.

Nuclear Reporting

In February 2016, the IAEA published its first report on Iran’s compliance with the JCPOA after its “Implementation Day.”[6]  The brevity of the report came as a surprise: a scant seven pages, compared to previous reports that routinely ran over 20 pages and included detailed technical annexes.[7]  The post-Implementation Day reports—there have now been four—offer a far narrower view of Iran’s nuclear wherewithal.

Crucially, the new reports fail to include important details that are needed for outside experts to independently assess Iran’s nuclear status and its compliance with the agreement.  The charts below compare what the IAEA reported before and after Implementation Day.  Where in the past, for example, the IAEA published a precise inventory of Iran’s stockpile of low-enriched uranium (LEU), including a detailed accounting of all LEU stockpiles, production, and flows, now the IAEA merely publishes a statement that Iran has not exceeded its overall limit on LEU—without offering any more specific information on the quantity or forms of Iran’s LEU stockpile.  Likewise, the IAEA’s post-Implementation Day reports offer far less detail on the centrifuges operating at Iran’s nuclear facilities, the amount of enriched uranium they are producing, Iran’s research and development work on advanced centrifuges, and other aspects of its nuclear conversion and fuel manufacturing work.  The level of detail needed to assess Iran’s nuclear status is simply not present.  This is all the more baffling because, as a result of the deal, Iran is provisionally applying the Agency’s “Additional Protocol,” which requires Iran to open additional sites to inspectors and provide a greater amount of information about its stockpiles and nuclear plans.  The IAEA is collecting more information, but disclosing less of it to the public.

Below are tables that present a side-by-side comparison of the IAEA’s reporting on Iran’s nuclear program before and after Implementation Day.  They show that the nuclear agreement, which promised unprecedented visibility, has actually provided less transparency and less public information.

Reporting on LEU Stocks in Gaseous Form (Up to 5%)
Before Implementation Day After Implementation Day
Amount of low-enriched UF6 produced

Increase in amount of this UF6 since last report

Annex with details on UF6 production and flows
 
Statement that total stock of UF6 enriched to 3.67% did not exceed 300kg

 

Reporting on LEU Stocks in Gaseous Form (Up to 20%)
Before Implementation Day After Implementation Day
Amount produced at Natanz and Fordow
(As of 2014 Joint Plan of Action)

Amount fed into conversion process

Amount downblended

Amount stored as UF6
 
Statement that Iran is not enriching above 3.67%

Statement that Iran transferred, diluted, or fabricated into fuel plates all uranium oxide enriched to between 5% and 20%

 

Reporting on Centrifuges at the Natanz Fuel Enrichment Plant
Before Implementation Day After Implementation Day
Number of IR-1s installed

Number of IR-1s operating

Number of IR-2ms installed

Number of centrifuges placed in storage
 
Number of 1R-1s installed

Number of centrifuges withdrawn from storage to replace failed or damaged units

 

Reporting on Centrifuges at the Fordow Fuel Enrichment Plant
Before Implementation Day After Implementation Day
Number of IR-1s installed

Number of IR-1s operating

Number of centrifuges placed in storage
 
Number of 1R-1s “maintained”

 

Reporting on Advanced Centrifuge Research and Development
Before Implementation Day After Implementation Day
Models fed with natural UF6

Number of each model installed and size of cascades

Amount of natural UF6 fed into advanced centrifuges
 
Statement that Iran has conducted enrichment in line with its long term plan

 

Reporting on Additional Information
Before Implementation Day After Implementation Day
Natural UF6 produced at the Uranium Conversion Facility (UCF)

Natural UF6 converted into other forms at UCF

Details of nuclear fuel manufacturing at multiple facilities using natural and enriched uranium

An updated list of declared nuclear facilities in Iran
 
 
 
Size of heavy water stockpile

In the past, the IAEA was careful to give narrative accounts of its inspections of key Iranian nuclear sites.  These accounts named the specific sites visited, gave dates of inspection and specific methods of inspection, listed specific equipment inspected and requests to interview Iranian personnel, described the issues raised and explanations received by the inspectors, and listed any unresolved questions.  This allowed the public to know the questions the IAEA was pursuing, the level of cooperation it was receiving from Iranian authorities, and whether questions were being resolved to the Agency’s satisfaction.

This limited reporting has been attributed to a new U.N. resolution.  As of Implementation Day, reporting was no longer driven by the Agency’s “absence of confidence that Iran’s nuclear program is exclusively for peaceful purposes” – the conclusion that sent Iran’s case to the Security Council in 2005.[8]  Rather, the IAEA’s governing board resolved that the Agency has “become seized of a separate agenda item covering JCPOA implementation and verification and monitoring in Iran in light of United Nations Security Council resolution 2231.”[9]  In a March 2016 interview, IAEA Director-General Yukiya Amano explained the distinction:  “In the previous reports the bases were the previous U.N. Security Council resolutions and Board of Governors.  But now they are terminated.  They are gone.  The basis of our report is the resolution of the United Nations Security Council 2231 and the Board of Governors resolution adopted on the 15th of December.  […] And as the basis is different, the consequences are different.”[10]  In other words, it is no accident that there is less transparency now.  The architects of the deal minted a new U.N. resolution that could be interpreted to make it that way.  Now the consequences of that decision are being felt.

The JCPOA also allows Iran to request exemptions from the deal’s requirements.  However, neither such requests, nor the Joint Commission’s decisions, are included in IAEA reports.  For example, the IAEA has never mentioned a series of exemptions that Iran received in order to expedite the implementation of the nuclear deal in January 2016.  As first reported by the Institute for Science and International Security in September 2016, the exemptions fell into three categories.  First, 3.5 percent LEU contained in low level nuclear waste was not counted toward the 300 kilogram cap on LEU, and Iran was given a pass on the near 20 percent LEU contained in “lab contaminant,” which was judged “unrecoverable.”  Second, Iran received permission to continue operating 19 “hot cells” larger in size than permitted by the agreement.  Third, Iran was allowed to bypass the 130 ton limit on heavy water by storing heavy water in Oman that nevertheless remained under Iranian control.[11]  None of these exemptions are described in any of the IAEA’s reports, though all have an impact on the ability to assess Iran’s nuclear status.

Nor do the Agency’s reports describe how Iran is carrying out its “long-term enrichment and research and development enrichment plan,” which Iran has submitted to the IAEA as a requirement of the nuclear agreement.  The agreement allows for limited work on several more powerful centrifuge models but perfecting their operation would decrease Iran’s nuclear breakout time.  Therefore, public information on the work is essential for an assessment of Iran’s nuclear status, as former IAEA deputy director Olli Heinonen has argued.[12]  Iran is publicizing this work on its own so why shouldn’t the IAEA report on it?  For instance, on January 28, Iran’s atomic energy organization announced that it had begun feeding uranium into its IR-8 centrifuge, which it called the “the most advanced generation of centrifuges.”[13]

Nuclear Inspections

Since Implementation Day, the reports contain none of this detail.  Instead, they merely state that the IAEA has “conducted complementary accesses under the Additional Protocol to sites and other locations in Iran.”[14]  Not even the sites visited are mentioned.

There is also the question of “challenge” inspections.  The JCPOA provides a mechanism for mounting inspections of suspicious, undeclared sites in Iran.  How the IAEA would gain access to such sites was one of the most contentious issues in the nuclear talks.  The compromise reached in the agreement allows the IAEA to inspect a suspicious site if five of the eight members of the Joint Commission agree.  This process, including adjudication by the Commission, could take up to 24 days.[15]  While this process is clearly described in the agreement, it is not clear how much information about it would be made public.  Given the known limits on IAEA reporting and the general secrecy of the workings of the Joint Commission, there is cause for skepticism that any meaningful information about challenge inspections would ever come to light.  In fact, over one year after the agreement’s implementation, it is unclear whether a single challenge inspection has been sought or mounted.

This question is particularly important in light of Iran’s claim that its military sites remain off-limits.  The Supreme Leader’s foreign policy advisor, Ali Akbar Velayat, told al Jazeera on July 25, 2015 that “The access of inspectors from the International Atomic Energy Agency or from any other body to Iran’s military centers is forbidden.”[16]  Foreign Minister Javad Zarif similarly assured the Iranian Parliament in July 2015 that he made sure access to military sites was a “red line.”[17]  Nevertheless, these are sites to which, under the deal, Iran is obligated to provide access if the Joint Commission requires it.  Access to military sites is crucial because the IAEA in the past has uncovered evidence of undeclared nuclear work at such sites, like the Parchin military complex, and reported on it.  The IAEA has also connected military entities to illicit nuclear procurement.[18]  The IAEA must establish clear modalities for accessing these sites, and should test them as soon as possible.

The Joint Commission

The JCPOA established a multilateral Joint Commission to act as the dispute resolution and oversight body for the agreement.  It includes representatives from each of the P5+1 countries (China, France, Germany, Russia, the United Kingdom, and the United States), Iran, and the European Union.  The Commission has crucial responsibilities.  They include issuing decisions on disputes by parties, on challenge inspections, on nuclear procurement requests, and on requests for exemption from nuclear restrictions.

According to media reports, the Commission has met at the ministerial level about six times in order to discuss nuclear exemptions requested by Iran, as well as Iran’s dissatisfaction with the pace of economic relief.

However, the Commission operates under rules of confidentiality imposed by the agreement.  The Commission does not even issue a broad public report, as does the IAEA.  Instead, its deliberations and decisions are secret.  Late last year, the Commission released eight documents related to its work, including four decisions made before Implementation Day that exempted Iran from meeting some of the  nuclear restrictions the JCPOA was designed to impose.[19]  It is not clear whether the documents are the totality of the Commission’s decisions or just a selection.

When the American press broke the news last September of the secret nuclear exemptions the Commission gave Iran, State Department spokesperson John Kirby took pains to repeat that “the work of the Joint Commission, as stipulated in the agreement itself, is to be confidential.”[20]  Mr. Kirby would not comment on any decision of the Commission and even refused to use the word “exemption.”  The Commission’s secrecy on this point is troubling because the Commission can grant exemptions in a broad range of areas—exemptions that could loosen the very restrictions that the agreement imposes.  Specifically, the Commission can approve exemptions for research and development on uranium-metal based fuel; the operation of additional or larger hot cells; mechanical testing of new types of centrifuges; the export of enrichment or enrichment-related equipment and technology; and the development, acquisition, or use of multi-point detonators that could be used to trigger a nuclear explosion.[21]  Iran could receive an exemption for any of this activity, and the public might never know.

This veil of secrecy also enshrouds the Procurement Working Group, a technical body overseen by the Commission whose role is to review proposals for nuclear exports to Iran through an official procurement channel.  The group has apparently met to discuss a handful of sales requests.  According to a December 2016 report by the U.N. Secretary General, five proposed sales have been submitted: three were approved and two were under review.[22]  However, there is no description of the item to be exported, the end-user, or the end use.

Finally, as discussed above, the public may never be informed about disputes and decisions on the inspection of suspicious, undeclared sites in Iran—one of the most important and potentially contentious mechanisms created by the agreement.

The U.N. Security Council

U.N. Security Council resolution 2231, which officially implements the JCPOA,[23]  carries forward an embargo on arms imports and exports.  It also restricts ballistic missile development.[24]  The Security Council is charged with enforcing these restrictions for five years for conventional arms, and eight years for ballistic missiles.  However, the Security Council has the authority to approve requests that bypass these restrictions, and its decision to do so is confidential.  According to the Secretary General’s December 2016 report, the Council already has received one request to sell conventional arms to Iran.  That request is “still under consideration.”[25]  There have been Russian media reports that Iran and Russia are actively discussing the sale of $10 billion worth of military hardware, including tanks, artillery, and aircraft.[26]  If the Security Council were to approve such a request, the public may only learn about it once the arms are delivered.

The Security Council also has a role in the nuclear procurement channel.  It issues a final decision on proposals for the sale of sensitive nuclear items to Iran, based on advice provided by the Procurement Working Group.[27]  As explained above, the Security Council has thus far approved three such sales and is considering a further two.  Nothing specific is known about these requests, or the criteria used by the Council to make its decision.

Resolution 2231 does ask that the Secretary General report on the implementation of the resolution’s provisions over which the Security Council has authority.  Two such reports have been issued thus far, and have provided useful, albeit general, information.  Both have described violations by Iran related to arms exports and missile tests; both also have concluded that without consensus among Security Council members, the provisions of the resolution cannot be enforced.

How to fill the transparency gap?

If the Trump administration decides to honor and enforce the agreement, it should start by increasing transparency.  Such a step would be seen as modest and even reasonable, a reaction the administration should welcome.  Although the rules governing the agreement do not require such an increase in clarity, they do not prevent it either.

First, the administration should insist that the IAEA reinterpret U.N. Security Council resolution 2231.  That resolution sets the rule.  It asks the IAEA to “undertake the necessary verification and monitoring of Iran’s nuclear-related commitments […]” under the agreement.  And it asks for “regular updates […] on Iran’s implementation.”  But it says nothing about what the updates should contain.  The resolution tells the IAEA what is “necessary” to inspect, but not what is “necessary” to report.  Thus, there is nothing in the resolution that requires the IAEA to report less now that it did before the agreement was implemented.  The IAEA has simply chosen to report less, and has cited resolution 2231 without true justification.  The new U.S. administration is free to challenge that choice, and to insist that the reporting be restored to its previous level of detail.

Second, the new administration could ask for a change in the rules governing confidentiality at the Joint Commission.  The JCPOA states only that the Commission’s work “is confidential […] unless the Joint Commission decides otherwise.”[28]  It also states that the Commission may “adopt or modify, as necessary, procedures to govern its activities.”[29]  Thus, it is clear that the confidentiality provisions can be changed.  If they were, the public would not be remitted to getting its information from targeted leaks and the post-hoc, incomplete release of randomly chosen documents, as is the case today.  All parties to the agreement would have the benefit of unbiased information released directly and promptly by the Commission itself.  This information should cover Iranian nuclear exemption requests and decisions, the result of any IAEA request for a challenge inspection, and the Commission’s recommendation on procurement requests.

Third, there is no reason why the U.N. Security Council should hide its decisions.  The new administration could also insist that the U.N. disclose its decisions on Iran’s missile development, on proposed military sales by or to Iran, and on approval of nuclear sales to Iran.  The Security Council’s work, as stated vaguely in the nuclear agreement, is governed by “confidentiality procedure of the UN.”[30]  And while this procedure states that sensitive or confidential information is “carefully protected in order to safeguard the interests of the Organization,” other U.N. guidance also promotes “openness and transparency.”[31]  Openness and transparency are exactly what the parties to the nuclear deal promised the agreement would bring.

And fourth, in order to ensure that a commitment to transparency continues through the 15-year lifetime of the agreement, there should be greater congressional involvement.  Congress could help bridge the transparency gap by creating an independent commission to monitor and oversee implementation of the agreement and report violations.  It could be modeled on the Helsinki Commission or the United States-China Economic and Security Review Commission.  This new commission would have access to U.S. government information, be staffed by specialized experts, and have credibility as an official body independent of any administration.  Also, crucially, the commission would allow Congress not only to exercise an oversight role but to work with the new administration to enforce the agreement, and with future administrations if the agreement survives.  The idea of creating a congressional commission was proposed in the previous Congress (HR 3741, the “Commission to Verify Iranian Nuclear Compliance Act”).  The creation of such a commission could be included in a comprehensive Iran sanctions bill that the new Congress is likely to take up.

More transparency should be welcomed by all.  If Iran is shown to be performing, that fact will undercut claims that it cannot be trusted.  If Iran is shown to be cheating, that fact will undercut claims that it can be trusted.  Either way, the public will come out ahead.  It will have gained an amount of truth in what some people fear may be a new, post-factual era.


Footnotes: 

[1] Donald J. Trump, Transcript of remarks at AIPAC Policy Conference, March 21, 2016, available at http://www.policyconference.org/article/transcripts/trump-2016.asp.

[2] Statement by the President on the Framework to Prevent Iran from Obtaining a Nuclear Weapon, April 2, 2015, available at https://obamawhitehouse.archives.gov/the-press-office/2015/04/02/statement-president-framework-prevent-iran-obtaining-nuclear-weapon.

[3] Joint Comprehensive Plan of Action (JCPOA), July 14, 2015, available at http://www.iranwatch.org/library/multilateral-organizations/european-union/joint-comprehensive-plan-action.

[4] Resolution 2231 (2015), U.N. Security Council (S/RES/2231), July 20, 2015, available at: http://www.iranwatch.org/sites/default/files/res2231e.pdf.

[5] Joint Comprehensive Plan of Action implementation and verification and monitoring in the Islamic Republic of Iran in light of United Nations Security Council Resolution 2231 (2015), International Atomic Energy Agency Resolution (GOV/2015/72), December 15, 2015, available at http://www.iranwatch.org/sites/default/files/iaea-pmdresolution-121515.pdf.

[6] Verification and Monitoring in the Islamic Republic of Iran in light of United Nations Security Council Resolution 2231 (2015), International Atomic Energy Agency Report (GOV/2016/8), February 26, 2016, available at http://www.iranwatch.org/library/multilateral-organizations/international-atomic-energy-agency/verification-monitoring-islamic-republic-iran-light-united-nations-security.

[7] Subsequent post-Implementation Day reports are less than five pages each.

[8] Implementation of the NPT Safeguards Agreement in the Islamic Republic of Iran, International Atomic Energy Agency Resolution (GOV/2005/77),  September 24, 2005, available at http://www.iranwatch.org/sites/default/files/iaea-iranresolution-092405.pdf.

[9] Joint Comprehensive Plan of Action implementation and verification and monitoring in the Islamic Republic of Iran in light of United Nations Security Council Resolution 2231 (2015), International Atomic Energy Agency Resolution (GOV/2015/72), December 15, 2015, available at http://www.iranwatch.org/sites/default/files/iaea-pmdresolution-121515.pdf.

[10] Statement by IAEA Director-General Yukiya Amano, March 7, 2016, available at http://www.iranwatch.org/library/multilateral-organizations/international-atomic-energy-agency/iaea-director-general-yukiya-amano-comments-iaeas-reporting-requirements-iran.

[11] David Albright and Andrea Stricker, Institute for Science and International Security, JCPOA Exemptions Revealed, September 1, 2016, available at http://isis-online.org/isis-reports/detail/jcpoa-exemptions-revealed/.

[12] Olli Heinonen, “Ensuring Iran’s Enrichment R&D is for Peaceful Purposes,” Foundation for Defense of Democracies, January 26, 2017, available at http://www.defenddemocracy.org/media-hit/olli-heinonen1-ensuring-irans-enrichment-rd-is-for-peaceful-purposes/#sthash.zpgmyI8D.dpuf.

[13] “Iran Injects UF6 into IR-8 Centrifuges,” Mehr News Agency, January 28, 2017, available at http://en.mehrnews.com/news/123078/Iran-injects-UF6-into-IR-8-centrifuges.

[14] Verification and Monitoring in the Islamic Republic of Iran in light of United Nations Security Council Resolution 2231 (2015) International Atomic Energy Agency Report (GOV/2016/8), May 27, 2016, available at https://www.iaea.org/sites/default/files/16/06/gov2016-23.pdf.

[15] See “How Will Inspections Work in Iran under the Nuclear Deal?” Iran Watch Policy Brief, July 14, 2015, available at http://www.iranwatch.org/our-publications/nuclear-iran-weekly/how-will-inspections-work-iran-under-nuclear-deal.

[16] “Leader’s Top Aide: Int’l Inspectors Not Allowed to Visit Iran’s Military Sites,” Fars News Agency, July 25, 2015, available at http://en.farsnews.com/newstext.aspx?nn=13940503000415.

[17] “Iranian MPs thank negotiating team for standing firm on redlines,” Islamic Republic News Agency, July 13, 2015, available at http://www.irna.ir/en/News/81680602/.

[18] Implementation of the NPT Safeguards Agreement and relevant provisions of Security Council resolutions in the

Islamic Republic of Iran, International Atomic Energy Agency Report (GOV/2011/65), November 8, 2011, available at http://www.iranwatch.org/sites/default/files/iaea-iranreport-110811.pdf.

[19] Communication dated 21 December 2016 to the Agency sent on behalf of High Representative Mogherini in her capacity as Coordinator of the Joint Commission established under the Joint Comprehensive Plan of Action, International Atomic Energy Agency (INFCIRC/907), December 23, 2016, available at http://www.iranwatch.org/library/multilateral-organizations/international-atomic-energy-agency/communication-dated-21-december-2016-agency-sent-behalf-high-representative.

[20] State Department Spokesperson John Kirby Addresses ISIS Report on JCPOA Exemptions for Iran, September 1, 2016, available at http://www.iranwatch.org/library/governments/united-states/executive-branch/department-state/state-department-spokesperson-john-kirby-addresses-isis-report-jcpoa-exemptions.

[21] JCPOA, Annex IV – Joint Commission, 2.1.

[22] Second report of the Secretary-General on the implementation of Security Council resolution 2231 (2015), U.N. Security Council (S/2016/1136), December 30, 2016, available at http://www.iranwatch.org/sites/default/files/unsyg-secondreporton2231.pdf.

[23] Security Council tasks under Security Council resolution 2231 (2015), Note by the President of the Security Council, U.N. Security Council (S/2016/44), January 16, 2016, available at http://www.iranwatch.org/sites/default/files/unsc-s-2016-44-20160116.pdf.

[24] Resolution 2231 (2015), U.N. Security Council (S/RES/2231), Annex B, July 20, 2015, available at: http://www.iranwatch.org/sites/default/files/res2231e.pdf.

[25] Second report of the Secretary-General on the implementation of Security Council resolution 2231 (2015), U.N. Security Council (S/2016/1136), December 30, 2016, available at http://www.iranwatch.org/sites/default/files/unsyg-secondreporton2231.pdf.

[26] “Russia, Iran plan $10bn arms supply to Tehran,” Russia Today, November 14, 2016, available at https://www.rt.com/news/366871-russia-iran-weapons-delivery/.

[27] Security Council tasks under Security Council resolution 2231 (2015), Note by the President of the Security Council, U.N. Security Council (S/2016/44), January 16, 2016, available at http://www.iranwatch.org/sites/default/files/unsc-s-2016-44-20160116.pdf.

[28] JCPOA, Annex IV – Joint Commission, 3.4.

[29] JCPOA, Annex IV – Joint Commission, 2.1.15.

[30] JCPOA, Annex IV – Joint Commission, 3.4.

[31] Ethics Advice and Guidance: Confidentiality and Use of Information, United Nations Ethics Office, available at http://www.un.org/en/ethics/information.shtml.

Attachment:

Iran’s Nuclear Veil: How to increase transparency under the JCPOA

Two Los Angeles-Area Men Arrested in Conspiracy to Export Defense Items to Iran

Two men based in the Los Angeles area were arrested on October 26, 2016 on federal charges related to a conspiracy to export military aircraft parts and other defense items to Iran.  Zavik Zargarian, 52, of Glendale, California, and Vache Nayiran, 57, of Lakeview Terrace, California, were taken into custody and charged with violations of the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations (ITSR).  Zagarian and Nayiran are both dual citizens of Iran and the United States.

The indictment, unsealed on October 26, also names Zagarian’s Glendale-based company, ZNC Engineering, along with two Iranian nationals believed to be in Iran: Hanri Terminassian, 55, and Hormoz Nowrouz, 56.

The indictment alleges that the five defendants participated in a scheme to purchase and illegally export fluorocarbon rubber O-rings to Iran.  O-rings have a variety of military applications and can be used in aircraft hydraulic systems and landing gear.  According to the indictment, Nowrouz, who is managing director of a company called Kalaye Sanaty Iran (KSI), would contact Tarminassian with requests to acquire the O-rings.  Tarminassian, who is a citizen of Iran and a legal permanent resident of the United States, would then contact Zargarian.  Zargarian used his company, ZNC Engineering, to purchase the O-rings from a California-based company. Tarminassian would then arrange for payment to be sent through Nayirian, who would assure the transfer of funds to Zargarian.  Nayrian would ship the O-rings to addresses in Dubai or Kuwait using deliberately falsified export documents that undervalued the items in order to avoid suspicion by the authorities.  Tarminassian would then arrange for the transshipment of the items to Iran, where the ultimate end-user was the Iranian Air Force. According to the indictment, the defendants exported more than 7,000 O-rings to Iran.

Federal authorities also accused three of the defendants of conspiring to purchase and ship jet fighter aircraft parts worth over $3.6 million to Iran.  According to the indictment, Zargarian, acting as an officer of ZNC Engineering, sought to acquire military aircraft parts from U.S.-based suppliers on behalf of Tarminassian. These parts include a pneumatic accumulator, a liquid oxygen converter, and a liquid oxygen tank, parts which can be used in F-14, F-15, F-16, and F-18 fighter jets.  Zagarian negotiated to purchase between 10 and 30 units of each item for Tarminassian from an undercover Homeland Security Investigations officer posing as a parts supplier.

The trial for Zargarain and Nayirian begins on December 20, 2016 in federal court before U.S. District Judge S. James Otero.  If convicted on all counts, Zagarian faces a maximum sentence of 115 years in prison and a $4,770,000 fine.  Nayiran faces 95 years in prison and a $3,700,000 fine.  Both defendants pleaded not guilty and were freed on bail on October 26.  Tarminassian and Nowrouz remain at large.


Sources:

[1] “Two Los-Angeles-Area Men Among Those Charged in Scheme to Smuggle $3 Million in Military Aircraft Parts and Defense Items to Iran,” Press Release, U.S. Attorney’s Office for the Central District of California, October 28, 2016.

[2] Indictment, United States of America v. Hormoz Nowrouz, aka Hormoz Naurouz; Hanri Terminassian; Zavik Zargarian; ZNC Engineering, Inc.; and Vache Nayirian, Case No. CR-14-00598, United States District Court, Central District of California.