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A week ago, the State Department announced the imposition of sanctions for alleged supply of WMD and missile-related technology or destabilizing conventional weapons systems in accordance with the provisions of the Iran, North Korea and Syria Nonproliferation Act (P.L. 109-353). Sanctions were levied against 13 entities from seven countries, as this Global Security Newswire story summarized. And Russia’s Rosoboronexport got sanctioned for dealing with Iran again.

In October’s ACT, Wade Boese offered up a great analysis of the Bush administration’s nonproliferation sanctions policy complete with some neat quotes on sanctions aficionado and the darling of this blog, John Bolton. But because Wade’s article chiefly focused on sanctions of Chinese and Iranian entities, I wanted to write something about the sanctions levied against Russian entities for their trade with countries of concern.

What bugs me here is State’s timing of the sanctions. In a true John Bolton fashion, the Russians got poked in the eye just as they were gearing up to talk START with State. Belatedly sanctioning Russia’s state conventional arms intermediary Rosoboronexport for a transfer of a short range air defense system that was completed in early 2007 seems silly. Yet, this latest imposition notwithstanding, an analysis of the number of State’s sanctions against Russian entities during the last eight years delivers surprising results.

The Russians Say Grrr…

The Russian response to last week’s sanctions determination was quite predictable.

In a 24 October release rus, Rosoboronexport complained that by imposing sanctions, the U.S. was engaging in “unfair competition.” And President Dmitriy Medvedev clearly followed the company’s talking points when he used the same “unfair competition” line a few days later.

However, the Russian Ministry of Foreign Affairs’ official release and Sergey Lavrov’s personal reaction were more colorful.

We consider this absolutely unacceptable, as our entire trade and economic activities in Iran and military-technical cooperation with that country are strictly compliant with the norms existing in international law, with our international obligations and with the export control regime currently in force in Russia. Here there can be no explanations other than another instance of arrogant application by the United States in an exterritorial manner of its national American laws. If it seems to some people in Washington that the US will thus make Russia more pliant towards accepting the American approach to resolving the Iranian nuclear problem, this is a mistake.

The story got nice press coverage. WaPo’s Glenn Kessler even picked up on the peculiar fact that State apparently “granted [Rosoboronexport] a partial waiver to permit the sale of nearly two dozen Russian helicopters to Iraq.” This fact, by the way, was not mentioned by Russian officials or brought up in Russian press coverage.

However, Kessler’s story (along with many others) did not discuss what triggered the sanctions on Rosoboronexport. Kessler surprisingly settled for a non-response from State, writing that State officials “declined to specify why the companies were placed on the list, saying the reasons are classified.”

What Was Transferred and When?

The reason for the sanctions actually seems quite boring. The same Rosoboronexport press release rus, which got cited aplenty for the “unfair competition” line, says that

The decision of the State Department was triggered by Russia’s transfer of the 29 Tor-M1, which supposedly disrupted the balance of forces in the region, and could potentially threaten U.S. forces… The appearance of the Tor-M1 in Iran doesn’t do more than allow for enhancing the protection of most critical small-scale facilities of state and military administration, elements of infrastructure (including nuclear energy, chemical manufacturing, and electrical power stations) from precision weapons strikes.

What Rosoboronexport meant to say by issuing this clarification was that the Tor-M1 was the only thing the company had transferred since it was last sanctioned by State in December 2006. Thus, it had not (yet?) transferred the mighty S-300 to Iran.

On the face of it, State’s wrath for the seemingly defensive Tor-M1 is also not unusual. For about a decade, they’ve been compelled to sanction the Russians for every defense item ever sold — and not sold — to the Iranians. Yet, the Tor-M1 transfer was completed as far back as January 2007. The Russians were even preparing to get punished for the transfer that same month. Surprisingly, though, the sanctions didn’t come until a year and half later.

What’s the Deal With State’s Timing?

Short answer: Dunno. But I wonder…

It’s been pointed out to me that there is a bureaucratic delay between the time a determination is made that a transfer potentially punishable under U.S. law has occurred and the time the imposition of the sanctions is actually announced. Thus, it is quite plausible that the January 2007 transfer of the Tor-M1 was completed too late for State to punish Rosoboronexport as part of the April 2007 round of Iran and Syria Nonproliferation Act sanctions, the only round that seems to have preceded the October 2008 one.

But why haven’t we seen more rounds of Iran and Syria (and North Korea) Nonproliferation Act sanctions since April 2007? And does this have anything to do with a possible reshuffle in the Department of State’s bureaucracy as related to the imposition of sanctions? Just looking at the Federal Register notice, it’s quite clear that the point of contact is now at the Bureau of Verification, Compliance and Implementation instead of the usual Bureau of International Security and Nonproliferation.

The Russians were certain to growl about the sanctions. Yet, State officials had to have known that due to Moscow’s interest in re-starting START, there wouldn’t have been any unexpected policy shifts. And by imposing the sanctions now, some at State might have figured that the Russians would easily swallow them as a farewell present from the departing politicos.

A Concluding Note on Russian Proliferation Trends

If instances of sanctions are to be held as any determinant of State’s perception of Russian proliferation trends, then here are the stats (conventional and WMD-related technology sanctions combined):

For purposes of comparison, during a 1998-1999 Congressional sanctions binge, a total of 14 Russian entities were sanctioned.

Yet, during and after the John Bolton sanctions spree, the record of sanctions on Russian entities and individuals was as follows: three times in 2002, just once in 2003, five times in 2004, five times in 2006 (sanctions on Sukhoy were lifted), zero in 2007, and just once in 2008 (the latter for the Tor-M1, transferred in 2007).

Seems to me the Russian record of proliferation to countries of concern, and Iran in particular, is today less of a cause for concern, at least according to the State Department. And this, of course, is a very positive thing.


The amazing Laura Holgate (with Robert Schultz) and the great Pavel Podvig are crossing swords over at the web edition of the Bulletin of the Atomic Scientists. The issue: Megatons to Megawatts.

Say Holgate/Schultz:

As Pavel Podvig points out in his July Bulletin Web-Edition column, the US-Russia “Megatons to Megawatts” program that is designed to eliminate 500 metric tons of HEU has been one of the most successful and cost-effective programs to reduce nuclear danger. Nonetheless, Podvig argues that extending or expanding the program could increase the risk of nuclear terrorism. Quite simply, he is wrong—his conclusion failing to take into account several key points that add up to a compelling case for moving faster and farther to eliminate HEU and its inherent risks.

Go have a read.


Thanks for all of your comments on the previous post. Yet, I am surprised that no one mentioned the one ongoing attempt to practically implement the multilateral nuclear approaches concept – Russia’s International Uranium Enrichment Center at Angarsk.

We all know the story. The idea grew out of Russia’s 2005 proposal that Iran share ownership of a uranium-enrichment plant, based in Russia. But when that fell through, Moscow committed to creating the IUEC at Angarsk, the first of a network of international centers that would provide nuclear fuel cycle services on a non-discriminatory basis. (By the way, Jane blogged about it here.)

The Angarsk IUEC concept can be summarized as follows:

  • Equal, non-discriminatory membership for all interested countries not envisaging the development of indigenous sensitive nuclear technologies and meeting the established non-proliferation requirements;
  • IUEC membership “advantages” (political, economic, scientific and technical) for the enrichment services recipient countries should outweigh the “disadvantages” of refraining from the development of domestic nuclear fuel cycle capabilities;
  • IUEC enrichment capacities are to be placed under IAEA safeguards; involvement of the IAEA in the Center’s management;
  • Foreign IUEC members will have no access to Russian uranium enrichment technology.

And since January 2006, when Vladimir Putin first announced the concept, the Russians have come a long way in terms of practical implementation of the IUEC. They have a dedicated facility, the IUEC is legally incorporated as a joint stock company and is allowed to own nuclear materials.

Russia also has already recruited two additional participants – Armenia and the uranium-rich Kazakhstan; both of the countries have committed not to develop domestic enrichment capabilities. They’ve also apparently clinched a commitment to participate in the IUEC from Ukraine (despite all of the problems in bilateral relations). (Here is a good summary of IUEC progress.)

But quite a few challenges and questions remain:

  • Membership: The IUEC obviously needs more members. Rosatom has promoted the idea to quite a few other countries, including Japan, South Korea, Bulgaria, Slovakia, Finland, Belgium, Uzbekistan, and even Mongolia. (Early on, it was also pitched to the Indians, conditioning their participation on the NSG exemption.) But what countries would you want to commit to the center and how much stake should they get?
  • Incentives for potential members: These take forever to figure out and negotiate on a case-by-case basis. Participation in Angarsk usually comes with a package of other “stuff” – for example, just for little Armenia, the Russian package included creation of joint venture for uranium prospecting, mining, and processing, a promise to assist with safety issues with Armenia’s Metsamor nuclear power plant, and a Russian commitment to stand ready to build an Armenian NPP. What cookies do you offer to interested countries to get them to commit?
  • IAEA safeguards: Transparency of the IUEC is key. In January 2008, Russia sent a note verbale to the IAEA regarding inclusion of the IUEC into the list of Russian facilities that could be subject to the IAEA safeguards. Yet, only the material at the IUEC will be safeguarded. Further, Moscow has been hoping to resolve practical safeguards issues with the IAEA since early 2008, but there still no official agreement. How do you balance transparency with nonproliferation?
  • U.S. involvement: The Bush administration has been supportive of the IUEC. Earlier this year, there was even some talk of possible U.S. “material” cooperation with the Russians in the IUEC. These discussion, however, seemingly died out after the U.S.-Russian 123 Agreement was withdrawn. But would U.S. participation be a good thing or a bad thing politically for the purported non-discriminatory nature of the IUEC?

But, ultimately, the two questions I think really need answered are these:

  • Does the fact that Moscow is seeking to profit take away from its commitment to the idea of sharing the fuel cycle for the sake of nonproliferation?
  • Does the IUEC effort matter if Iran and other “countries of concern” are NOT participating? (Not participating yet?)

Privet, dear Readers of Wonk,

Greetings from Monterey! By means of an introduction, I’ll say that I’ve been a loyal ACW reader for a long time (we probably have that in common). And as Jeffrey has already mentioned, I’m lucky to share a blog home with ACW alumnus Paul Kerr. I hope you don’t mind having me around this week. Think of me as a modest warm-up act for the other awesome guest blogger(s) that Jeffrey has in store for you.

To kick things off, here is a topic that isn’t oft discussed on ACWmultilateral approaches to the nuclear fuel cycle. You’ve undoubtedly read the 2005 IAEA Expert Group report, which argued that “[s]uch approaches are needed and worth pursuing, on both security and economic grounds.” You’re also likely very familiar with the diverse proposals, which followed this report. All of them are available on the IAEA’s Revisiting the Nuclear Fuel Cycle page.

Rosatom's Children of the Nuclear Renaissance

Anyway, last month, the U.S. National Academy of Sciences released a report on a two-year study jointly conducted with the Russian Academy of Sciences on the “Internationalization of the Civilian Nuclear Fuel Cycle.” Check out the project description and definitely download (and read) the whole report.

As part of this joint study, the NAS-RAS committee analyzed the “proposals and options for future international nuclear fuel cycles, including the incentives that might be required for countries to accept the fuel assurance guarantees and not develop enrichment or reprocessing facilities.” Not surprisingly, the committee endorsed creation of a “global system featuring a small number of centers for the sensitive steps of the fuel cycle.” Yet, the study also noted that

“the implementation of those elements that are feasible today, for example, assurance of fuel supply, should not be delayed while other options are being refined or explored both institutionally and technically.”

This concern about timing seems to be somewhat of a recurring theme. For example, the September issue of Arms Control Today has a great article by Fiona Simpson titled Reforming the Nuclear Fuel Cycle: Time Is Running Out. Simpson, who also authored this ACT piece on multilateral approaches to the fuel cycle with IAEA’s Tariq Rauf four years ago, argues that

“[t]he next six months are likely to prove critical in determining whether any of [the] proposals becomes a genuine blueprint for a new approach to this issue or whether, like similar efforts three decades ago, they simply gather dust.”

So what say you, Readers of Wonk? Are discussions of internationalizing the nuclear fuel cycle losing momentum? Where do we go from here?