International Nonproliferation Export Control Program (INECP) Proliferation Procurement Tactics and the Role of Strategic Trade Controls
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1 International Nonproliferation Export Control Program (INECP) Proliferation Procurement Tactics and the Role of Strategic Trade Controls
2 Outline A brief history of proliferation Examples of contemporary proliferation Karni (South Africa) XVAC (LAX) Yadegari (Canada) Khaki and Yi Ghasri (Sweden) Proliferation threat and procurement tactics - What are strategic commodities? Introduction to Commodity Identification Training (CIT)
3 A Brief History of Proliferation and Nonproliferation Nuclear Industry Dawn of nuclear age Atoms for Peace Overt facility transfers Nuclear Renaissance -More reactors -More enrichment -More suppliers Proliferation Mode Diversion Espionage, turnkey peaceful facilities Procurement Dual-use gap, clandestine facilities Illicit Supply proliferation networks, sub-state actors, terrorism Secondary Suppliers Strain on safeguards and export controls Nonproliferation Response NPT Trigger Lists Safeguards to prevent diversion/misuse Strengthened Export Controls: NSG/Dual-Use Strengthened Safeguards: Additional Protocol PSI, UNSCR 1540 effective export control implementation, interdiction, LEEMs, WCO, etc. next generation safeguards, State Level Concept, State Factor Analysis, etc.
4 2000 s Illicit supplier networks 2000 s brought new proliferation revelations - New and intensified terrorism concerns post 9/11 - New clandestine activities by Libya, Syria, Iran. - Networks of enterprises and brokers defying export controls - E.g., A.Q. Kahn network
5 The Privatization of Proliferation Privatized proliferation (enterprises, brokers, procurement agents, etc.) now overlays the historical pattern of state-based nuclear assistance. - Proliferation operations by non-state actors occur counter to or outside of state-level policy commitments Thus, the focus of nonproliferation efforts expanded from the domain of policy into implementation and enforcement. - UNSCR PSI - Development of licensing and enforcement experts meetings (LEEMs)
6 Examples of Contemporary Proliferation 2004: Asher Karni Pakland PME, a Pakistani company, approached South African company Top-Cape in search of PerkinElmer triggered spark gaps CEO Asher Karni worked through another layer of intermediaries to obtain the switches Karni falsely indicated the triggered spark gaps were intended for medical use Karni re-exported the switches to Pakistan via Dubai. The air waybill listed them as scientific equipment On September 14, 2004, Asher Karni pleaded guilty to arranging illegal export of nuclear-related equipment Triggered Spark Gap Sources: U.S. DOJ Press Release, Pakistani businessman indicted for trafficking in nuclear detonators and testing equipment dated Apr 8, 2005 Asher Karni Case Shows Weakness in Nuclear Export Controls by Jacob Blackford, Institute for Science and International Security, Sept. 8, 2004.
7 Examples of Contemporary Proliferation 2009: XVAC 11 shipments from XVAC in Burbank, CA - Sole proprietor: Jirair Avanessian (US lawful permanent resident, citizen of Iran) - All shipments of spare parts declared value below $ No export declaration required - One shipment appraised at $188k - Actually new vacuum pumps and other equipment Investigation - $1.6M in wire transfers from Sweden, UAE, and HK - Avanessian would ship to Sairafi in RAK/UAE, Sairafi would ship to Masoumian in Iran
8 Examples of Contemporary Proliferation 2009: Canada s first export control prosecution Yadegari, an Iranian-born Canadian citizen, procured Setra pressure transducers from Pfeiffer Vacuum in the U.S. - Stated they were for export to Denmark Pfeiffer reported suspicious procurement Financed and directed by N. Tabari in Iran - Tabari advised Yadegari to conceal value of transducers, remove labels and ship to a company in the UAE - UAE company would then re-export to Tabari - Yadegari was tasked by Tabari to obtain nearly $1M worth of controlled goods - Yadegari contacted over 118 companies and exchanged more than s with suppliers, manufacturers, and Tabari Yadegari arrested and convicted of 9 export control violations and sentenced to 20 months in prison
9 Examples of Contemporary Proliferation 2012: Khaki and Yi Khaki-Arrested in Philippines Parviz Khaki, citizen of Iran, and Zongcheng Yi, resident of China, indicted for alleged efforts to obtain and illegally export maraging steel, aluminum alloys, mass spectrometers, vacuum pumps, and other items Khaki arrested in May 2012 in the Philippines; Yi remains at large Alleged scheme: - Khaki directed Yi and others to contact U.S. companies, purchase goods and have the goods exported from the U.S. through China and Hong Kong to Khaki and others in Iran. - Yi and others allegedly made a variety of false statements to U.S. companies on behalf of Khaki to conceal that Iran was the final destination and end-user of the goods and to convince U.S. companies to export these items to a third country.
10 Examples of Contemporary Proliferation 2013: Sweden s first export control prosecution Shahab Ghasri, a Swedish citizen born in Iran Customs declaration said valves would be exported to the UAE Address tags on the boxes indicated Iran Before loading the airplane to UAE, he planned to send in new papers with Iran as recipient country Product: 11 Pfeiffer Control Valves, Type BR 1a-7 Vacuum pumps District court in Lund found Ghasri guilty on February 6, 2013.
11 11 Proliferation Threat There is no greater threat to global peace and security than the spread of weapons of mass destruction. Keeping WMD out of the hands of state and non-state actors requires a coordinated and substantial effort.
12 Proliferation Procurement Programs Proliferation history demonstrates that countries developing WMD programs build indigenous production facilities These facilities rely on imports of special equipment, materials, systems, and components WMD procurement programs systematically use networks of agents, brokers, and front companies to obtain these commodities
13 What are strategic commodities? 13
14 Strategic commodities are used to develop, produce, and/or test WMD Regime Est. Membership Guidelines to Control Australia Group (AG) CW precursors, pathogens & toxins, and dual-use equipment Missile Technology Control Regime (MTCR) Delivery systems and dual-use materials & equipment Nuclear Suppliers Group (NSG) Nuclear commodities and dual-use materials & equipment Wassenaar Arrangement (WA) Conventional weapons & dual-use goods In response to proliferation developments, the nonproliferation regime has developed guidelines and control lists Carbon fiber, filament winding machine, and gas centrifuge rotors
15 Proliferation Procurement Differs from Traditional Smuggling Traditional Smuggling Proliferation Procurement - Cartel suppliers - Commercial suppliers - Illicit substance or contraband - Legitimate dual-use commercial goods - Concealed when shipped - Often shipped openly - Distribution networks - Procurement networks - Recurring transactions - Atypical transactions - Sell into mass market - Diversion from commercial market to clandestine end user - Money launderers, organized crime - Brokers, front companies
16 Proliferators Attack Export Control Weaknesses 16 Supplier Agent/ Broker Intermediate Consignees End User Some suppliers willing to export illegally, out of ignorance, for economic reasons, or to provide clandestine assistance Inaccurate or vague commodity descriptions complicate enforcement Agents of foreign procurement networks obtain goods, often with circuitous buying patterns, and ship without license Disguises or falsifies the final recipient country and/or the end user Exploit countries with ineffective export controls and other loopholes Diversion in transit and smuggling Use of other enterprises and universities to acquire facilities, equipment, technology and training Cover names and front companies diversion to unknown ultimate end user Utilization of dual-use or uncontrolled commodities to obscure the actual use in a weapons program False end use statements, connections to activities of concern
17 Current Trends are Intensifying Proliferation Threats 17 Globalization - Increasing transshipment trade Modernization - Technology advances and ease of intangible transfer of technology WMD Brokering - Front companies, offshore procurement networks and black-market supply networks Terrorism - Threat of development and use of WMD by subnational groups Secondary Proliferation - Proliferants are themselves now suppliers of WMD commodities and know-how
18 18 Summary States continue to build WMD programs through illicit dual-use purchases by taking advantage of vulnerabilities in export control systems - Sub-state groups also pose a credible threat Proliferators use clandestine brokering, procurement and supply networks - The proliferation threat is evolving, e.g. privatized proliferation - Nonproliferation responses need to evolve too Suppliers must guard against inadvertently contributing to weapons programs in countries of proliferation-concern Transit states risk harboring brokers and front companies supplying WMD programs with crucial commodities Nonproliferation implementation initiatives are needed to help states effectively implement strategic trade controls to block illicit supply and procurement
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