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October 28, 2021

This month's newsletter features an international enforcement action
examining two recent prosecutions of Iranian efforts to illicitly procure
mass spectrometers, machines that can be used for uranium enrichment as
well as a range of non-nuclear activities. The two cases, one in Germany
and the other in the United States, showcase the diverse methods Iran uses
to acquire export controlled technology.

The newsletter also features profiles of three entities linked to Iran's
military activities in Syria. Featured documents from the Iran Watch
library include a policy speech by a U.S. Department of Justice official on
corporate sanctions-compliance enforcement, Germany's imposition of
penalties on the Hamburg branch of Iran's Bank Melli, and readouts of
ongoing diplomatic activity related to Iran's nuclear program, as well as
news about the International Atomic Energy Agency's increasing difficulty
monitoring Iranian uranium enrichment

[2]View the newsletter in your browser and [3]subscribe to receive it in
your inbox.

PUBLICATIONS

[4]

Image source: Wikimedia Commons, CC 1.0

Enforcement Action | [5]Mass Spectrometer Cases Illustrate Diversity of
Iranian Procurement Efforts

As Iran ramps up uranium enrichment, authorities in multiple countries have
uncovered efforts by Iranian agents to procure mass spectrometers from
abroad. These dual-use machines can precisely measure the purity and
molecular structure of radioactive material and also have a range of
non-nuclear applications. One recent case involved two individuals with
ties to Canada and Iran who allegedly transshipped U.S.-origin
spectrometers to Iran via the United Arab Emirates (UAE). A second case
involved a German-Iranian national who allegedly shipped spectrometers
directly from Germany to Iranian companies that had been sanctioned by the
European Union for supporting Iran's nuclear program.

These cases, both opened in 2021, involve alleged transactions dating from
2015-2016 and 2019, respectively. The timing indicates that Tehran may have
continued to use illicit means to further its uranium enrichment program
even though the 2015 Joint Comprehensive Plan of Action (JCPOA) provided a
licit procurement channel for such acquisitions. The cases also suggest
that Iran still relies on, or prefers, Western-origin technology for its
nuclear program, and they provide two illustrative examples of the diverse
sanctions evasion methods used to import items from Europe and North
America into Iran.

[6]READ THE FULL ENFORCEMENT ACTION

ENTITIES OF CONCERN

Iran relies on key transportation and financial firms to facilitate its
nuclear and missile programs and to support Tehran’s state-sponsored terror
operation overseas.

[7]Mahan Air

An Iranian commercial airline; has provided assistance to the Islamic
Revolutionary Guard Corps-Qods Force (IRGC-QF) and Lebanese Hizballah by
transporting operatives, weapons, equipment, and funds to Syria, according
to the U.S. Treasury Department; has provided travel services to IRGC-QF
personnel flown to and from Iran and Syria for military training; has
facilitated the covert travel of IRGC-QF members by bypassing security
procedures; has received assistance from the Iran-based financial
institution Bank Tejarat.

[8]LEARN MORE

[9]Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF)

A branch of the IRGC that supports terrorist organizations; provides
financial and military support to militant and terrorist groups, including
to Hezbollah and groups in Africa; officers have trafficked narcotics and
use diplomatic, non-governmental, and humanitarian organizations as cover
for operational activities; has provided support and equipment to the
Syrian government to repress civilian movements; has cooperated with Yas
Air (Pars Aviation Services Company), Mahan Air, and Iran Air, to
reportedly supply the Syrian government with weapons and crowd control
equipment; reportedly uses Syria as a hub to transfer weapons to Hezbollah
in Lebanon, Hamas in Gaza, and Islamic Jihad in the West Bank.

[10]LEARN MORE

[11]Bank Tejarat

A large Iranian commercial bank that has directly facilitated Iran's
nuclear efforts and supported the activities of entities involved in Iran's
missile program; assisted designated Iranian banks in circumventing
international sanctions, according to the European Union; in 2011,
facilitated the movement of tens of millions of dollars to assist the
Atomic Energy Organization of Iran (AEOI) in its effort to acquire
yellowcake uranium; conducted business for front companies of Shahid Hemmat
Industrial Group (SHIG); provided financial services to Bank Mellat and
Export Development Bank of Iran (EDBI) that supported the activities of
subsidiaries of the IRGC, Defense Industries Organization (DIO), and
Ministry of Defense Armed Forces Logistics (MODAFL).

[12]LEARN MORE

IN THE NEWS

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Image source: IAEA Imagebank, CC BY 2.0

[14]IAEA Chief Warns Iran Nuclear Surveillance Is No Longer Intact |
Financial Times

October 19: International Atomic Energy Agency (IAEA) Director General
Raphael Grossi said on October 18 that he has not been able to speak
directly with Iran's Foreign Minister Hossein Amirabddollahian and that he
needs to do so urgently. Meanwhile, Grossi said Iran's breakout time to
having enough fissile material for a nuclear weapon is down to "a few
months" and is becoming shorter as Iran employs more advanced centrifuges.
He added that IAEA's monitoring system is "not intact" due to Iran's
continued refusal to allow new cameras at a centrifuge manufacturing plant
in Karaj. The plant was damaged in a June attack that Iran blames on
Israel.

[15]Iran Makes More 20% Enriched Uranium Than Reported By IAEA | Associated
Press

October 10: In September, the IAEA estimated that Iran's stockpile of 20%
enriched uranium amounted to 84.3 kilograms. Iran's nuclear chief Mohammad
Eslami told Iranian state media on October 9th that Iran actually possesses
over 120 kilograms of the material. Eslami claimed that the additional
production was necessary because other parties to the JCPOA have not
delivered fuel for the Tehran Research Reactor as promised by the 2015
agreement.

[16]Norway Charges Professor With Violating Sanctions On Iran | Associated
Press

September 29: Norwegian authorities have pressed charges against a
professor for violating sanctions on Iran between 2018 and 2019. The
professor invited four Iranian researchers to a university in Trondheim,
where he gave them access to the "nano-mechanical lab", which can analyze
metal alloys. One of the Iranian researchers allegedly installed software
on a computer system that allowed him to continue to collect data without
university credentials. Norwegian prosecutors said that the knowledge had
the potential to be useful to Iran's nuclear program. The professor, a
German-Iranian dual citizen, has left Norway but is willing to return for
court proceedings, according to his attorney.

FROM THE LIBRARY

While the monitoring dispute between Iran and the IAEA simmered, the United
States, Iran, and other JCPOA participants held bilateral meetings and
calls centered on the question of when--and under what conditions--nuclear
negotiations would resume.
* In an [17]interview, Iranian President Ebrahim Raisi said Iran is
serious about nuclear talks but the “other side” should lift sanctions to
show its own seriousness.
* Deputy Director of the EU Action Service Enrique Mora [18]met with his
Iranian counterpart, Ali Bagheri, in Tehran to urge Iran to return to the
negotiating table.
* Russian Foreign Minister Sergei Lavrov [19]met with his Iranian
counterpart, Hossein Amirabdollahian, in Moscow.
* Lavrov also had a [20]phone call with U.S. Secretary of State Antony
Blinken to discuss “mutual compliance” with the JCPOA by Iran and the
United States.

In the sanctions arena, the United States reversed its missile-related
designations of two Iranian firms after they [21]brought a lawsuit in U.S.
court. A U.S. government spokesperson denied that the delistings were
related to ongoing diplomatic efforts with Iran. Authorities in the United
States and Europe pursued Iran-related regulatory activity in October.
* Associate Deputy Attorney General John Carlin [22]laid out an
aggressive sanctions enforcement policy in a public speech.
* The U.S. Department of the Treasury [23]delisted Mammut Industrial
Group and Mammut Diesel a year after their initial designations for
supporting Iran's missile program.
* The German financial regulator BaFin [24]banned the Hamburg branch of
Iran’s Bank Melli from issuing new loans after finding it to be violating
accountability rules.

Iran Watch is a website published by the Wisconsin Project on Nuclear Arms
Control. The Wisconsin Project is a non-profit, non-partisan organization
that conducts research, advocacy, and public education aimed at inhibiting
strategic trade from contributing to the proliferation of weapons of mass
destruction.

Copyright © 2021 - Wisconsin Project on Nuclear Arms Control

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