How to Prevent Iran from Evading Sanctions at Sea

In this episode of Iran Watch Listen, we sat down with Wolf-Christian Paes, an expert on arms and maritime security who served on the U.N. Panel of Experts on Yemen from 2018 until 2023. We discussed Iran’s support for the Houthi rebel group, the ways in which arms are smuggled into Yemen, and the challenges of enforcing the arms embargo imposed on the Houthis by the U.N. Security Council—as well as what that bodes for the outcome of the current crisis in the Red Sea.  Expert Bio Wolf-Christian Paes is a Senior Fellow for Armed Conflict at the International Institute for Strategic Studies (IISS). From 2018 until 2023, he served as the arms expert on the U.N. Panel of Experts on Yemen, where he monitored the sanctions regime imposed by the U.N. Security Council and reported on maritime security. Prior to that, he was the Head of Advisory Services at the Bonn International Center for Conflict Studies (BICC). Related Resources Wolf-Christian Paes, “Assessment of the Response to Illicit Weapons Trafficking In the Gulf of Aden and the Red Sea,” U.N. Office on Drugs and Crime, March 2024. Reports of the Panel of Experts on Yemen “Iranian Technology Transfers to Yemen,” Conflict Armament Research, March 2017. “Evolution of UAVs Employed By Houthi Forces in Yemen,” Conflict Armament Research, February 2020. Jay Bahadur, “Following the Money: The Use of the Hawala Remittance System in the Yemen–Somalia Arms Trade,” Global Initiative Against Transnational Organized Crime, September 17, 2020. Credits Intro/Outro music by AudioCoffee (Denys Kyshchuk): https://www.audiocoffee.net.

In this episode of Iran Watch Listen, we sat down with Dr. Bruce Goodwin, an expert on nuclear weapons design and testing. We discussed the steps required to build a nuclear weapon and what is publicly known about Iran’s weaponization efforts to date. The conversation took place on May 3 and was hosted by Valerie Lincy, Executive Director at the Wisconsin Project on Nuclear Arms Control, and John Krzyzaniak, a Research Associate at the Wisconsin Project. Expert Bio Bruce Goodwin is a retired senior fellow at the Center for Global Security Research at the Lawrence Livermore National Laboratory. Earlier, he was the Principal Associate Director for the nuclear weapons program at Livermore from 2001 until 2013. He has been a key player in the success of the U.S. nuclear weapons program since 1981, first at Los Alamos National Laboratory and since 1985 at Livermore. While at both Labs, he was a design physicist on five nuclear tests. Related Resources “Additive Manufacturing and Nuclear Security: Calibrating Rewards and Risks,” Center for Global Security Research, Lawrence Livermore National Laboratory, November 2019. “Nuclear Weapons Technology 101 for Policy Wonks,” Center for Global Security Research, Lawrence Livermore National Laboratory, August 2021.

In this episode of Iran Watch Listen, we sat down with Dan Gettinger and Adam Rawnsley, both experts on Iranian drones and drone technology. We discussed the current state of Iran’s capabilities, Iran’s growing ambitions to become a drone exporter, and whether tighter sanctions and export controls could hinder its progress. The conversation took place on September 15 and was hosted by John Caves, Senior Research Associate at the Wisconsin Project on Nuclear Arms Control, and John Krzyzaniak, a Research Associate at the Wisconsin Project. Expert Bios Dan Gettinger is the Director of Publications and Communications at the Vertical Flight Society. Before that he was the founder and co-director of the Center for the Study of the Drone at Bard College where he authored the Drone Databook.  Adam Rawnsley is a reporter at Rolling Stone and a Fellow at the Foreign Policy Research Institute. His work focuses on the intersection of technology and security, and he’s been doing in-depth investigations into Iranian drone proliferation for about a decade.  Related Resources The Drone Databook, Dan Gettinger, Center for the Study of the Drone, 2019. Unmanned Combat Aerial Vehicles: Current Types, Ordnance and Operations, Dan Gettinger, 2021. “The Clues Hidden in the Drones that Attacked Saudi Arabia,” Adam Rawnsley, Daily Beast, 2019. “Inside the U.S.-Iran Drone War,” Adam Rawnsley, Daily Beast, 2019. “Remotely Piloted Vehicles in the Third World: A New Military Capability,” U.S. Central Intelligence Agency, 1986. Evolution of UAVs Employed by Houthi Forces in Yemen, Conflict Armament Research, 2020.

In the fourth episode of Iran Watch Listen, we sit down with Neil Watts, who served for five years as the Maritime Expert on the United Nations Panel of Experts on North Korea. We discuss missile and arms-related cooperation between Iran and North Korea and how such collaboration has evolved over time, from the transfer of complete systems to the sharing of test data and technical expertise. Neil describes the "close working relationship" between Iran and North Korea on ballistic missile development, notably "leapfrog technologies" from North Korea that have allowed Iran to qualitatively increase its ballistic missile capabilities. Our discussion also covers sanctions evasion methods used by Iran and North Korea, including ship-to-ship transfers, transshipment, splitting shipments among multiple containers and vessels, and hiding illicit items in bulk cargo. The conversation took place on September 8 and was hosted by Valerie Lincy, Executive Director of the Wisconsin Project on Nuclear Arms Control, and Treston Chandler, a Senior Research Associate at the Wisconsin Project. Expert Bio Neil Watts is a Senior Contributor at Compliance and Capacity Skills International and a Senior Research Associate at Kings College's Project Alpha. He served as the Maritime Expert on the United Nations Panel of Experts for North Korea from 2013 through 2018, where he investigated sanctions evasion and North Korea's sea-launched ballistic missile program. Neil had the unique opportunity during his service on the Panel to board and inspect several interdicted North Korean-flagged or controlled vessels, including the Chong Chon Gang, which was caught ferrying arms from Cuba to North Korea for repairs. He also served in the South African Navy for over 30 years, specializing in surface warfare and weapons systems. Neil has conducted extensive training for government and industry on sanctions, best practices, and due diligence and advises on maritime security. Related Resources Reports of the Panel of Experts on North Korea, United Nations Security Council. Reports of the Panels on Iran, Yemen, and North Korea, United Nations Security Council via Iran Watch. Treasury Sanctions Those Involved in Ballistic Missile Procurement for Iran, U.S. Department of the Treasury, January 17, 2016. Treasury Sanctions Key Actors in Iran’s Nuclear and Ballistic Missile Programs, U.S. Department of the Treasury, September 21, 2020. Sanctions Advisory for the Maritime Industry, Energy and Metals Sectors, and Related Commodities, Department of the Treasury, Department of State, U.S. Coast Guard, May 14, 2020.

In the third episode of the Iran Watch Listen podcast, we speak with Laura Rockwood, a former senior official at the International Atomic Energy Agency (IAEA), about the authorities that the IAEA uses to conduct nuclear inspections in Iran, as well as Iran's recent decision to reduce the Agency's level of access. Background The IAEA plays a leading role in monitoring Iran’s nuclear program, including through inspections of nuclear material and related facilities. The international community relies on the IAEA and its public reporting as an objective source of information about the status of Iran's nuclear program and Iran’s compliance with restrictions set forth in the Joint Comprehensive Plan of Action (JCPOA), the 2015 agreement placing limits on Iran’s nuclear activities. However, nuclear monitoring in Iran did not begin with the JCPOA. As a party to the Nuclear Nonproliferation Treaty (NPT), Iran has had a Comprehensive Safeguards Agreement (CSA) in force for decades. These Agreements are intended to cover all nuclear material and nuclear facilities in a country and are used to verify that a nuclear program is peaceful. Following the discovery in the 1990s of Iraq's undeclared nuclear program, the IAEA developed an Additional Protocol to CSAs. This Protocol provides the IAEA with more information about and access to the entirety of a country's nuclear fuel cycle. Iran signed an Additional Protocol in 2003 and implemented it provisionally until 2006. In 2015, Iran agreed to resume its provisional implementation of its Additional Protocol—pending its entry into force—under the JCPOA. The IAEA was granted further access pursuant to the JCPOA, including to inventories of key gas centrifuge components and manufacturing equipment, and was provided with a mechanism to request access to locations not declared by Iran but suspected of involvement in Iran’s nuclear-related work. Our Discussion Laura explains the relationship between the IAEA's authorities in Iran and the differing levels of access that they provide. She uses the analogy of a jigsaw puzzle, with the Agency bringing together pieces of information obtained through inspection to verify the peaceful nature of a country’s nuclear program. Iran's CSA gives the Agency a number of puzzle pieces; provisional application of the Additional Protocol provides more pieces of the puzzle and therefore a higher degree of confidence in the peaceful nature of Iran's nuclear program; the JCPOA adds still more pieces and therefore provides even greater confidence. Late last year, Iran’s parliament ordered the government to suspend all voluntary measures under the JCPOA, including provisional application of the Additional Protocol, by February 23 if the United States failed to lift sanctions. The order has limited the Agency's access in Iran, although Iran and the IAEA did strike a short-term agreement, or “temporary bilateral technical understanding,” just before the deadline. While Agency access will be limited to that provided under Iran’s CSA, Iran has agreed to maintain surveillance in other locations that don’t fall under the CSA for up to three months—though it will not share the images unless sanctions are lifted and the JCPOA is again being implemented. Our discussion also covers the world of open source research—both data, and the tools used to ingest that data and turn it into knowledge. The IAEA has embraced this resource: it has a section dedicated to open source data analysis and is increasingly interested in such research from civil society. Laura describes how analysis based on open source data provides a useful check on government conclusions; it offers a means of verifying governments' claims and a way for governments to share information without compromising sources and methods. Laura further emphasizes the value of publicly releasing IAEA reports, and for those reports to include a high level of detail. This provides transparency and confidence in the nuclear intent of the country being inspected. Expert Bio Laura Rockwood is Director of One Earth Future's Open Nuclear Network, which works on the reduction of nuclear risk using innovation, inclusion, and dialogue supported by open-source data. She spent 28 years at the IAEA, including as the Section Head for Non-Proliferation and Policy in the Office of Legal Affairs. Laura was also the senior legal advisor on all aspects of IAEA safeguards, the principal author of what became the IAEA's Model Additional Protocol, and a participant in negotiations on Iran, Iraq, and North Korea. Useful Links “IAEA Safeguards Overview: Comprehensive Safeguards Agreements and Additional Protocols,” International Atomic Energy Agency “IAEA and Iran,” International Atomic Energy Agency “Monitoring Iran’s Nuclear Activities: NPT and JCPOA Requirements,” Arms Control Association, February 2021 “Joint Statement by the Vice-President of the Islamic Republic of Iran and Head of the AEOI and the Director General of the IAEA,” Atomic Energy Organization of Iran and International Atomic Energy Agency, February 21, 2021 “Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security Council Resolution 2231 (2015),” International Atomic Energy Agency, February 16, 2021 “How Will Inspections Work in Iran under the Nuclear Deal?” Iran Watch, July 14, 2015

In the second episode of Iran Watch Listen, we speak with John Smith, the former Director of the U.S. Treasury Department's Office of Foreign Assets Control (OFAC), about the impact of the Trump administration's Iran sanctions campaign and how Iran policy might change with the incoming Biden administration. Background OFAC administers and enforces U.S. economic and trade sanctions programs. Foreign individuals, companies, and groups that pose a threat to U.S. national security, foreign policy, and economic goals may be sanctioned for laundering money, drug trafficking, terrorist activities, human rights abuses, and contributing to the proliferation of weapons of mass destruction. The Treasury Department, and in particular OFAC, have increasingly been called on by successive administrations and by Congress to wage economic war with respect to national security and foreign policy threats to the United States. Our Discussion We hear from John about the key role OFAC has played in U.S. efforts to counter the multiple threats Iran poses: more than a decade ago through sanctions on Iran's shipping, energy, and banking sectors; in 2015 and 2016 when some of these sanctions were relaxed as part of the Joint Comprehensive Plan of Action (JCPOA), the nuclear deal with Iran; and more recently, as part of the Trump administration's sanction-based "maximum pressure" campaign against Iran. Since the United States withdrew from the nuclear deal with Iran in 2018, OFAC has imposed sanctions on Iran’s nuclear program, arms sales, petroleum exports, metals industry, and a number of other sectors. Just last month, OFAC strengthened sanctions against Iran's financial sector – part of a flood of new sanctions planned by the Trump administration before Joe Biden's inauguration. John puts the latest actions into context, explaining the difference between sectoral sanctions and targeted designations using terrorism or proliferation authorities. He argues that while the outgoing administration's pressure campaign has unquestionably crippled Iran’s economy, it has failed to rally most of the world behind U.S. policy or to compel Iran to strike a new deal, which looks as elusive as ever. It can take months for the United States to impose or remove sanctions on a particular entity, because of the evidentiary requirements for such actions. We discuss how the Trump administration's multilayered sanctions on Iran will complicate any effort by the Biden administration to offer Iran economic relief as part of negotiations or a new agreement. We also touch on the role that diplomacy has played in U.S. sanctions policy regarding Iran. Expert Bio John E. Smith, former Director of OFAC, is a partner at Morrison and Foerster, where he co-heads the firm's national security practice. At OFAC, John was centrally involved in all aspects of developing, implementing, and enforcing U.S. government sanctions requirements. As OFAC Director, he oversaw every OFAC enforcement case against financial institutions and global operating companies. John has also served in the U.S. Justice Department and on a terrorism sanctions committee at the United Nations. Useful Links “U.S. ‘Maximum Pressure’ Campaign Expands Isolation of Iran's Financial Sector,” Morrison and Foerster, October 15, 2020 “Treasury Sanctions Eighteen Major Iranian Banks,” U.S. Department of the Treasury, October 8, 2020 “U.S. Treasury Secretary Jacob J. Lew on the Evolution of Sanctions and Lessons for the Future,” Carnegie Endowment for International Peace, March 30, 2016

In the inaugural episode of Iran Watch Listen we discuss deceptive shipping practices used by Iran to evade U.S. sanctions and U.S. efforts to counter these practices with two experts from the U.S. State Department: Blake Pritchett, the Deputy Director of the Office of Economic Sanctions Policy, and Jen Chalmers, Chief of the Disruption Operations and Transport Team. Read more about our guests below. Background On May 14, the U.S. Departments of State and the Treasury, along with the U.S. Coast Guard, issued a Maritime Advisory listing techniques that Iranian merchant vessels use to evade economic sanctions. The United States followed this measure on June 8, when additional sanctions on Islamic Republic of Iran Shipping Lines (or IRISL) and its Chinese-based subsidiary went into effect; both companies employ many of the tactics outlined in the Advisory. On the same day, the U.S. imposed secondary sanctions on more than 100 vessels owned by or otherwise linked to IRISL. Iran continues to sell oil and petroleum products despite U.S. sanctions. The United States and other countries have also caught Iran sending weapons to the Houthis in Yemen, demonstrating the need to counter illicit Iranian shipping and sanctions evasion. Our Discussion The Advisory provides industry actors, in particular those operating in or near high risk jurisdictions, with specific business practices that, if implemented, would help them identify and disrupt illicit Iranian transfers. We discussed the deceptive shipping practices used by Iran, recent outreach by the U.S. government to the industry actors about these practices, and relevant industries' response. We also highlighted how Iran uses the techniques outlined in the Advisory to move goods that range from arms to oil. Expert Bios Blake Pritchett is the Deputy Director of the Department of State's Office of Economic Sanctions Policy and Implementation in the Bureau of Economic and Business Affairs. His office maintains and enforces sanctions to maximize their economic impact on the targets and minimize the damage to U.S. economic interests. Blake manages the office's licensing and policy work. Jen Chalmers is the Team Chief for Disruption Operations and Transport in the Office of Counterproliferation Initiatives in the U.S. Department of State's Bureau of International Security and Nonproliferation (ISN). Her office works to develop and implement appropriate diplomatic, defense, law enforcement, and rapid response options to combat the proliferation of weapons of mass destruction. Jen focuses on counterproliferation policies related to disrupting illicit maritime trade. Useful Links "OFAC Advisory to the Maritime Petroleum Shipping Community," U.S. Department of the Treasury, September 4, 2019 "Guidance to Address Illicit Shipping and Sanctions Evasion Practices," U.S. Coast Guard, U.S. Department of State, and U.S. Department of the Treasury, May 14, 2020 "United States Designates Key Iranian Shipping Entities under Proliferation Authority as Tehran Continues to Expand Proliferation Sensitive Activities," U.S. Department of State, June 8, 2020 "Treasury Sanctions Five Iranian Captains Who Delivered Gasoline to the Maduro Regime in Venezuela," U.S. Department of the Treasury, June 24, 2020

Welcome to Iran Watch Listen, a new podcast for the Wisconsin Project on Nuclear Arms Control's Iran Watch website hosted by Valerie Lincy, the Wisconsin Project's director. Iran Watch Listen will bring you in-depth interviews with experts in and out of government. We'll be talking to them about Iranian proliferation and illicit procurement plus related export control and sanctions efforts. You'll be able to listen to some of what you normally read on Iran Watch. The aim is to bring forward non-partisan, expert voices to provide you with a range of perspectives on one of the most pressing proliferation challenges of the day. Iran Watch and this podcast are published by the Wisconsin Project on Nuclear Arms Control, a research organization in Washington, D.C. that works to prevent international trade from contributing to the proliferation of weapons of mass destruction.