Articles and Reports
April 4, 2017
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. The company used multiple avenues to evade U.S. sanctions and export control regulations, including establishing shell companies, falsifying customs documents, and...
Articles and Reports
February 1, 2017
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...
International Enforcement Actions
November 16, 2016
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...
Policy Briefs
November 3, 2016
The United States and its allies have interdicted five separate weapons shipments from Iran to the Houthis in Yemen since April 2015—shipments that violate U. N. Security Council resolutions. According to U.S. Vice Admiral Kevin Donergan, “We know they came from Iran and we know the destination.” The U.S. State Department has also criticized...
Policy Briefs
October 28, 2016
Another Iranian bank has received sanctions relief earlier than anticipated under the nuclear deal with Iran.  The European Union’s sanctions on state-owned Bank Saderat Iran and its London-based subsidiary, BankSaderat PLC, which were originally set to last until 2023, were quietly lifted this week.  The decision was made in April, in response to...
Policy Briefs
October 6, 2016
Last week, the Wall Street Journal reported that the Obama administration secretly agreed to lift United Nations sanctions on two of Iran's missile financing institutions as part of a package of controversial accommodations with Iran in January. Critics of the move have focused on an alleged "quid pro quo" in which the delisting of Bank Sepah and...
Policy Briefs
September 22, 2016
According to a July 2016 report by the U.N. Secretary General, Iranian firms participated in a defense trade show in Iraq last March, in potential violation of U. N. Security Council resolution 2231. Under the resolution, prior approval is required by the Security Council for any arms transfer to or from Iran; none was sought. What's more, one...
Policy Briefs
September 7, 2016
The controversy over the Iran nuclear agreement was reignited last week, after a new report revealed secret exemptions Iran received in order to meet the requirements of the agreement. The response to the report has been predictably polarized...
Weapon Program Background Report
August 9, 2016
This is a brief history of Iran's progress toward the ability to build a nuclear weapon. The emphasis is on achievements, rather than motives. The achievements presented here have been cataloged primarily by the International Atomic Energy Agency (IAEA).
International Enforcement Actions
August 3, 2016
Ali Reza Parsa, a businessman with dual Iranian and Canadian citizenship, pleaded guilty in federal court in January 2016 to conspiring to ship U.S.-origin electronic components from the United States to Iran, via Canada, without a license required by the U.S.

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