Executive Summary of Findings on Adherence to and Compliance with Arms Control, Nonproliferation, and Disarmament Agreements and Commitments (Excerpts)

April 15, 2020

Weapon Program: 

  • Nuclear
  • Chemical
  • Biological

Related Country: 

  • United States



This document is an unclassified Executive Summary of the Report that is transmitted pursuant to Section 403 of the Arms Control and Disarmament Act, as amended (22 U.S.C. § 2593a), which requires a report by the President on Adherence to and Compliance with Arms Control, Nonproliferation, and Disarmament Agreements and Commitments.




Iran’s efforts to retain files, documents, and personnel related to its pre-2004 nuclear weapons program – as revealed in the atomic archive acquired by Israel in 2018 – suggest that Iran may have maintained this information at least in part to preserve technical expertise relevant to a nuclear weapons capability, and potentially to aid in any future effort to pursue nuclear weapons again, if a decision were made to do so.

In November 2019, the Acting IAEA Director General (DG) reported the detection by IAEA inspectors of particles of chemically processed uranium at an undeclared location in Iran, and noted that this indicates the possibility of undeclared nuclear material in Iran.  The IAEA continues to engage Iran regarding an explanation for the presence of these uranium particles that is consistent with the IAEA’s technical analysis.  Iran’s intentional failure to declare nuclear material subject to IAEA safeguards would constitute a clear violation of Iran’s CSA required by the NPT, and would constitute a violation of Article III of the NPT itself.  Until Iran provides a full and complete explanation for the presence of this man-made uranium, the IAEA’s safeguards concerns are a matter of current proliferation concern.  (Following the reporting period, additional concerns arose with regard to Iran’s compliance with its safeguards obligations and commitments.  In March 2020, the IAEA DG reported that Iran had failed to provide inspector access at two locations not declared by Iran, and did not substantively respond to the IAEA’s requests for clarification regarding possible undeclared nuclear material or activities at those locations and a third, unspecified location.)

During the reporting period, Iran progressively expanded its uranium enrichment activities and stockpile of enriched uranium, key factors in determining the amount of time required to produce enough fissile material for a nuclear weapon or device, should Iran decide to pursue nuclear weapons.  If Iran were to manufacture or otherwise acquire a nuclear weapon, such actions would violate its obligations under Article II of the NPT.




The United States certifies Iran is in non-compliance with the CWC due to (1) its failure to declare its transfer of CW to Libya during the 1978-1987 Libya-Chad war, (2) its failure to declare its complete holdings of Riot Control Agents (RCAs), and (3) its failure to submit a complete Chemical Weapons Production Facility (CWPF) declaration.  Further, the United States has concerns that Iran is pursuing pharmaceutical-based agents (PBAs) for offensive purposes.




During the reporting period, Iran’s activities raised concerns regarding its compliance with Article I of the BWC.  The United States continues to assess that Iran has not abandoned its intention to conduct research and development of biological agents and toxins for offensive purposes.  This is based on a cumulative assessment of current and past Iranian activity and its continued lack of transparency.  Also, Iran maintains flexibility to use, upon leadership demand, legitimate research underway for biodefense and public health purposes for a capability to produce lethal BW agents; whether maintaining this flexibility is pursuant to decisions by leadership is unknown.  The United States remains unable to differentiate some of Iran’s public health research and biodefense activities from those that are prohibited under the BWC, complicating assessments of Iranian compliance.

Historically, the issue of compliance by the Islamic Republic of Iran (Iran) with the BWC has been of great concern for many years, though the assessments have changed over time.  In the 2005 Report, for instance, United States assessed that “based on all available information, Iran has an offensive biological weapons program in violation of the BWC.”  In 2010, it noted that “Iran may not have ended activities prohibited by subparagraphs (1) and (2) of Article I of the BWC.”