The procurement channel set up under the Joint Comprehensive Plan of Action (JCPOA), or Iran nuclear deal, appears to be considering fewer proposals than expected and is altogether unused by a traditionally illicit conduit to Iran’s nuclear, missile, and non-nuclear programs, namely China. The procurement channel was designed to regulate Iran’s imports of nuclear and nuclear-related dual-use goods for nuclear or non-nuclear use. Given that Iran’s non-nuclear industries have often imported nuclear dual-use goods, this finding raises the question of whether the procurement channel, and its associated Procurement Working Group (PWG), is simply not being used, but illicit, nuclear dual-use supplies are still going to Iran.
Although no evidence has emerged of banned sales going from the United States, Europe, or Japan, which have often been targets of Iranian illicit procurement networks, there is concern that banned sales could be going from parts of Asia. In particular, Chinese entities may be continuing to make sales of nuclear dual-use goods to Iran without using the channel. The United States and its allies should augment efforts to detect and intercept the flow of any strategic goods from China to Iran and from other potentially illicit supplier countries to Iran. China needs to reach out to suppliers or distributors of dual-use goods operating on its territory and ensure that they are informed about China’s export control laws and PWG requirements governing the sale of nuclear dual-use goods to Iran’s industries, whether they be nuclear or non-nuclear.
Read the full report at the Institute for Science and International Security