On September 9, 2021, the German Federal Prosecutors Office issued an arrest warrant for a German-Iranian citizen, Alexander J., who is accused of illegally exporting a multitude of laboratory equipment, including four spectrometers, in three separate cases, exports that appear to have also violated the Joint Comprehensive Plan of Action (JCPOA). The total value of all the goods exported to Iran is 1.1 million euros. The defendant, Alexander J., is accused of violating the Foreign Trade Act (AWG) and Regulation (EU) No. 267/2012 of March 23, 2012, as amended in October 2015 in response to the establishment of a special Iranian procurement channel in the JCPOA, which places restrictive measures on certain Iranian entities and equipment for export (and related activities, such as brokering). In the first two cases, Alexander J. is alleged to have exported items to an Iranian national whose Iran-based companies were EU-sanctioned front companies procuring laboratory equipment for Iran’s nuclear and ballistic missile programs at the time. Alexander J. further supplied the sanctioned entity with two spectrometers listed in Annex II of this EU regulation, which lists items that are not on the EU dual-use control list (Regulation (EC) No 428/2009 of 5 May 2009) but that could contribute to sensitive activities, including enrichment-related activities, reprocessing or heavy-water-related activities. These items require a license on a case-by-case basis. In addition, Alexander J. violated the regulation by providing goods to an embargoed entity. In the third case, Alexander J. exported two listed spectrometers to a different, unspecified Iranian entity, also without the required license.

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Read the rest of the report from the Institute for Science and International Security.