The Procurement Channel of the Joint Comprehensive Plan of Action (JCPOA) is a potentially valuable transparency and verification tool aimed at controlling the export of goods to Iran’s authorized nuclear programs and non-nuclear, civil end users. Troubling problems emerged early on and weakening compromises and exemptions were made that called into question if the Procurement Channel could truly be an effective monitoring mechanism for Iran’s nuclear-related imports. A particular challenge to the viability of the channel is Iran’s on-going commitment to illicitly procuring sensitive goods for its missile and military programs, combined with a long history of illicit nuclear and nuclear-related procurements. Until the channel is better established, the United States should adopt a policy of a presumption of denial with regard to Iranian proposals to the channel, unless two conditions are met. The first condition is a determination that the parties seeking the goods do not have any involvement with Iran’s military industries or entities, particularly the Iran Revolutionary Guard Corps (IRGC), or companies linked to any of these entities. The second is rigorous, reliable, on the ground checks on the use of goods in Iran after they are imported, otherwise known as “end use checks.”

Moreover, the procedures of the Procurement Channel need reform within the context of the JCPOA, which should be pursued at the Joint Commission in order to repair some of the channel’s other deficiencies. Investing the appropriate time, attention, and resources is critical to ensuring that the Procurement Channel is successful at regulating exports of proliferation-sensitive goods to Iran. In the longer term, Iran should be pressed to create an internationally acceptable export control system, as it stated in the JCPOA it intends to do. However, this effort makes sense only if Iran commits not to undermine, or worse, make a mockery of, such an internationally acceptable export control regime by conducting illicit procurements for its own military programs. In addition, much more scrutiny is needed of any Iranian cooperation on missiles with North Korea and other pariah states, as well as investigating whether there is any nuclear cooperation between Iran and North Korea. A full list of proposed remedies and reforms is at the end of this report.

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Read the full report at the Institute for Science and International Security