Iran Watch Newsletter: October 2021

October 28, 2021

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This month's newsletter features an international enforcement action examining two recent prosecutions of Iranian efforts to illicitly procure mass spectrometers, machines that can be used for uranium enrichment as well as a range of non-nuclear activities. The two cases, one in Germany and the other in the United States, showcase the diverse methods Iran uses to acquire export controlled technology.

The newsletter also features profiles of three entities linked to Iran's military activities in Syria. Featured documents from the Iran Watch library include a policy speech by a U.S. Department of Justice official on corporate sanctions-compliance enforcement, Germany's imposition of penalties on the Hamburg branch of Iran's Bank Melli, and readouts of ongoing diplomatic activity related to Iran's nuclear program, as well as news about the International Atomic Energy Agency's increasing difficulty monitoring Iranian uranium enrichment.

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A thermal imaging mass spectrometer viewed from above

Enforcement Action | Mass Spectrometer Cases Illustrate Diversity of Iranian Procurement Efforts

As Iran ramps up uranium enrichment, authorities in multiple countries have uncovered efforts by Iranian agents to procure mass spectrometers from abroad. These dual-use machines can precisely measure the purity and molecular structure of radioactive material and also have a range of non-nuclear applications. One recent case involved two individuals with ties to Canada and Iran who allegedly transshipped U.S.-origin spectrometers to Iran via the United Arab Emirates (UAE). A second case involved a German-Iranian national who allegedly shipped spectrometers directly from Germany to Iranian companies that had been sanctioned by the European Union for supporting Iran's nuclear program.

These cases, both opened in 2021, involve alleged transactions dating from 2015-2016 and 2019, respectively. The timing indicates that Tehran may have continued to use illicit means to further its uranium enrichment program even though the 2015 Joint Comprehensive Plan of Action (JCPOA) provided a licit procurement channel for such acquisitions. The cases also suggest that Iran still relies on, or prefers, Western-origin technology for its nuclear program, and they provide two illustrative examples of the diverse sanctions evasion methods used to import items from Europe and North America into Iran.

Read the full enforcement action here.



Iran relies on key transportation and financial firms to facilitate its nuclear and missile programs and to support Tehran’s state-sponsored terror operation overseas. 

Mahan Air
An Iranian commercial airline; has provided assistance to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Lebanese Hizballah by transporting operatives, weapons, equipment, and funds to Syria, according to the U.S. Treasury Department; has provided travel services to IRGC-QF personnel flown to and from Iran and Syria for military training; has facilitated the covert travel of IRGC-QF members by bypassing security procedures; has received assistance from the Iran-based financial institution Bank Tejarat.
Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF)
A branch of the IRGC that supports terrorist organizations; provides financial and military support to militant and terrorist groups, including to Hezbollah and groups in Africa; officers have trafficked narcotics and use diplomatic, non-governmental, and humanitarian organizations as cover for operational activities; has provided support and equipment to the Syrian government to repress civilian movements; has cooperated with Yas Air (Pars Aviation Services Company), Mahan Air, and Iran Air, to reportedly supply the Syrian government with weapons and crowd control equipment; reportedly uses Syria as a hub to transfer weapons to Hezbollah in Lebanon, Hamas in Gaza, and Islamic Jihad in the West Bank.
Bank Tejarat
A large Iranian commercial bank that has directly facilitated Iran's nuclear efforts and supported the activities of entities involved in Iran's missile program; assisted designated Iranian banks in circumventing international sanctions, according to the European Union; in 2011, facilitated the movement of tens of millions of dollars to assist the Atomic Energy Organization of Iran (AEOI) in its effort to acquire yellowcake uranium; conducted business for front companies of Shahid Hemmat Industrial Group (SHIG); provided financial services to Bank Mellat and Export Development Bank of Iran (EDBI) that supported the activities of subsidiaries of the IRGC, Defense Industries Organization (DIO), and Ministry of Defense Armed Forces Logistics (MODAFL).



IAEA Director General Grossi listens to someone speaking out-of-frame

IAEA Chief Warns Iran Nuclear Surveillance Is No Longer Intact | Financial Times

October 19: International Atomic Energy Agency (IAEA) Director General Raphael Grossi said on October 18 that he has not been able to speak directly with Iran's Foreign Minister Hossein Amirabddollahian and that he needs to do so urgently. Meanwhile, Grossi said Iran's breakout time to having enough fissile material for a nuclear weapon is down to "a few months" and is becoming shorter as Iran employs more advanced centrifuges. He added that IAEA's monitoring system is "not intact" due to Iran's continued refusal to allow new cameras at a centrifuge manufacturing plant in Karaj. The plant was damaged in a June attack that Iran blames on Israel. (Image source: IAEA Imagebank via Wikimedia Commons)

Iran Makes More 20% Enriched Uranium Than Reported By IAEA | Associated Press

October 10: In September, the IAEA estimated that Iran's stockpile of 20% enriched uranium amounted to 84.3 kilograms. Iran's nuclear chief Mohammad Eslami told Iranian state media on October 9th that Iran actually possesses over 120 kilograms of the material. Eslami claimed that the additional production was necessary because other parties to the JCPOA have not delivered fuel for the Tehran Research Reactor as promised by the 2015 agreement.  
Norway Charges Professor With Violating Sanctions On Iran | Associated Press

September 29: Norwegian authorities have pressed charges against a professor for violating sanctions on Iran between 2018 and 2019. The professor invited four Iranian researchers to a university in Trondheim, where he gave them access to the "nano-mechanical lab", which can analyze metal alloys. One of the Iranian researchers allegedly installed software on a computer system that allowed him to continue to collect data without university credentials. Norwegian prosecutors said that the knowledge had the potential to be useful to Iran's nuclear program. The professor, a German-Iranian dual citizen, has left Norway but is willing to return for court proceedings, according to his attorney.  



While the monitoring dispute between Iran and the IAEA simmered, the United States, Iran, and other JCPOA participants held bilateral meetings and calls centered on the question of when--and under what conditions--nuclear negotiations would resume.

  • In an interview, Iranian President Ebrahim Raisi said Iran is serious about nuclear talks but the “other side” should lift sanctions to show its own seriousness - October 18
  • Deputy Director of the EU Action Service Enrique Mora met with his Iranian counterpart, Ali Bagheri, in Tehran to urge Iran to return to the negotiating table - October 14
  • Russian Foreign Minister Sergei Lavrov met with his Iranian counterpart, Hossein Amirabdollahian, in Moscow - October 6
  • Lavrov also had a phone call with U.S. Secretary of State Antony Blinken to discuss “mutual compliance” with the JCPOA by Iran and the United States - October 6

In the sanctions arena, the United States reversed its missile-related designations of two Iranian firms after they brought a lawsuit in U.S. court. A U.S. government spokesperson denied that the delistings were related to ongoing diplomatic efforts with Iran. Authorities in the United States and Europe pursued Iran-related regulatory activity in October.

  • Associate Deputy Attorney General John Carlin laid out an aggressive sanctions enforcement policy in a public speech - October 11
  • The U.S. Department of the Treasury delisted Mammut Industrial Group and Mammut Diesel a year after their initial designations for supporting Iran's missile program - October 8
  • The German financial regulator BaFin banned the Hamburg branch of Iran’s Bank Melli from issuing new loans after finding it to be violating accountability rules - October 8