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The House of Representatives approved two measures last week aimed at blocking Boeing from selling commercial aircraft to Iran. The vote comes a few weeks after Boeing announced a preliminary agreement to sell commercial aircraft to Iran Air, Iran's national carrier, in a deal worth an estimated $25 billion. Iran Air was removed from the U.S. sanctions blacklist in January as part of the nuclear deal. Critics of the proposed sale have cited Iran Air’s links to the Islamic Revolutionary Guard Corps and the Syrian regime and argued that the Boeing aircraft could be used to fly weapons into Syria and to support terrorism. But there is another troubling link that has gone unnoticed in the current debate: Iran Air’s suspected facilitation of ballistic missile cooperation between Iran and North Korea.
According to a 2011 report by an expert United Nations panel on North Korea, North Korea and Iran allegedly shared ballistic missile technology with the assistance of Iran Air: “Prohibited ballistic missile-related items are suspected to have been transferred between the Democratic People’s Republic of Korea and the Islamic Republic of Iran on regular scheduled flights of Air Koryo and Iran Air, with trans-shipment through a neighboring third country.” The unnamed third country that served as a trans-shipment point was reportedly China, which blocked the official release of the report. When the U.S. Treasury Department sanctioned Iran Air in 2011, it also cited the carrier's transport of missiles and military dual-use technology using passenger aircraft.
While it is unclear to what extent Iran Air is still supporting Iran's missile-related procurement, there is no evidence that its behavior has changed. In response to a question at a press briefing on June 23, State Department spokesperson John Kirby refused to confirm that Iran Air was removed from the U.S. blacklist because it was no longer involved in the activities for which it was sanctioned, including shipping weapons to Syria, or even that the United States was convinced it was no longer engaged in those activities. Instead, Mr. Kirby stated, “I’m not at liberty to go into the reasons behind the fact that it was removed from the SDN list. All I could tell you is that we wouldn’t have done that if we weren’t comfortable doing so.” Emanuele Ottolenghi, a senior fellow at the Foundation for Defense of Democracies, has noted that while Iran Air has mostly avoided the Iran-Syria route since the conclusion of the nuclear agreement in July 2015, there were three flights using Iran Air aircraft along known weapons routes to Syria last month.
The Iran-North Korea ballistic missile nexus, cited by the U.N. report in 2011, resurfaced in the first round of U.S. sanctions after the implementation of the nuclear agreement in January. The Treasury Department targeted five Iranian officials affiliated with the Ministry of Defense of Armed Forces Logistics (MODAFL), which coordinates Iran’s ballistic missile program, and two MODAFL subsidiaries: the Aerospace Industries Organization (AIO), which oversees missile production; and the Shahid Hemmat Industrial Group (SHIG), which is responsible for liquid-fueled missiles.
According to Treasury, SHIG missile technicians and MODAFL officials have traveled to North Korea over the past several years to work on an 80-ton rocket booster being developed by the North Korean government. This technology would help both countries extend the range of their missiles. SHIG also coordinates shipments of missile-related goods to Iran from the Korea Mining Development Trading Corporation (KOMID), North Korea’s primary exporter of ballistic missile-related equipment that has been sanctioned by the United Nations, United States, and European Union. These goods include valves, electronics, and measuring equipment that can be used in tests of liquid-fueled ballistic missiles and space launch vehicles.
These designations, along with a spate of recent tests, confirm that Iran's ballistic missile program has not slowed, despite the nuclear agreement struck in July 2015. They also confirm that Iran still relies on illicit procurement networks to fuel its missile progress. A June report from Germany’s domestic intelligence service found that Iran's “illegal proliferation-sensitive procurement activities in Germany […] persisted in 2015 at what is, even by international standards, a quantitatively high level.” The report also noted “a further increase in the already considerable procurement efforts in connection with Iran’s ambitious missile technology program.” Another recent intelligence report, by Germany's state of North Rhine-Westphalia, cited nearly 150 WMD-related procurement attempts in that state in 2015, about two-thirds of which were by Iran. Two German intelligence officials interviewed by the Wall Street Journal about these reports said that such illegal procurement efforts by Iran have continued in 2016, though at a slower pace.
Iran Air, therefore, offers a troubling case. It has been linked by the United Nations to the facilitation of missile-related cooperation between Iran and North Korea—activity that led to the first new U.S. sanctions against Iran after the nuclear agreement was implemented this year. The U.S. government has not explained publicly why Iran Air was removed from the U.S. blacklist or explicitly stated that Iran Air is no longer engaged in the activity for which it was originally sanctioned. Meanwhile, Iran has resumed its ballistic missile tests and, as the German intelligence services report, continues to seek sensitive missile-related technology overseas, in violation of U.N. Security Council resolutions. Given that Iran’s commitment to ballistic missile development is unchanged, even if the Boeing aircraft to be sold to Iran Air are intended for civil aviation purposes, there is no guarantee that these aircraft would not end up supporting Iran’s missile program or other malign activities.
 “Report of the Panel of Experts established pursuant to resolution 1874 (2009),” United Nations Security Council, May 2011, p. 40, unpublished (via Iran Watch): http://www.iranwatch.org/library/multilateral-organizations/united-nations/un-security-council/report-panel-experts-established-pursuant-resolution-1874-2009.
 Tania Branigan, “China Denies Role in North Korea-Iran Missile Trade,” Guardian (U.K.), May 18, 2011, https://www.theguardian.com/world/2011/may/18/china-denies-role-north-korea-iran-missile-trade.
 “Fact Sheet: Treasury Sanctions Major Iranian Commercial Entities,” U.S. Department of the Treasury, June 23, 2011 (via Iran Watch): http://www.iranwatch.org/library/governments/united-states/executive-branch/department-treasury/fact-sheet-treasury-sanctions-major-iranian-commercial-entities.
 Daily Press Briefing, U.S. Department of State, June 23, 2016 (via Iran Watch): http://www.iranwatch.org/library/governments/united-states/executive-branch/department-state/state-department-spokesman-john-kirby-comments-boeing-sale-iran
 Emanuele Ottolenghi, “The Risks of the Iran-Boeing Deal,” The Hill, June 21, 2016, http://thehill.com/blogs/pundits-blog/international/284269-the-risks-of-the-iran-boeing-deal
 “Treasury Sanctions Those Involved in Ballistic Missile Procurement for Iran,” U.S. Department of the Treasury, January 17, 2016 (via Iran Watch): http://www.iranwatch.org/library/governments/united-states/executive-branch/department-treasury/treasury-sanctions-those-involved-ballistic-missile-procurement-iran
 Federal Ministry of the Interior, 2015 Annual Report on the Protection of the Constitution, June 2016, p. 30, https://www.verfassungsschutz.de/en/public-relations/publications/annual-reports/annual-report-2015-summary.
 Verfassungsschutzbericht des Landes Nordrhein-Westfalen über das Jahr 2015, July 4, 2016, pp. 214-217, https://www.mik.nrw.de/nc/publikationen/produktauswahl.html?tt_products%5Bcat%5D=11.
 Anton Troianovski and Jay Solomon, “Germany Says Iran Kept Trying to Get Nuclear Equipment After Deal,” Wall Street Journal, July 8, 2016, https://www.wsj.com/articles/germany-says-iran-kept-trying-to-get-nuclear-equipment-after-deal-1468006075.