EXPORTING SENSITIVE GOODS TO IRAN: ASSESSING THE JCPOA PROCUREMENT CHANNEL

On 29th March, the International Institute for Strategic Studies published a paper saying that under the 2015 nuclear deal with Iran, a new mechanism was set up to regulate any procurement made by Tehran for its now limited nuclear programme.  The research paper takes an in-depth look at the Procurement Channel, as it is known, examining its workings and effectiveness so far, and offers recommendations to policymakers to ensure its sustainability.  The mechanism covers 3 categories of goods, and associated assistance and services –

  • goods that are ‘especially designed or prepared for nuclear use’;
  • dual-use goods with both nuclear and civilian applications – controlling this category of goods is generally more difficult because it comprises items which, in addition to their more sensitive use, also have wide industrial and commercial applications and which have comprised the bulk of Iran’s procurement activities; and
  • any other items that are determined by the ‘relevant State’ as having the potential to ‘contribute to activities inconsistent with the JCPOA’ – this is akin to the catch-all provision in many national export-control regimes, the goal being to capture the less straightforward cases. These items typically have lower technical specifications than what would normally be used in a nuclear programme.  Iran’s procurers have often focused on this type of goods once export-control enforcement has made purchasing others much more difficult.

To export any of the items in question to Iran, a company needs to go through the established licensing process in its home country whilst also submitting documents required by the Procurement Channel.

https://www.iiss.org/en/iiss%20voices/blogsections/iiss-voices-2018-2623/march-b1b3/assessing-the-jcpoa-procurement-channel-3424

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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