Oval Office, Official White House (Photo by Pete Souza).

July 21, 2009

U.S. Policy Toward Iran's Nuclear Program

President Obama’s public statements indicate that he remains committed to pursuing a tactical engagement policy towards Iran in the near-term while reserving the potential for increased sanctions over Tehran’s nuclear program in the coming year. The Obama administration maintains U.S. policies toward Iran that it inherited from previous administrations, including a series of financial and weapons proliferation-related sanctions, cooperative nonproliferation programs, and regional partnerships. Deviating from his predecessor, however, Obama may engage Iran in bilateral talks, and has identified a September 2009 timeline for assessing the effectiveness of an engagement policy. Here, IranTracker provides an overview of U.S. policy towards Iran’s nuclear program under the Obama, Bush, and previous administrations.

I. Expressed Policy

II. Sanctions & Legal Tools

III. Nonproliferation Regimes

IV. Military & Security Measures

V. Diplomacy & Regional Initiatives


Expressed Policy

Iran presents a range of issues for U.S. policy: the sponsorship of terrorism, regional stability, human rights, influence in the Arab-Israeli peace process, and expressed hostility toward American allies, among others. Ultimately, nuclear proliferation remains the primary concern for U.S. foreign policy towards Iran. In particular, the basis for concern regarding Iranian nuclear proliferation stems from Iran’s violation of its Nuclear Nonproliferation Treaty (NPT) obligations and refusal to provide objectives guarantees that it will use its nuclear program strictly for peaceful, civilian purposes.[1]

Obama Administration

Since taking office, President Barack Obama’s administration has reiterated a willingness to engage Iran in a direct dialogue through high-level contact, while offering limited detail on a broader strategy for U.S. policy towards Iran. As of July 2009, the precise outline and substance of a diplomatic initiative remains unclear, with direct U.S.-Iran contact limited to a brief exchange between U.S. Special Representative Richard Holbrooke and Iran’s deputy foreign minister, Mehdi Akhundzadeh, at an international conference focused on Afghanistan.[2] Secretary of State Hillary Clinton noted that the two officials did not discuss substantive issues, but that the U.S. delivered a letter to the Iranian delegation, calling on Iran to locate a U.S. citizen missing in Iran, release an American journalist currently imprisoned in Iran, and lift travel restrictions for an American student recently detained in Iran.[3] The Obama administration has limited its public discussion of the substance of potential engagement with Iran and instead referred to a general reconciliation process, aimed primarily at deterring Iran’s development of a nuclear weapon, which will be carried out through multilateral and bilateral talks. 

President Obama has referred to engagement with Iran on multiple occasions since taking office. Following June’s disputed Iranian presidential elections that sparked an uprising in Iran and a violent government crackdown on protestors, President Obama maintained the position that the U.S. would pursue engagement with Iran, primarily through multilateral discussions.[4] Although the president avoided direct condemnation of events in Iran in the immediate aftermath of the election, he stated on June 23 that, “The United States and the international community have been appalled and outraged by the threats, the beatings and imprisonments of the last few days [in Iran]. I strongly condemn these unjust actions…”[5]

The administration’s continued pursuit of a policy involving engagement with Iran, after the mid-June presidential elections, follows a pattern of statements President Obama has made since taking office. In a speech delivered in Egypt on June 4, 2009, President Obama stated that there “will be many issues to discuss between our two countries, and we are willing to move forward without preconditions on the basis of mutual respect.”[6] On March 20, 2009, President Obama addressed the people and leaders of Iran in a videotaped message. In his statement, the president signaled that engagement with Iran would “[address] the full range of issues” and encouraged Iran to “take its rightful place in the community of nations” through “peaceful actions” and not “through terror or arms.”[7] In similar remarks made during a January 2009 interview, President Obama stressed that, in spite of Iran’s threats toward Israel, pursuit of a nuclear weapon, and support for terrorist organizations, it is “important for us to be willing to talk to Iran, to express very clearly where our differences are” and identify “potential avenues for progress.”[8]  

On May 24, Chairman of the Joint Chiefs of Staff (CJCS), Admiral Michael Mullen, reiterated that “Iran’s strategic objective is to achieve nuclear weapons,” and that the Iranian leadership remains committed to that path.[9] To this end, President Obama has noted that his administration is “engaged in a process to reach out to Iran and persuade them that it is not in their interest” to pursue the path towards a nuclear weapon.”[10] Although the administration has expressed general concern with Iran’s nuclear program, it has not taken a concrete position on the uranium enrichment portion of the program.  Media reports in the New York Times and other outlets indicate that American officials are considering dropping a precondition that Iran suspend its uranium enrichment activities before negotiations can begin.[11] Other reports highlight administration efforts to incentivize Iran to relinquish its enrichment activities, in some cases temporarily. The P5+1 group, which includes the U.S., reportedly resubmitted a 2006 proposal which would grant Iran diplomatic and economic incentives in exchange for a suspension of uranium enrichment and a temporary “freeze-for-freeze” offer whereby Iran ceases enrichment and the U.N. suspends sanctions as an interlude to negotiations.[12]

More generally, President Obama has indicated a willingness to acknowledge Iran’s right to access nuclear technology within the scope of Iran’s treaty obligations. In June, President Obama proclaimed that Iran “should have the right to access peaceful nuclear power if it complies with its responsibilities under the nuclear Non-Proliferation Treaty.”[13] When asked whether Iran’s monitored nuclear reprocessing should be accepted, the president stated, “Without going into specifics, what I do believe is that Iran has legitimate energy concerns, legitimate aspirations. On the other hand, the international community has a very real interest in preventing a nuclear arms race in the region.[14] The IAEA reported in June that Iran continues its uranium enrichment activities, increasing the potential for a nuclear weapons capability that could trigger such an arms race.[15] This significant timing consideration poses an immediate challenge for the administration’s tactical approach.  

President Obama has said that while he will avoid setting a deadline for engagement, the administration is “…not going to have talks forever. We’re not going to create a situation in which talks become an excuse for inaction while Iran proceeds with developing a nuclear -- and deploying a nuclear weapon.”[16] Assuming that the engagement process between the U.S. and Iran would commence shortly after Iran’s presidential elections, President Obama initially stated that, by the end of 2009, “…we should have a fairly good sense…as to whether [talks] are moving in the right direction and whether the parties involved are making progress and that there’s a good faith effort to resolve differences.”[17]

The U.S. reasserted a deadline for assessing talks with Iran in a joint G8 statement following a summit attended by President Obama in July. The statement indicated indicated that engagement with Iran would be assessed at the United Nations General Assembly meeting in September.[18] Several days later, President Obama stated that the U.S. and other nations would “take stock of Iran’s progress…this September at the G20 meeting [in Pittsburgh].”[19] President Obama has indicated that the channel for engagement would initially involve the five permanent members of the UN Security Council and Germany (known as the Permanent Five Plus One, or P5+1), with the additional possibility of bilateral talks occurring between the U.S. and Iran.[20] 

Beyond rhetoric on engagement, enrichment, and timelines, President Obama has explicitly referred to “a range of steps” his administration is considering, including “stronger international sanctions” against Iran.[21] Secretary of State Hillary Clinton referred to increased sanctions, noting during an April congressional hearing that the administration was “laying the groundwork for the kind of very tough...crippling sanctions that might be necessary in the event that our offers [of engagement with Iran] are either rejected or the process is inconclusive or unsuccessful.”[22] 

Statements from other administration officials reiterate that that the administration reserves the right to utilize all policy tools against Iran. Pentagon Press Secretary Geoff Morrell stated on May 19 that the U.S. “has been consistent about one thing, that no options are off the table. However, it is clearly the preference of this president and this secretary of Defense to reach out and try to engage Iran, and try to diplomatically and economically persuade them not to pursue their nuclear weapons program.”[23] In July, Admiral Mullen referred more explicitly to the potential of military action against Iran, stating that the U.S. should pursue engagement with Iran “…with all options remaining on the table, including, certainly, the military options.”[24] Beyond these reiterations of a policy of tactical engagement, the substance of the current administration’s strategy towards Iran has yet to materialize. A review of U.S. policy inherited from the previous administration follows. 

Bush Administration

Just two weeks before leaving office in 2009, outgoing National Security Advisor Stephen Hadley identified Iran as the biggest U.S. foreign policy challenge that the next administration will confront in the Middle East.[25] The Bush administration made ending Iran’s enriched uranium production a policy priority.[26]  They put forward inducements and disincentives in order to encourage Iran to suspend uranium enrichment and commit to a fully accountable civilian nuclear program, verifiable through the International Atomic Energy Agency (IAEA). Up until its last days, the Bush administration maintained that it preferred a diplomatic approach to altering Iran’s behavior, but that “President Bush never took any of his options [regarding Iran’s nuclear program] off the table.”[27] 

The Bush administration primarily cooperated with the P5+1 group, which consists of the U.K., France, Germany, Russia and China, to implement U.S. policy regarding Iran’s nuclear program. In June 2008, the Bush administration signed onto a P5+1 letter offering Iran trade relations, support for World Trade Organization (WTO) membership, the prospect for opening diplomatic relations, and support for a civilian nuclear program, among other incentives, in exchange for an end to uranium enrichment.[28] At a July 2008 P5+1 meeting with Iranian officials in Geneva, U.S. Undersecretary of State William Burns reiterated the Bush administration’s position that Iran’s suspension of uranium enrichment must precede negotiations with Iran.[29] The Obama administration has since dropped preconditions to negotiations with Iran. The official U.S. position on the future of Iran’s enrichment activity, however, remains unclear.

Sanctions & Legal Tools

The broad U.S. sanctions program in place against Iran includes: an investment and trade ban; targeted financial measures designed to limit Iranian access to U.S. and international financial systems; proliferation sanctions covering dual-use items, technology, and equipment that have civilian or military uses; and terrorism and foreign aid sanctions. Acting Assistant Treasury Secretary for Terrorist Financing Daniel Glaser described the intent of the various sanctions:

“…the trade and investment ban is aimed at making it more difficult for Iran to procure U.S. goods, services, and technology, including those that could be used for terrorism or proliferation…as with all U.S. economic sanctions programs, the premise of the sanctions is to exact a price on the sanctioned entity, which serves as an inducement to change the behavior that threatens U.S. national security and foreign policy goals. Sanctions also serve to make it more difficult for a sanctioned entity to pursue its threatening conduct.”[30]

The U.S. treasury serves as a primary department for implementing economic sanctions—including those related to Iran’s nuclear and weapons programs. Shutting down funding, and procurement of materiel for Iran’s nuclear and weapons program remains a significant challenge for the Treasury Department. Iran possesses expansive global financial links, employs deceptive financial practices devised to mask transactions related to nuclear and missile programs, and is involved in money laundering and illegal financial schemes.[31]

Treasury’s “three-pronged strategy” to mitigate these challenges incorporates sanctions targeting Iranian individuals, entities, and government branches, the enlistment of international allies in denying Iran access to the global financial system, and cooperative engagement with the global private sector to limit transactions with Iranian financial institutions. [32] The U.S. designed the latter two strategies to augment unilateral U.S. measures already in place.[33]

U.S. policy toward Iran’s nuclear program employs various legal mechanisms crafted to compel Iran to honor its nonproliferation obligations and allow for an independent verification of its nuclear program objectives.   In particular, the U.S. supports binding UNSC sanctions resolutions based on IAEA reporting and a U.S. sanctions program against Iran founded on nonproliferation and antiterrorism laws initiated by the president and by Congress.

United Nations Security Council Resolutions

Between 2006 and 2008, the UNSC passed five resolutions—four of which were Chapter Seven resolutions invoking the UNSC’s binding authority to maintain and restore international peace and security—imposing limited sanctions on Iran (see Figure 1).[34] The sanctions attempt to: ban weapons of mass destruction (WMD)-related trade; freeze the assets of individuals and entities associated with Iran’s nuclear program and related industries; prevent Iran from exporting arms; ban or require transparency on international travel by Iranians; call for inspections on select Iranian sea and air cargo shipments; and restrict activities with some Iranian banks.[35]

Figure 1[36]









July 31, 2006

14 in favor, 1 against (Qatar)

Iran must verifiably suspend enrichment-related and reprocessing activities.


December 23, 2006

15 in favor

Iran must verifiably suspend enrichment-related and reprocessing activities; prohibit sales to Iran of technology useful for enrichment or reprocessing activities; member states must freeze assets of identified firms and persons.


March 24, 2007

15 in favor

Iran must verifiably suspend enrichment-related and reprocessing activities; ban on arms transfers by Iran; required member states to report travel by sanctioned Iranians.


March 3, 2008

14 in favor, 1 abstention (Indonesia)

Iran must verifiably suspend enrichment-related and reprocessing activities; the resolution also authorizes cargo inspections for two Iranian firms, bans the sale of dual-use items, imposes a travel ban on certain individuals, and encourages a ban on financial transactions with identified banks.


September 27, 2008

15 in favor

Reaffirms resolutions 1696, 1737, 1747 and 1803.

* Chapter VII charter resolutions

The UNSC first passed a resolution responding to Iran’s nuclear program in July of 2006.  Resolution 1696 set an August 31, 2006 deadline for Iran’s complete and unconditional compliance with IAEA requirements for the suspension of enrichment-related and reprocessing activities.[37] The measure also encouraged UN members to prevent transfers related to Iran’s nuclear and missile programs.[38] Iran’s noncompliance with 1696 forced the UNSC to pass Resolution 1737.

Resolution 1737 demanded that Iran suspend its enrichment and reprocessing activities by February of 2007 and sanctioned economic activity supporting Iran’s nuclear and weapon programs.[39] The resolution prohibited the sale or financing of technology that had the potential to further Iran’s enrichment or heavy-water reprocessing activities, nuclear weapons development, or ballistic missile program; required UN members to freeze financial assets of designated entities and individuals, including Iranian nuclear industry organizations and officials; called on states to provide notification of travel undertaken by designated Iranian nuclear industry officials and exercise restraint in allowing those individuals to enter their country; and provided a de facto exemption to permit Russian assistance in the construction of Iran’s Bushehr reactor.[40] According to then Under Secretary of State for Political Affairs R. Nicholas Burns, the U.S. deemed the provision freezing individuals’ assets to be the most important aspect of the resolution.[41] 

Following an IAEA report confirming Iran’s unabated enrichment activities and noncompliance with standing resolutions, the UNSC adopted Resolution 1747 in March 2007.  The resolution set a date for the suspension of enrichment – May 2007 – and provided for the following: sanctions on individuals and organizations involved in nuclear and missile programs; ban on arms transfers; reporting requirements for travel by sanctioned Iranian individuals; a call for countries to avoid selling arms or dual-use items to Iran; and the exercise of restraint in financial dealings with Iran.[42]  Key Islamic Revolutionary Guard Corps (IRGC) individuals identified in Resolution 1747 include Deputy IRGC Commander Morteza Rezai and Qods Force Commander Qassem Soleimani.[43]

Following the passage of Resolution 1747, Iran agreed to clarify outstanding issues with the IAEA. However, then U.S. Ambassador to the IAEA, Gregory Schulte, underlined the eventual lack of cooperation by citing Iran’s failure to provide enough information on advanced centrifuge designs, intentions to construct or modify nuclear facilities, and the sources for Iran’s centrifuge technology.[44] Iran’s continued noncompliance led to the passage of Resolution 1803, the fourth legally binding Chapter Seven sanctions resolution. It required Iran to suspend enrichment-related, reprocessing and heavy water-related activities, including the construction of a production plant and reactor in Arak.[45] 

Resolution 1803 includes provisions on travel restrictions, financial measures, and oversight of technology transfers. On travel restrictions, the resolution expands and modifies the list of targeted individuals. With regard to financial measures, the resolution also expands the list of individuals and organizations subject to asset freezes, calls upon nations to show restraint in issuing export credits, guarantees, or insurance in trade with Iran that may support nuclear proliferation and weapons programs, and urges nations to maintain oversight of the activities of financial institutions that may assist Iranian banks supporting nuclear and weapons programs. In the area of technology transfers, the resolution attempts to strengthen a ban on the transfer of items with a potential weapons or proliferation use and urges nations to inspect aircraft and cargo ships suspected of transporting sanctioned items.[46]  

Iran’s noncompliance with 1803 resulted in the UNSC’s adoption of Resolution 1835. Russia and China’s resistance to additional sanctions, however, kept the UNSC from passing substantive measures in the resolution.[47] Resolution 1835 instead reaffirmed the four previous Chapter Seven resolutions and committed to negotiating concerns regarding Iran’s nuclear pursuits.[48]

Independent of the resolutions pursued through the UNSC, the U.S. has implemented a sanctions program that attempts to eliminate the exposure of U.S. individuals and businesses to Iranian firms and curb support for Iran’s nuclear and weapons programs. The U.S. implements sanctions against Iran using a legal framework of executive orders and laws, with a focus on prohibiting general trade with Iran and denying Iran access to financing and resources for its nuclear and weapons programs (see Figure 2).[49]

Executive Orders

Figure 2[50]




EO 13382

June 28, 2005

Freezes assets of persons engaged in proliferation of WMD and members of their support networks

EO 13224

September 23, 2001

Freezes assets of persons who commit, threaten to commit, or support terrorism

EO 13059

August 19, 1997

Consolidates prior EOs and prohibits U.S. persons from virtually all trade and investment activities with Iran

EO 12959

May 6, 1995

Bans certain exports and investment in Iran

EO 12957

March 15, 1995

Prohibits U.S. participation in Iran’s petroleum development

EO 12938

November 14, 1994

Declares a national emergency to counter threat of WMD and delivery systems

EO 12613

October 29, 1987

Bans import of Iranian goods and services


Executive Order 13382

On June 28, 2005, President George W. Bush issued Executive Order (EO) 13382—“Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters.”[51] EO 13382 authorizes relevant U.S. government agencies, primarily the Departments of State and Treasury, to identify individuals and businesses supporting WMD proliferation. The EO then charged the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) with administering a sanctions program prohibiting U.S. firms and individuals from conducting business with the identified parties and their support networks in an effort to deny the parties “access to the U.S. financial and commercial systems.”[52]

EO 13382 also requires banks and other institutions to freeze any assets owned by designated individuals under U.S. jurisdiction. The original order designated several Iranian firms and organizations as WMD proliferators, including the Aerospace Industries Organization, the Shahid Hemmat Industrial Group, and the Shahid Bakeri Industrial Group.[53] Since its inception in 2005, EO 13382 has targeted Iranian firms and individuals in order to deny Iran “access to the materials and services” supporting its nuclear ambitions.”[54] The U.S. had designated over ninety Iranian organizations and individuals as WMD proliferation supporters under EO 13382 as of November 2008.[55]

Throughout 2007, the Departments of State and Treasury exercised their authority under EO 13382 to identify significant supporters of Iran’s weapons programs. In January, the Treasury Department sanctioned the fifth-largest state-owned Iranian bank, Bank Sepah, for funding Iran’s purchases of missile technology and equipment.[56] In October, the State Department sanctioned the Islamic Revolutionary Guard Corps (IRGC) for its support of ballistic missile programs, including development and testing of the Shahab-3, “which could be modified to deliver WMD.”[57] Two more recent examples of EO 13382’s use illustrate the challenges posed by the deceptive nature of the complex relationships within the networks supporting Iran’s proliferators.

In April 2009, the Treasury Department designated six Iranian companies under EO 13382 based on their relationships with Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) or Iran’s Defense Industries Organization (DIO). Both groups, designated previously under EO 13382, contribute significantly to Iran’s nuclear and missile programs. According to Treasury, the six companies acted for, on behalf of, or as subordinates to MODAFL and DIO.[58] In March 2009, U.S. authorities arrested an Iranian businessman who had been purchasing helicopter engines and visual equipment for fighter bombers from American companies and exporting them through several international companies—including a trading company in Ireland and a book publisher in Malaysia—to a firm in Iran controlled by the EO 13382-designated MODAFL.[59]   

Despite its unilateral authority, EO 13382 has served as a model for complementary responses from the international private sector. As former U.S. Treasury assistant secretary Matthew Levitt noted in 2007, “major international financial institutions typically incorporate U.S. Treasury designation lists into their due-diligence databases,” making it more difficult for proliferation supporters to access the international financial system.[60] Beginning in 2006, Treasury Undersecretary for Terrorism and Financial Intelligence Stuart Levey elicited cooperation from the international community by approaching the private sector directly. As Robin Wright explained in November 2008: 

“Levey’s pitch was simple: Banks were only as reputable as their clients’ practices. And the reputations of banks that did business with Iran were at risk as long as Iran financed extremists and pursued missile and nuclear technology. More basically, he argued, Iran had bad banking habits, with little oversight to prevent money laundering…Levey’s idea was to press banks not to do business with Iran until it complied with international standards.”[61] 

A trio of Iranian banks – Sepah, Saderat, and Melli, which together service more than three quarters of Iran’s international trading transactions – lost customers and found it difficult to attract new business; over eighty banks in Europe, the Middle East, and Asia pared back their business with Iran.[62] Yet, a fragmented response diminished the net effect of these measures in isolating Iran. As Michael Jacobson notes, the retreat of high-profile banks doing business with Iran – driven by reputational concerns and their relationship with the U.S. financial system – created an opportunity for less risk-averse and less reputation-sensitive “second-tier entities” to fill the void.[63]  

Executive Order 13224

EO 13224, signed on September 23, 2001, aims to “disrupt the financial support network for terrorists and terrorist organizations by authorizing the U.S. government to designate and block the assets” of foreign individuals, businesses, or organizations that commit, pose a significant risk to commit, or support terrorist activities.[64] The U.S. Treasury designated Iran’s IRGC Qods Force under EO 13224 in 2007 for its material support of Hezbollah, the Taliban in Afghanistan, and Shi’i militants in Iraq.[65]

Executive Order 13059

EO 13059, enacted in August 1997, consolidated three prior Iran trade-related executive orders (12613, 12957, 12959) by banning “virtually all trade and investment activities” between U.S. persons and Iran.[66] The order prohibits various types of transactions with by U.S. persons, including “purchasing, selling, transporting, swapping, brokering, approving, financing, facilitating, or guaranteeing.”[67]

Executive Order 12938 

EO 12938 declared a national emergency in 1994 to confront the “unusual and extraordinary threat to the national security, foreign policy, and economy of the United States” posed by the proliferation of WMD and the weapons used to deliver them.[68] EO 12938 “provides that the Secretary of Treasury shall prohibit the importation into the U.S. of goods, technology, or services produced or provided by foreign persons on which the Secretary of State has determined to impose an import ban because of their WMD proliferation activities.”[69] 


Figure 3[70]





Iran Freedom Support Act

September 30, 2006

Penalizes persons or firms aiding Iran’s WMD and weapons programs

Iran, North Korea, and Syria Nonproliferation Act

March 14, 2000

Penalizes nations whose firms aid Iran’s attempts to acquire WMD and weapon delivery systems

Nuclear Proliferation Prevention Act

April 30, 1994

Strengthens penalties against violators of nuclear nonproliferation safeguards

Iran-Iraq Arms Nonproliferation Act of 1992

October 23, 1992

Imposes sanctions on persons or nations aiding Iran in acquiring WMD and specific conventional weapons

Soviet Nuclear Threat Reduction Act/ Nunn-Lugar Amendment

November 27, 1991

Secures post-Soviet nuclear weapons and related nuclear material, equipment and expertise

Missile Technology Control Act

November 5, 1990

Penalizes export of items banned by Missile Technology Control Regime

Export Administration Act

September 30, 1979

*expired in 1989

Authorizes executive branch to link export regulations with nonproliferation

Nuclear Nonproliferation Act

March 10, 1978

Incorporates nonproliferation safeguard obligations for foreign countries importing U.S. nuclear technology

Arms Export Control Act

January 25, 1974

Links potential military-related U.S. exports with nonproliferation standards

Atomic Energy Act

August 30, 1954

Establishes export controls for U.S. nuclear technology

Export-Import Bank Act

July 31, 1945

Authorizes Export-Import Bank to deny financing for violators of proliferation safeguards


Iran Freedom Support Act (IFSA)

The September 2006 Iran Freedom Support Act (IFSA) reinforces U.S. sanctions on Iran previously imposed under the aegis of executive orders 12957, 12959, and 13059. Further, IFSA grants the president authority to end these sanctions “upon congressional notification,” except in cases involving extenuating circumstances.[71] IFSA also declared that U.S. policy supports “efforts by the Iranian people to exercise self-determination over their country’s form of government” and “independent human rights and peaceful pro-democracy forces in Iran.”[72] Further, though not legally binding, a section of the act expressed that the U.S. should not sign agreements with countries that assist Iran’s nuclear and weapons programs unless those countries systematically cease nuclear and weapons assistance to Iran or Iran ends its enrichment and reprocessing activities (except in the case of exporting enriched uranium to “foreign nuclear fuel production facilities” under international agreements).[73]

Iran, North Korea, and Syria Nonproliferation Act (INKSA)

The Iran, North Korea, and Syria Nonproliferation Act of 2006 (INKSA) penalizes foreign persons, businesses, organizations, and governments for transferring export control-designated equipment and technology to Iran. Additionally, INKSA authorizes sanctions for the transfer of equipment and technologies that can materially contribute to the proliferation of WMD and missile systems.[74]

Officials from the U.S. Department of State conduct bi-annual analyses, assessing 60,000 intelligence reports in order to identify cases to recommend for interagency review.[75] The interagency review meetings, chaired by the NSC, include input from the Departments of Defense, Energy, Treasury, and other agencies. Ultimately, the State Department’s Verification, Compliance, and Implementation (VCI) Bureau informs Congress of sanction targets, and their activities, before publishing the names of parties in the Federal Register.

The U.S. sanctioned over one hundred parties in Iran-related cases under the INKSA; primarily from China, and secondarily from North Korea, Syria, and Russia.[76] In some cases, State has withheld sanctioning certain parties: when a foreign government has already punished or prosecuted offenders, or when department officials deem that the imposition of sanctions may “compromise the intelligence ‘sources and methods’ used to collect information on a particular proliferation case.”[77]  

Iran Sanctions Act 

The Iran Sanctions Act of 1996 attempts to bolster efforts to deny Iran access to resources that could support its nuclear program and support for terrorism.[78] Specifically, the act charges the president to impose sanctions—including the denial of export credits and U.S. bank loans—on foreign persons or businesses investing in Iran’s energy industries and transferring WMD technology or “destabilizing numbers and types” of advanced conventional weapons to Iran.[79]

Nuclear Proliferation Prevention Act (NPPA) 

The Nuclear Proliferation Prevention Act of 1994, also known as the Glenn Amendment, stiffened penalties against individuals assisting in the acquisition of nuclear weapons and on non-nuclear-weapon countries acquiring or exploding nuclear devices.[80] Only waiver authority granted to the president through congressional action can revoke sanctions enacted under the Glenn Amendment.[81]

Iran-Iraq Arms Nonproliferation Act

The Iran-Iraq Arms Nonproliferation Act of 1992 (IIANA) calls for the president to initiate sanctions against persons or governments “knowingly and materially” bolstering Iran or Iraq’s capability to acquire WMD or “destabilizing numbers and types of certain” advanced conventional weapons.[82] Also known as the Gore-McCain Act, the law initially arose from concerns over Russia’s exports of advanced conventional weapons to Iran.[83] Congress amended the IIANA in 1996 to allow for sanctions against arms suppliers for states designated as sponsors of terrorism, including Iran.[84] In 1997, Chinese transfers of C-802 cruise missiles to Iran became the subject of debate in the context of the Gore-McCain Act. At the time, the Clinton administration chose not to sanction any parties based on those transfers because “the known transfers (of C-802s) are not of a destabilizing number and type.”[85]

Soviet Nuclear Threat Reduction Act 

Congress enacted the Soviet Nuclear Threat Reduction Act, or Nunn-Lugar Amendment, of 1991 to support and fund the dismantling and safeguarding of the former Soviet Union’s WMD and related system stockpiles.[86] The initiatives under Nunn-Lugar began with concerns over unsecured nuclear weapons in the former Soviet Union and developed into programs for managing the “proliferation risks associated with weak political control” over nuclear materials, equipment, and expertise, as well as other WMDs and missiles.[87] In 2003, Congress broadened the Nunn-Lugar Amendment to address proliferation concerns beyond the former Soviet Union.[88] 

Missile Technology Control Act 

The Missile Technology Control Act of 1990 added provisions to the Arms Export Control Act that allowed the president to sanction persons exporting equipment and technology designated on the Missile Technology Control Regime (MTCR) list.[89] 

Nuclear Nonproliferation Act

The Nuclear Nonproliferation Act of 1978 (NNPA) intended to curb the spread of nuclear weapons by controlling the export of U.S. nuclear technology and bolstering international safeguards against the proliferation of nuclear weapons.[90] The NNPA established the de facto criteria for countries seeking U.S. nuclear technology and fuel by requiring “full-scope safeguards on their entire nuclear program.”[91]

Arms Export Control Act 

The Arms Export Control Act (AECA) of 1976 “authorizes U.S. government military sales, loans, leases, financing, and licensing of commercial arms sales” to foreign nations, taking into consideration U.S. foreign and nonproliferation policies.[92] The act ensures that the U.S. does not transfer arms to nations violating nonproliferation obligations and safeguards.

Atomic Energy Act

The Atomic Energy Act of 1954 declares that the development, use and control of atomic energy must be reconciled with the mission of maximizing “contribution to…common defense and security,” and should be directed to further peace, prosperity, and strengthen free markets.[93] 

Export-Import Bank Act

The Export-Import Bank Act of 1945 (EIBA) established the U.S. Export-Import Bank to facilitate trade between the U.S. and foreign nations. In 1978, Congress added provisions to the act authorizing the Bank to deny financing to persons or nations violating nuclear safeguards agreements, nuclear agreements with the U.S., or policies established to deter non-nuclear weapon states from acquiring nuclear devices or sensitive nuclear material.[94]

Nonproliferation Regimes

Proliferation Security Initiative

The Proliferation Security Initiative (PSI) is a voluntary program launched by the Bush administration in 2003 to inhibit the global trafficking of WMD, delivery systems and related materials.[95] In April 2009, President Obama signaled support for the PSI’s activities and called for building the PSI into a “durable international institution.”[96] The initiative, supported by over ninety countries, operates within relevant existing national and international legal frameworks, encouraging member states to deny proliferators free movement of WMD related equipment through interdiction, the sharing of information, and a commitment to bolster domestic legal authorities.[97] PSI lacks a “formal support structure, secretariat, headquarters or chairperson,” instead relying on voluntary commitments from individual states to cooperate with interdiction efforts through relevant legal authorities.[98]

PSI relies on a “broken tail-light scenario” whereby national officials explore all potential options to interdict the transportation of WMD and related items—seizing cargos in their own ports, for example, when the carriers violate national laws.[99] PSI supporters conduct multilateral exercises in order to enhance cooperation and practice interdiction measures. In October 2006, the PSI held its first training exercise in the Arabian Gulf with an intelligence-sharing war game, followed by a live maritime exercise to uncover a hidden nuclear detonator aboard an oil tanker; participating countries included the U.K., Australia, France, Italy and Bahrain.[100]

While a scenario involving a nuclear detonator provides a clear case for interdiction, the PSI encounters challenges when WMD-related cargo material and equipment possess legal, dual-use applications. In these instances, “establishing a shipment’s illegality can be difficult,” and dependent on real-time intelligence and data to judge the applicability of domestic laws and other regulations.[101]

According to the U.S. Department of State, the PSI has demonstrated a wide range of successes in recent years. In February 2005, a European government – working from a U.S. intelligence tip in accordance with a national export law – denied an export license for an Iran-bound shipment containing coolers that could be used in Iran’s heavy water reactor program.[102] In November 2006, an unnamed “third country” denied the transfer of potential missile component inputs to Iran in accordance with UNSC resolution 1696.[103] In April 2007, a shipment of material that could be used to build solid rocket propellant for ballistic missiles intended for shipment to a UN sanctioned-Iranian entity was denied access to an unidentified port in Asia and rerouted to its point of origin.[104] 

Nuclear Suppliers Group

The forty-six member Nuclear Suppliers Group (NSG), created in 1974, controls nuclear-related exports at the national level in accordance with nonproliferation policies and laws.[105] The NSG guidelines cover the export of nuclear-use items—including nuclear material, reactors and related equipment, equipment for reprocessing and enrichment—and dual-use items and technology that can be used for nuclear as well as industrial purposes.[106] The NSG operates as a voluntary program, thus, it lacks formal enforcement capabilities or binding legal authority.[107] 

Zangger Committee

Developed in the early 1970s, the thirty-seven member Zangger Committee acts as a “faithful interpreter” and guide for Article III.2 of the Nuclear Non-Proliferation Treaty (NPT), which dictates that parties to the NPT cannot export nuclear material and equipment to non-nuclear weapons nations without the application of IAEA safeguards.[108] The Zanger Committee maintains and updates a “trigger list” of export items that require safeguards and transfer controls.[109] 

Missile Technology Control Regime

The voluntary, thirty-four member Missile Technology Control Regime (MTCR), established in 1987, enhances non-proliferation policies associated with WMD delivery systems. The regime relies on member states to enforce export controls and licenses covering missile systems and related equipment, software and technology.[110] MTCR partners jointly establish common guidelines and compile a list of controlled items, but the implementation of the guidelines occur nationally at the discretion of individual member nations.

Wassenaar Arrangement 

Through the coordination of export controls, the voluntary, the forty-member Wassenaar Arrangement of 1994 seeks to curb “destabilizing accumulations” of conventional arms, goods and technologies that have military purposes.[111] Member nations undertake measures to promote transparency and responsibility in the transfer of conventional weapons and other technologies at a national level. 

Military & Security

The U.S. additionally pursues certain actions that indirectly support the expressed policy positions and sanctions taken in regard to Iran’s nuclear program. These measures include defensive military assets, security partnerships, gestures of engagement and diplomacy.

The U.S. has sought cooperative security arrangements with Iran’s neighbors and developed a military posture in the surrounding region.  In 2000, the U.S. joined Saudi Arabia, Kuwait, the United Arab Emirates, Bahrain, Qatar, Oman, Egypt and Jordan to form the Cooperation Defense Initiative (CDI) as a mechanism for cooperation on active defense, passive defense, shared early warning systems, consequence management and medical countermeasures.[112]

At a forum in Bahrain seven years following the CDI’s formation, U.S. Defense Secretary Robert Gates stressed a U.S.-Gulf Security Dialogue (GSD) to counter conventional, unconventional, asymmetric and terrorist threats.  The GSD partnership sought cooperation on regional defense, the future of Iraq, regional stability related to Iran, energy security, counter-proliferation, and counter-terrorism.[113]  Earlier in 2007, then-Secretary of State Rice envisioned the partnership as a vehicle for strengthening the defense capabilities of U.S. allies in the region in order to “support their ability to secure peace and stability in the Gulf region.”[114] Following from this, Obama administration officials have encouraged the U.S.-Gulf partnership, especially as it relates to supporting Iraq. In June 2009, Secretary Gates stated that, “The embrace of Iraq by its fellow Gulf states will help contain the ambitions of Iran.”[115] In the area of non-proliferation, Secretary Gates also indicated that the U.S. and allied Gulf nations would be “sharing intelligence for the interdiction of illegal shipments of weapons or [nuclear] material.”[116]

According to Missile Defense Agency Director Lt. Gen. Henry Obering, the U.S. “intends to begin site construction for up to ten long-range interceptors and a fixed-site radar in Europe to defend allies and deployed forces in Europe and expand homeland defense against limited Iranian long-range [missile] threats.”[117] In addition to proposing missile defense sites in Eastern Europe, the U.S., under President George W. Bush announced the deployment of an additional U.S. aircraft carrier, extension of Patriot anti-missile deployments, and increased intelligence sharing with Gulf allies.[118] In April 2009, President Obama noted that, “As long as the [ballistic missile] threat from Iran persists, we will go forward with a missile defense system [in Poland and the Czech Republic] that is cost-effective and proven.”[119] According to an Obama administration official, Acting Assistant Secretary of State Stephen Mull, the U.S. intends to review the missile defense proposal by the end of summer 2009.[120] 

Diplomacy & Regional Initiatives

On May 18, 2009, President Obama said that his administration is “engaged in a process to reach out to Iran and persuade them that it is not in their interest to pursue a nuclear weapon and they should change course.” In the context of alternative policy options, President Obama explicitly referred to “a range of steps” to include a “stronger international sanctions” program.[121] For the near-term, President Obama offered the opaque contours and timeline for his administration’s engagement tactic. Following Iran’s June presidential elections, President Obama indicated that there would be a “serious process of engagement, first through the P5-plus-one process” and “potentially through additional direct talks between the United States and Iran.”[122] President Obama did not set a deadline for the engagement process, however, assuming the engagement process between the U.S. and Iran begins shortly after the June elections, President Obama contended that, by the end of 2009, “we should have a fairly good sense…as to whether [talks] are moving in the right direction and whether the parties involved are making progress and that there’s a good faith effort to resolve differences.”[123]

The U.S. has engaged Iran in diplomatic initiatives on several occasions prior to the Obama administration. In May 2003, U.S. and Iranian officials met in Geneva “under U.N. auspices” to discuss Afghanistan, Iraq and related regional issues.[124] Two former Bush administration officials testified to a congressional committee that the U.S. and Iran cooperated on a range of Afghanistan-related issues, including enforcement of an arms embargo against the Taliban, counter-narcotics, humanitarian relief, and planning and intelligence assistance for Operation Enduring Freedom (OEF).[125] The State Department reportedly assigns U.S. Foreign Service Officers to “Iran-watcher” positions in U.S. embassies and diplomatic outposts in countries neighboring Iran and in capitals with large numbers of Iranian exiles.[126]    

The Bush administration explored the idea of opening an interests section in Tehran to facilitate people-to-people contacts and process visas, but ultimately deferred any formal decision on the matter.[127] The Obama administration, in a similar attempt at diplomatic outreach, invited Iranian diplomats to attend July 4th gatherings at U.S. embassies abroad. The invitations, which had not received a response from Iranian diplomats, were withdrawn two weeks following Iran’s elections.[128] 

Recently, the U.S. has taken steps toward a commitment to support civilian nuclear programs in the Middle East. The U.S. has attempted to demonstrate, through civilian nuclear cooperation agreements, that nations seeking nuclear energy do not need to pursue indigenous enrichment programs that could be diverted to a nuclear weapons program. As former Deputy Assistant Secretary of State for Nuclear Nonproliferation Policy and Negotiations Mary Alice Hayward outlined in December 2008:           

“In the past year and a half we have signed Memorandums of Understanding, or MOUs, on peaceful nuclear energy with several states in the Middle East who are seriously considering nuclear energy programs, including Bahrain, Jordan, Saudi Arabia and the United Arab Emirates. These MOUs are non-legally binding statements of policies shared by both countries. In each case, the MOUs affirm the intent of the country concerned to rely on the international fuel market rather seeking enrichment or reprocessing capabilities. When implementing the MOUs, we plan to help these countries develop the necessary infrastructure for the safe and secure deployment of nuclear energy. We believe that, within the region, they can serve as powerful counter-examples to Iran’s irresponsible enrichment program. Additional MOUs are under consideration with other countries in the Middle East and elsewhere.”[129] 

During the Bush administration’s last week in office, the U.S. and the UAE signed a civilian nuclear cooperation agreement. Secretary Rice, speaking at the signing ceremony, noted that the UAE was “choosing to pursue nuclear power via the import of nuclear fuel, rather than developing expensive and proliferation-sensitive fuel cycle technologies,” including enrichment.  Secretary Rice described the agreement as a “powerful and timely model” for the region.[130] In May, the Obama administration submitted the agreement to Congress, standing up a regional model that they believe “stands in direct contrast to Iran’s nuclear program.”[131] On July 14, House Foreign Affairs Committee Chairman Howard Berman (D-CA) announced a joint resolution approving the US-UAE nuclear cooperation agreement submitted to Congress.[132]  


[1] White House.  The National Security Strategy of the United States of America (Washington DC: Government Printing Office, March 2006), 24.
[2] Jay Solomon, “Senior U.S., Iranian Officials Meet At Afghanistan Conference,” The Wall Street Journal, April 1, 2009.
[3] Hillary Clinton, Press availability following international conference on Afghanistan, The Hague, Netherlands, March 31, 2009. http://www.state.gov/secretary/rm/2009a/03/121050.htm.  Accessed April 2, 2009. 
[4] Remarks by President Obama And Chancellor Merkel of Germany in Joint Press Availability, June 26, 2009. http://www.whitehouse.gov/the_press_office/Remarks-By-President-Obama-And-Chancellor-Merkel-Of-Germany-In-Joint-Press-Availability/.  Accessed June 29, 2009.
[5] “President Obama’s Press Briefing,” New York Times, June 23, 2009. http://www.nytimes.com/2009/06/23/us/politics/23text-obama.html.  Accessed June 24, 2009. 
[6] Barack Obama, Transcript of remarks at Cairo University, June 4, 2009.  http://www.whitehouse.gov/the_press_office/Remarks-by-the-President-at-Cairo-University-6-04-09/.  Accessed June 5, 2009. 
[7] Barack Obama, Videotaped remarks by the president in celebration of Nowruz, Washington DC, March 20, 2009. http://www.whitehouse.gov/the_press_office/VIDEOTAPED-REMARKS-BY-THE-PRESIDENT-IN-CELEBRATION-OF-NOWRUZ/. Accessed March 21, 2009.
[8] Barack Obama, Interview with Al Arabiya News Channel, Washington DC, January 27, 2009.  http://www.alarabiya.net/articles/2009/01/27/65096.html.  Accessed January 30, 2009. 
[9] Michael Mullen, ABC News “This Week” Interview, May 24, 2009.  http://www.abcnews.go.com/ThisWeek/story?id=7664072&page=1.  Accessed May 25, 2009.
[10] Remarks By President Obama and Prime Minister Netanyahu In Press Availability, May 18, 2009. http://www.whitehouse.gov/the_press_office/Remarks-by-President-Obama-and-Israeli-Prime-Minister-Netanyahu-in-press-availability/.  Accessed May 19, 2009.
[11] David Sanger, “U.S. May Drop Key Condition for Talks With Iran,” New York Times, April 13, 2009; Ewen MacAskill, “Obama to drop uranium precondition for Iran nuclear talks,” Guardian, April 14, 2009. 
[12] Mark Heinrich and Sylvia Westall, “ElBaradei prods Iran not to ignore Obama overture,” Reuters, June 15, 2009. 
[13] Barack Obama, June 4, 2009.
[14] Barack Obama, BBC Interview with Justin Webb, June 1, 2009. http://www.whitehouse.gov/the_press_office/Transcript-of-the-Interview-of-the-President-with-Justin-Webb-BBC-6-1-09/.  Accessed June 3, 2009.
[15] According to the June 2009 International Atomic Energy Agency (IAEA) report, Iran’s Natanz enrichment facility now houses more than 7,000 centrifuges – 5,000 of which actively enrich uranium.  See the IAEA report at http://www.iaea.org/Publications/Documents/Board/2009/gov2009-35.pdf.  For an explanation of how the uranium enrichment process figures into a nuclear weapons capability, see: Maseh Zarif, “Overview of Iran’s Nuclear Program,” IranTracker.org, April 2009. http://www.irantracker.org/nuclear-program/overview-irans-nuclear-program.
[16] Remarks by President Obama and Prime Minister Netanyahu, May 18, 2009. 
[17] Ibid. 
[18] Denis McDonough, White House Conference Call Briefing on the G8 Dinner Meeting, July 8, 2009. http://www.whitehouse.gov/the_press_office/Conference-Call-Briefing-on-the-G8-Dinner-Meeting/.  Accessed July 9, 2009. 
[19] Press Conference by the President in L’Aquila, Italy, July 10, 2009. http://www.whitehouse.gov/the_press_office/Press-Conference-by-the-President-in-LAquila-Italy-7-10-09/.  Accessed July 12, 2009.
[20] Remarks by President Obama and Prime Minister Netanyahu, May 18, 2009. 
[21] Ibid.
[22] Nicholas Kralev, “‘Crippling sanctions’for Iran an option,” The Washington Times, April 23, 2009.
[23] Geoff Morrell, Department of Defense News Briefing, May 19, 2009.  http://www.defenselink.mil/transcripts/transcript.aspx?transcriptid=4425.  Accessed May 20, 2009.
[24] Jim Garamone, “Chairman Cites Dialogue as Key to Middle East Strategy,” Armed Forces Information Services, July 7, 2009. http://www.jcs.mil/newsarticle.aspx?ID=119, accessed July 8, 2009.
[25] Stephen Hadley, Remarks at the Center for Strategic and International Studies, Washington D.C.  January 7, 2009.
[26] John Negroponte, Remarks at the Baltimore Council on Foreign Affairs, Baltimore,  October 16, 2008.
[27] Condoleezza Rice.  Interview with Andrea Mitchell of MSNBC, Washington D.C., January 12, 2009.
[28] U.S. Department of State, Letter by P5+1 Partners on new incentives package for Iran, June 17, 2008.  http://www.america.gov/st/texttrans-english/2008/June/20080617165530eaifas0.1855738.html.  Accessed January 12, 2009. 
[29] Condoleezza Rice, Interview with CNN’s Wolf Blitzer, Washington D.C.,   July 18, 2008.
[30] U.S. Government Accountability Office.  Iran Sanctions: Impact in Furthering U.S. Objectives Is Unclear and Should Be Reviewed (GAO 08-58).  Report to the Ranking Member, Subcommittee on National Security and Foreign Affairs, House Committee on Oversight and Government Reform, December 2007. 
[31] Daniel Glaser, Statement to the House, Subcommittees on the Middle East and South Asia and Terrorism, Nonproliferation, and Trade of the Committee on Foreign Affairs.  Between Feckless and Reckless: U.S. Policy Options to Prevent A Nuclear Iran, Hearing, April 17, 2008 (Serial 110-172), 24.  
[32] Ibid. 
[33] Matthew Levitt and Michael Jacobson, The Money Trail: Finding, Following, and Freezing Terrorist Finances (Washington DC: The Washington Institute for Near East Policy, November 2008), 30. 
[34] For the text of the U.N. Charter’s Seventh Chapter, see http://www0.un.org/aboutun/charter/chapter7.shtml
[35] Kenneth Katzman.  Iran: U.S. Concerns and Policy Responses (Washington DC: Congressional Research Service, October 8, 2008), 2. 
[36] Adapted from United Nations Security Council resolutions pertaining to Iran. http://www.iaea.org/NewsCenter/Focus/IaeaIran/index.shtml. 
[37] U.N. Security Council, 5500th meeting, “Resolution 1696 (2006),” S/RES/1696, July 31, 2006. http://www.un.org/News/Press/docs//2006/sc8792.doc.htm.  Accessed January 12, 2009. 
[38] Sean McCormack.  U.S. Department of State Press Statement, Washington D.C.  July 31, 2006. 
[39] U.N. Security Council, 5612th meeting, “Resolution 1737 (2006),” S/RES/1737, December 27, 2006. http://www.iaea.org/NewsCenter/Focus/IaeaIran/unsc_res1737-2006.pdf.  Accessed January 12, 2009.
[40] Kerr, Paul, “U.N. Security Council Sanctions Iran,” Arms Control Today, January/February 2007. 
[41] Burns, R. Nicholas, U.S. Department of State Press Call on UN Sanctions Resolution 1737,  December 23, 2006.  http://2001-2009.state.gov/p/us/rm/2006/78246.htm.  Accessed January 12, 2009. 
[42] U.N. Security Council, 5647th meeting, “Resolution 1747 (2007),” S/RES/1747, March 24, 2007. http://www.iaea.org/NewsCenter/Focus/IaeaIran/unsc_res1747-2007.pdf.  Accessed January 12, 2009. 
[44] Gregory L. Schulte, Statement by U.S. Ambassador to IAEA Board of Governors Meeting, Vienna, Austria, November 22, 2007.
[45] U.N. Security Council, 5848th meeting, “Resolution 1803 (2008),” S/RES/1803, March 23, 2008.  http://www.iaea.org/NewsCenter/Focus/IaeaIran/unsc_res1803-2008.pdf.  Accessed January 12, 2009; U.S. Department of State Bureau of International Security and Nonproliferation, “Fact Sheet: UN Security Council Resolution 1803 on Iran’s Nuclear Program,” April 4, 2008. http://2001-2009.state.gov/t/isn/rls/fs/102891.htm.  Accessed January 12, 2009.
[46] U.S. Department of State Bureau of International Security and Nonproliferation, “Fact Sheet: UN Security Council Resolution 1803 on Iran’s Nuclear Program,” April 4, 2008. http://2001-2009.state.gov/t/isn/rls/fs/102891.htm.  Accessed January 12, 2009. 
[47] Crail, Peter, “ElBaradei Says Iran Stalls Iran IAEA Inquiry,” Arms Control Today, October 2008. 
[48] U.N. Security Council, 5984th meeting, “Resolution 1835 (2008),” S/RES/1835, September 27, 2008. http://www.iaea.org/NewsCenter/Focus/IaeaIran/unsc_res1835-2008.pdf.  Accessed January 12, 2009.
[49] See a list of related legal precedents at the U.S. Department of Treasury’s Office of Foreign Assets Control website on sanctions pertaining to Iran:  http://www.treas.gov/offices/enforcement/ofac/programs/iran/iran.shtml
[50] Refer to footnotes 51-69.
[51] George W. Bush, Weekly Compilation of Presidential Documents 41, no. 26 (July 4, 2005), 1084.
[52] U.S. Department of Treasury OFAC, “Nonproliferation: What You Need To Know About Treasury Sanctions,” April 7, 2009. http://www.treas.gov/offices/enforcement/ofac/programs/wmd/wmd.pdf.
[53] U.S. Department of Treasury OFAC, “Recent OFAC Actions,” June 29, 2005. http://www.treas.gov/offices/enforcement/ofac/actions/20050629.shtml.  Accessed April 17, 2009.
[54] U.S. Department of Treasury, “Press Release: Treasury Targets Iranian Companies for Supporting WMD Proliferation,” February 16, 2007. http://www.treas.gov/press/releases/hp267.htm
[55] Peter Crail, “U.S. Wields Financial Sanctions Against Iran,” Arms Control Today, November 2008.
[56] U.S. Department of Treasury, “Press Release: Iran’s Bank Sepah Designated By Treasury – Sepah Facilitating Iran’s Weapons Program,” January 9, 2007. http://www.treas.gov/press/releases/hp219.htm.
[57] U.S. Department of Treasury, “Fact Sheet: Designation Of Iranian Entities And Individuals For Proliferation Activities And Support For Terrorism,” October 25, 2007.  http://www.ustreas.gov/press/releases/hp644.htm.  
[58] U.S. Department of Treasury, “Press Release: Treasury Designates Iranian Proliferation Network and Identifies New Aliases,” April 7, 2009. http://www.treas.gov/press/releases/tg84.htm
[59] U.S. Department of Justice, “Press Release: Iranian Man and His Company Charged in International Scheme to Supply Iran with Sensitive U.S. Technology,” March 16, 2009.  http://www.usdoj.gov/opa/pr/2009/March/09-nsd-240.html.  
[60] Matthew Levitt, PolicyWatch #1297: Iran Sanctions: Can They Be Effective? (Washington DC: The Washington Institute for Near East Policy, October 25, 2007).  http://www.washingtoninstitute.org/templateC05.php?CID=2673.
[61] Robin Wright, “Stuart Levey’s War,” New York Times Magazine, November 2, 2008, 31.
[62] Ibid., 31-32.
[63] Michael Jacobson, “Sanctions Against Iran: A Promising Struggle,” The Washington Quarterly 31, no.3 (Summer 2008), 81.
[64] Bureau of Coordinator for Counterterrorism, “Executive Order 13224,” September 23, 2001. http://www.state.gov/s/ct/rls/other/des/122570.htm.  Accessed April 17, 2009.
[65] U.S. Department of Treasury, October 25, 2007.
[66] U.S. Department of Treasury OFAC, “Iran: What You Need To Know About Treasury Sanctions,” January 22, 2009. http://www.treas.gov/offices/enforcement/ofac/programs/iran/iran.pdf.  Accessed April 17, 2009.
[67] “Prohibiting Certain Transactions With Respect to Iran,” Federal Register 62, no.162, August 21, 1997.  http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=1997_register&docid=fr21au97-142.pdf.  Accessed April 17, 2009.
[68] White House Office of the Press Secretary, “Executive Order 12938: Proliferation of Weapons of Mass Destruction,” November 14, 1994. http://www.treas.gov/offices/enforcement/ofac/legal/eo/12938.pdf.  Accessed April 17, 2009.
[69] U.S. Department of Treasury OFAC, “Nonproliferation: What You Need To Know About Treasury Restrictions,” May 12, 2009.  http://www.treas.gov/offices/enforcement/ofac/programs/wmd/wmd.pdf.  Accessed May 14, 2009.
[70] Adapted from public law records and congressional reports.
[71] Library of Congress, “H.R. 6198: To hold the current regime in Iran accountable for its threatening behavior and to support a transition to democracy in Iran,” September 30, 2006. http://thomas.loc.gov/cgi-bin/bdquery/z?d109:HR06198:@@@D&summ2=m&.  Accessed April 17, 2009.
[72] Ibid.
[73] Ibid.
[74] U.S. Department of State Bureau of Verification, Compliance, and Implementation, “Iran, North Korea, And Syria Nonproliferation Act Sanctions (INKSNA).” http://www.state.gov/t/vci/inksna/index.htm.  Accessed April 17, 2009.
[75] U.S. Government Accountability Office, GAO-08-58: Iran Sanctions, December 2007, 13. http://www.gao.gov/new.items/d0858.pdf.  Accessed April 18, 2009.
[76] Ibid., 11.
[77] Ibid., 14.
[78] Kenneth Katzman, The Iran Sanctions Act (ISA) (Washington: Congressional Research Service, April 2009), 1. http://assets.opencrs.com/rpts/RS20871_20090414.pdf.  Accessed May 17, 2009.
[79] Ibid.
[80] Mary Beth Nikitin, Paul Kerr, Steve Bowman, and Staven Hildreth, Proliferation Control Regimes: Background and Status (Washington: Congressional Research Service, 2008), 27-28. 
[81] Ibid., 29.
[82] Ibid., 28; P.L. 102-484, div. A, title XVI, 23 October 1992, 106 Stat. 2571.
[83] “Despite Secret ’95 Pact by Gore, Russian Arms Sales to Iran Go On,” New York Times, October 12, 2000.
[84] Ibid.
[85] Senate Congressional Record, S.3968-3969, May 5, 1997. http://bulk.resource.org/gpo.gov/record/1997/1997_S03968.pdf.  Accessed May 19, 2009.
[86] Richard Lugar, “The Nunn-Lugar Cooperative Threat Reduction Program.” http://lugar.senate.gov/nunnlugar/index.cfm.  Accessed June 2, 2009.
[87] Nikitin et al., 28.
[88] See http://lugar.senate.gov/nunnlugar/.
[89] The act introduced Chapter 7 of the Arms Export Control Act.
[90] U.S. Nuclear Regulatory Commission, Nuclear Regulatory Regulation, Vol. 2 (June 2002), 15.1-15.3.  http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0980/ml022200111-vol2.pdf#pagemode=bookmarks&page=376.  Accessed April 17, 2009.
[91] Nikitin et al., 25.
[92] Ibid.
[93] U.S. Nuclear Regulatory Commission, Nuclear Regulatory Regulation, Vol. 1 (June 2002), 1-9. http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0980/ml022200075-vol1.pdf#pagemode=bookmarks&page=14.  Accessed April 17, 2009. 
[94] Nikitin et al., 27.
[95] U.S. Department of State, “Proliferation Security Initiative,” http://www.state.gov/t/isn/c10390.htm.  Accessed May 17, 2009.
[96] White House Press Office, Remarks by President Barack Obama in Prague, April 5, 2009. http://www.whitehouse.gov/the_press_office/Remarks-By-President-Barack-Obama-In-Prague-As-Delivered/.  Accessed May 29, 2009.
[97] U.S. Department of State, “Interdiction Principles for the Proliferation Security Initiative,” http://www.state.gov/t/isn/c27726.htm.  Accessed May 17, 2009.
[98] Condoleezza Rice and George Iacovou, “Safeguarding Nuclear Arsenals,” The Washington Times, August 12, 2005.
[99] Mary Beth Nikitin, Proliferation Security Initiative (Washington: Congressional Research Service, February 2008), 6. http://fpc.state.gov/documents/organization/102629.pdf.  Accessed May 17, 2009.
[100] Hassan Fattah, “U.S.-Led Exercise in Persian Gulf Sets Sights on Deadliest Weapons,” New York Times, October 31, 2006.
[101] Andrew Winner, “The Proliferation Security Initiative: The New Face of Interdiction,” The Washington Quarterly 228, no.2 (Spring 2005), 139.
[102] Wade Boese, “Interdiction Initiative Successes Assessed,” Arms Control Today, July/August 2008. http://www.armscontrol.org/act/2008_07-08/Interdiction.  Accessed May 17, 2009.
[103] Ibid.
[104] Ibid.
[105] U.S. Department of State, “Nonproliferation Regimes,” http://www.state.gov/t/isn/c10527.htm.  Accessed May 18, 2009.
[106] Nuclear Suppliers Group, “What Are The Guidelines?,” http://www.nuclearsuppliersgroup.org/Leng/02-guide.htm.  Accessed May 17, 2009.
[107] Nikitin et al., 23.
[108] See the Zangger Committee website at http://www.zanggercommittee.org/Zangger/Misssion/default.htm.  Accessed May 17, 2009.
[109] Nikitin et al., 23.
[110] See the MTCR website at www.mtcr.info/english. Accessed May 17, 2009.
[111] See the Wassenaar Arrangement website at http://www.wassenaar.org/.  Accessed June 14, 2009.
[112] Jim Garamone.  “Cooperative Defense Initiative Seeks to Save Lives.”  American Forces Press Services.  April 10, 2000.
[113] Robert Gates.  Remarks at the Manama Dialogue in Bahrain.  December 8, 2007.
[114] Condoleezza Rice.  Statement on Assistance Agreements with Gulf States, Israel and Egypt, Washington D.C., July 30, 2007.
[115] John Kruzel, “Gates: Gulf Nations’ Support of Iraq Contains Iran,” American Forces Press Service, June 23, 2009. http://www.defenselink.mil/news/newsarticle.aspx?id=54878.  Accessed July 9, 2009.
[116] Ibid.
[117] Lieutenant General Henry A. Obering III, USAF Director, Missile Defense Agency, Before the House Oversight and Government Reform Committee National Security and Foreign Affairs Subcommittee, April 30, 2008.
[118] Katzman, 39.
[119] Barack Obama, April 5, 2009.
[120] Jonathan Fowler, “Poland reassured over US missile shield plans: minister,” Agence France Presse, July 9, 2009. http://www.google.com/hostednews/afp/article/ALeqM5hSO47YdXb7UsEL7dNv7g8AA17tXA.  Accessed July 13, 2009.
[121] Remarks By President Obama and Prime Minister Netanyahu In Press Availability, May 18, 2009. http://www.whitehouse.gov/the_press_office/Remarks-by-President-Obama-and-Israeli-Prime-Minister-Netanyahu-in-press-availability/.  Accessed May 19, 2009.
[122] Ibid.
[123] Ibid.
[124] Robin Wright, “U.S. in ‘Useful’ Talks With Iran,” The Los Angeles Times, 5/13/03. 
[125] James Dobbins and Hillary Leverett, Prepared remarks before the Subcommittee on National Security and Foreign Affairs of the House Committee on Oversight and Government Reform, Washington DC, November 7, 2007.
[126] Laura Rozen, “U.S. Moves To Weaken Iran,” The Los Angeles Times, May 19, 2006.
[127] Rice, Condoleezza, Remarks on the NATO Foreign Ministers Meeting, Washington DC, November 26, 2008.  http://2001-2009.state.gov/secretary/rm/2008/11/112423.htm.  Accessed January 12, 2009.
[128] Ross Colvin, “US withdraws July 4 invitations to Iranian diplomats,” Reuters, June 24, 2009. http://www.reuters.com/article/vcCandidateFeed1/idUSN24232730.  Accessed July 1, 2009.
[129] Mary Alice Hayward.  Remarks of the Deputy Assistant Secretary for Nuclear Nonproliferation Policy and Negotiations at the ExchangeMonitor Conference, December 3, 2008.
[130] Condoleezza Rice.  Remarks at Signing Ceremony for U.S.-U.A.E. Agreement on Peaceful Uses of Nuclear Energy, Washington DC, January 15, 2009.
[131] U.S. Embassy: Abu Dhabi, “U.S. – UAE Cooperation on Development of Civilian Nuclear Power,” May 28, 2009. http://abudhabi.usembassy.gov/pr_05282009.html.  Accessed June 3, 2009.
[132] Congress had ninety days to review the agreement, after which period it would go have gone into effect. For the text of the resolution approving the agreement, see http://www.hcfa.house.gov/111/MAS_046_xml.pdf.
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