Taking on Iran (The Art of Sanctions - Part 5)

Taking on Iran (The Art of Sanctions – Part 5)

The Art of Sanctions – Taking on Iran: AMERICAN OFFICIALS LEARNED MUCH from the experience with Iraq. Some of this learning shaped the response to concerns with Iran’s nuclear program, which existed throughout the 1990s but exploded into the public consciousness in August 2002 with revelations that Iran had been constructing two secret nuclear facilities. These revelations prompted an international investigation, led by the International Atomic Energy Agency (IAEA), and—ultimately—both the imposition of sweeping sanctions against Iran and the nuclear deal that began the process of removing those same sanctions in 2015.

Mauood’s Introduction: The author of the present book (The Art of Sanctions) is Richard Nephew. Richard Nephew was in charge of the sanctions team against Iran during Obama’s second term. He supported the nuclear negotiators in the matter of sanctions in Vienna. Richard Nephew has previously served for ten years as an Iran member of the National Security Council at the White House and as Deputy Secretary of State for Coordination of Sanctions at the State Department. The book is also translated into Persian by the Iranian Parliamentary Research Center (IPRC).

Note: The content of this book is not approved by us and is published solely to familiarize policymakers with the views, approaches, and methods of the designers of sanctions against Iran.

Iranian Nuclear History, in Brief

Contrary perhaps to some expectations, Iran’s nuclear program did not begin under its present government, the post-revolution Islamic Republic. Rather, it began under the previous government of the Shah of Iran, who ruled Iran from 1941 to 1979 (with a brief interruption in 1953). He began the Iranian nuclear program as both a potential energy source and as a way of advancing the country’s overall scientific capacity. The nuclear program was the subject of considerable internal investment of treasure and talent.

The West helped. In 1967, Iran acquired a research reactor from the United States (along with highly enriched uranium fuel). Hundreds of Iranian students were dispatched to a variety of Western institutions to learn what they could of nuclear physics and related disciplines after the creation of the Atomic Energy Organization of Iran in 1974.1

The Shah’s Iran spent considerably to develop a rudimentary nuclear infrastructure and to lay the groundwork for more, with the budget of the Atomic Energy Organization reaching $1 billion in 1976 alone.2 The twin nuclear power reactors planned for Bushehr were to be the crowning achievement of the Shah’s nuclear program, but by far not its terminus: Iran was to have at least 23,000 megawatts (electric) by 1994.3

And hidden under the surface but a paramount concern for the United States (at least for a time), the Shah also appears to have been interested in applying his country’s burgeoning nuclear expertise toward nuclear weapons. He sought a variety of technologies that have a place in civil nuclear energy production, but which are also essential for the production of nuclear material for weapons.

These technologies—which constitute what is known as the nuclear “fuel cycle”—include spent fuel reprocessing (that can support plutonium-based weapons) and uranium enrichment (that can support uranium-based weapons). It was the Shah’s interest in developing spent fuel reprocessing in particular that prompted concern in the United States as to his overall ambitions.

It appears today that the Shah was motivated to consider nuclear power as a means of delivering reliable energy supply, providing insurance for a future in which Iranian oil and gas might not be available for electricity production, and spurring further technical innovation; he sought a nuclear weapons option as a way of managing regional security issues, deterring Western or Soviet interference, and demonstrating the sophistication and majesty of the Iranian people.

In this, there is a corollary to the Shah’s massive acquisition of conventional weapons with the oil boom of the early 1970s, which some have speculated stemmed both from his regional ambitions and a fundamental sense of regime insecurity.4

After the Iranian revolution in 1979, there was less interest in a nuclear program, in part due to the expense.5 As much as the Iranian revolution took a religious tone over time, it began as an economic protest against extravagant spending by the Shah while economic inequality wracked the broader population. The nuclear program was lumped into this same category by the revolutionary government. But by the mid-1980s, the Iranian nuclear program was once more funded and pursuing a variety of technology lines.

Some of these activities were legitimately associated with civil applications, such as nuclear power or the production of medical isotopes for the treatment of disease. Iran also sought technical cooperation from a variety of sources, including the IAEA and a number of individual countries, in order to expand its knowledge base and capabilities.

However, we also now know that, beginning in the late 1980s and continuing through the early 2000s, Iran once more pursued technologies that could contribute directly to the development and acquisition of nuclear weapons. Some of this covert work Iran did on its own, but much of it was supported through technology purchases and technical assistance from the father of Pakistan’s nuclear weapons program, Abdul Qadeer Khan.6

Khan had started Pakistan’s nuclear weapons program through the illicit acquisition of technology from his former employer, URENCO, and, in time, he used his connections with companies around the world to create what became known as the “A. Q. Khan” proliferation network. While active, this network transferred sensitive nuclear technology and designs to Libya, in addition to Iran. It may have also supported nuclear weapons research in Iraq, Syria, and North Korea (although this has yet to be proven).7

Iran’s purchases centered on the production of material usable for nuclear weapons through the use of uranium centrifuges, and the country procured two designs and several prototype centrifuges from Khan to advance its program.

Combined with Iran’s work to develop a nuclear warhead—possibly through the application of still further information bought from Khan—Iran’s nuclear program was bifurcated into a declared program and an undeclared one. The declared program operated on the surface, with facilities made known to the IAEA and—through the IAEA— the rest of the world in accordance with Iran’s obligations under the Treaty on the Nonproliferation of Nuclear Weapons (NPT) and its Comprehensive Safeguards Agreement (CSA).8

The undeclared program consisted of activities that Iran was either legally required to disclose to the IAEA but did not or work that it was absolutely forbidden to pursue in accordance with Iran’s NPT commitment not to pursue nuclear weapons. In this undeclared program, separate lines of work—some involving Atomic Energy Organization of Iran (AEOI) scientists and others involving personnel from the Ministry of Defense and Iranian Revolutionary Guard Corps (IRGC)—pushed forward Iran’s understanding of nuclear science and the capabilities to use it.

The United States and some of its partners were sufficiently aware of this line of effort—though not necessarily its full extent or who was involved—to be concerned about Iran’s nuclear program. On this basis, the United States and its partners discouraged nuclear cooperation with Iran through the 1980s and 1990s.

Coincident with this effort, the United States also imposed its own domestic sanctions on Iran for a variety of bad acts, such as support for terrorism. This effort began in earnest in 1984, the year Iran was named a State Sponsor of Terrorism. The United States imposed a sweeping embargo on all U.S. trade with Iran in 1995.

But because U.S.-Iranian trade had never again approached the levels of significance that marked the pre-revolution relationship, the impact on Iran from this step was muted.

For this reason, the United States also tried to leverage its own economic position to discourage other countries from pursuing new business with Iran. This took the form of the Iran-Libya Sanctions Act of 1996 (ILSA), which targeted new investments in Iran’s oil and gas sectors (as well as those of Libya).

ILSA was the real start of the U.S. sanction campaign that culminated in the Joint Comprehensive Plan of Action (JCPOA) in 2015, though it was an inauspicious beginning. For the rest of the world, U.S. hostility to Iran—and its nuclear program as well—was assumed to be only a result of the overall negative U.S.-Iran relationship post 1979, a product of mutual recriminations, the hostage taking at the U.S. embassy, and the resulting break in diplomatic relations between the countries.

Thus, instead of starting international bandwagoning, ILSA was widely condemned around the world as an extraterritorial application of U.S. law. The European Union was particularly aggrieved, as ILSA became law coincident with a similarly aggressive set of U.S. sanctions related to Cuba (named the Helms-Burton Act after its sponsors). The EU both announced the intention to file a grievance with the World Trade Organization and adopted new legislation that effectively forbade any EU legal person from complying with non-EU sanctions law (Council Regulation No 2271/96 of 22 November 1996).

The Clinton administration negotiated an arrangement with the EU to deal with these challenges to U.S. sanctions, effectively shelving implementation of ILSA with respect to European companies so long as the United States and Europe cooperated to deal with the challenges presented by Iran.9

Only when confronted with unambiguous evidence of Iran’s illicit activities did most of the world come to understand what Iran was doing and the threat presented by an unimpeded Iranian nuclear program.

This realization began dawning in 2002 when the National Council of Resistance of Iran (NCRI, a dissident group associated with the Mujahadeen el Kaliq, a U.S.-designated terrorist group until 2012) announced at a press briefing the uncovering of two clandestine Iranian nuclear facilities. The first was a massive, “cut and cover” bunker installation at a place called Natanz, where Iran intended to build a 50,000 uranium centrifuge plant.

The second was a heavy-water production plant at a place called Arak; heavy water can be used to moderate nuclear reactions for a type of nuclear reactor that also happens to be an effective producer of weapons-usable plutonium. At this point, Iran faced a critical choice: come clean or attempt to sweep under the carpet all of its past illicit work. Iran chose the latter, beginning a more active game of cat and mouse with the IAEA and the larger international community.

The Predicate of the Post-1996 Sanctions Campaign My initial part in the Iranian nuclear drama was modest. I joined the Pacific Northwest National Laboratory (PNNL) in June 2003 as a Nonproliferation Graduate Fellow, based at the National Nuclear Security Administration (NNSA) of the U.S. Department of Energy (DOE).

This program, like others, sought to bring early career professionals into the government, in this instance focused on managing the challenge of the spread of weapons of mass destruction. The fellowship program had its origins in the need of the Energy Department to staff new positions to support cooperative threat-reduction programs with the former Soviet Union. But, in time, the needs of the department prompted an expansion of the program and its writ.

I served as a special assistant to an assistant deputy adminis-trator at DOE/NNSA. My task was, in essence, to be the grease that permitted the real professionals to do their jobs, while learning all that I could about the department, its mission, and my chosen area of specialization. Of course, this position also meant that I was available for whatever else DOE/NNSA might require.

Starting in December 2003, this included serving on the team that helped to dismantle Libya’s nuclear weapons program under the landmark agreement struck between Libya, the United States, and the United Kingdom. My job on this team began with the mixture of joy and pain familiar to all interns: photocopying. In my case, I was photocopying sensitive documents retrieved from Libya to permit further analysis throughout the U.S. government.

My participation in Libya-related efforts led me to be invited to join the DOE/NNSA team working on broader issues of nuclear noncompliance, such as those ongoing with North Korea and Iran. Over the next two years, I took on greater responsibility as an action officer at DOE/NNSA for the Iran file, including—in 2005–2006—participating in the development and delivery of technical briefings on the Iranian nuclear program to foreign governments around the world.

This was part of the U.S. government’s overall strategy to explain to the rest of the international community the severity of the threat posed by Iran’s activities. Here, the United States faced a variety of challenges, many of which centered on the credibility lost by the U.S. government over Iraq.

First, though the IAEA had made public some information concerning previously undeclared nuclear activities in Iran, a substantial basis for U.S. pressure was in its belief that Iran was actively pursuing a nuclear weapon outright, rather than just technologies that could enable the production of nuclear weapons at some point. However, unfounded U.S. assertions over the existence of weapons of mass destruction (WMD) in Iraq cast a deep shadow over international perceptions of the U.S. intelligence community.

Many U.S. partners expressed doubts about the U.S.’s official conviction that Iran’s nuclear program was irretrievably destined to result in nuclear weapons. They were prepared to accept some of Iran’s arguments, especially in the absence of any direct, unambiguous evidence of Iranian nuclear weapons research. What the IAEA found in Iran could support weapons production, to be sure, but it could also support civil nuclear energy. That Iran had failed to fulfill its obligations under the NPT was fairly clear and obvious, but Iran’s argument that U.S. hostility and dissuasion of even declared, public, civil nuclear cooperation with Iran throughout the 1980s and 1990s forced the Iranians to go underground was persuasive to many international audiences.

Second, though the invasion of Iraq had demonstrated U.S. war-fighting capability, U.S. failure to secure Iraq after the invasion and subsequent trouble in restoring order to the country created a sufficient drain on U.S. resources—when combined with the ongoing conflict in Afghanistan—that there was doubt in the U.S. ability to mount a third military offensive in the region and even more doubt that it would be prudent to do so. And, third, there was enough bad blood between the United States and many of its allies, particularly in Europe, over the entire matter of the invasion of Iraq that partner support for further U.S. military activity was impossible to assume.

The U.S. approach was to take a dramatically different tack with Iran than we had with Iraq, relying on the reports of international inspectors rather than those of intelligence officers to make the case that Iran was up to no good. Iran helped. From 2002 to 2005, Iran selectively disclosed parts of its nuclear program, usually just prior to having them exposed by the IAEA or others. But in these disclosures, Iran admitted to having conducted a wide range of nuclear activities that, per its Safeguards Agreement with the IAEA and pursuant to its NPT obligations, Iran should have declared years before.

This included activities at a variety of locales in which undeclared nuclear work had taken place using undeclared nuclear materials. These admissions were documented in an IAEA report issued on November 15, 2004, at the request of the United States and its partners in September 2004.10 Though the listing is technical in nature, a pattern of direct Iranian efforts to undertaken sensitive nuclear activities far from the watchful eye of international inspectors is discernible:

As assessed in light of all information available to date, these failures can now be summarized as follows:

(a.) Failure to report:

  1. the import of natural uranium in 1991, and its subsequent transfer for further processing;
  2. the activities involving the subsequent processing and use of the imported natural uranium, including the production and loss of nuclear material where appropriate, and the production and transfer of waste resulting therefrom;
  3. the use of imported natural UF6 for the testing of centrifuges at the Kalaye Electric Company workshop in 1999 and 2002, and the consequent production of enriched and depleted uranium;
  4. the import of natural uranium metal in 1993 and its subsequent transfer for use in laser enrichment experiments, including the production of enriched uranium, the loss of nuclear material during these operations and the production and transfer of resulting waste;
  5. the production of UO2, UO3, UF4, UF6 and ammonium uranyl carbonate (AUC) from imported depleted UO2, depleted U3O8 and natural U3O8, and the production and transfer of resulting wastes; and
  6. the production of natural and depleted UO2 targets at ENTC and their irradiation in TRR, the subsequent processing of those targets, including the separation of plutonium, the production and transfer of resulting waste, and the storage of unprocessed irradiated targets at TNRC.

(b.) Failure to declare:

  1. the pilot enrichment facility at the Kalaye Electric Company workshop; and
  2. the laser enrichment plants at TNRC and the pilot uranium laser enrichment plant at Lashkar Ab’ad.

(c.) Failure to provide design information, or updated design information, for:

  1. the facilities where the natural uranium imported in 1991 (including wastes generated) was received, stored and processed (JHL, TRR, ENTC, waste storage facility at Esfahan and Anarak);
  2. the facilities at ENTC and TNRC where UO2, UO3, UF4, UF6 and AUC from imported depleted UO2, depleted U3O8 and natural U3O8 were produced; (iii) the waste storage at Esfahan and at Anarak, in a timely manner;
  3. the pilot enrichment facility at the Kalaye Electric Company workshop;
  4. the laser enrichment plants at TNRC and Lashkar Ab’ad, and locations where resulting wastes were processed and stored, including the waste storage facility at Karaj; and
  5. TRR, with respect to the irradiation of uranium targets, and the facility at TNRC where plutonium separation took place, as well as the waste handling facility at TNRC.

(d.) Failure on many occasions to cooperate to facilitate the implementation of safeguards, as evidenced by extensive concealment activities.11

Paragraphs later, the IAEA offered the conclusion that, in the end, set the terms of conflict between the United States, its partners, and Iran until the initial nuclear deal was reached in 2013:

“All the declared nuclear material in Iran has been accounted for, and therefore such material is not diverted to prohibited activities. The Agency is, however, not yet in a position to conclude that there are no undeclared nuclear materials or activities in Iran.”12

This same conclusion was offered by the IAEA in its reports on Iran’s nuclear program through the subsequent years of IAEA investigations, and will persist until the IAEA is able to verify Iran’s nuclear declarations fully (a process that—even with the provisions of the JCPOA intact for their full duration—could take another decade given the extent of Iran’s undeclared work over the years).

Under the terms of Iran’s CSA and the IAEA Statute, Iran’s failure to provide the appropriate declarations and provide for inspections was grounds for a finding by IAEA that Iran was out of compliance with its obligations. Under paragraph XII.C of the IAEA statute, “the inspectors shall report any non-compliance to the Director General who shall thereupon transmit the report to the Board of Governors. The Board shall call upon the recipient State or States to remedy forthwith any non-compliance which it finds to have occurred.

The Board shall report the non-compliance to all members and to the Security Council and General Assembly of the United Nations.”13 Upon receiving such a report, the UN Security Council and General Assembly could then decide how to respond.

It was on the basis of these verified, IAEA-reported Iranian violations that the United States sought to pursue international action. The United States and other countries greeted this report as a validation of their concerns about the nature of Iran’s nuclear program, particularly in that IAEA Director General Mohamed El-Baradei, whose adversarial relationship with the George W. Bush administration over Iraq was public knowledge, issued it.

Though the United States had some ambition of reporting Iran to the UN Security Council based on November 2004 report, that report was issued amid negotiations that were ongoing between the members of the so-called EU-3 (France, Germany, and the United Kingdom) over the terms of an Iranian suspension of its most significant nuclear activities.

This suspension was intended to replace an earlier one, agreed to in October 2003 but fractured in subsequent months over a fundamental disagreement about key terms, such as the extent of the nuclear stand-down Iran was supposed to make. The EU-3 used the report and the threat of U.S. pressure to convince Iran to return to a more complete suspension of its fuel cycle activities and to the negotiating table.

However, this suspension too came under pressure, this time at the hands of political changes in Tehran. In June 2005, Mahmoud Ahmadinejad was elected president of Iran. The president of Iran is subordinate to the position of Supreme Leader, held since 1989 by Ayatollah Ali Khamenei.

Consequently, the Iranian president does not have complete autonomy or full executive authority. But it is an important role, both from the standpoint of offering Iranians a sense of democratic control over their government institutions (though the degree to which this sense is real is subject to continual debate by observers and academics) and from the perspective of day-to-day government operations.

On August 1, 2005, the Iranian government informed the IAEA that it was restarting some of the uranium conversion–related activities that had been suspended pursuant to the arrangement with the Europeans agreed in November 2004. Ahmadinejad was inaugurated on August 3. The Iranian Foreign Ministry declared the EU-3’s negotiating offer for a long-term comprehensive solution “not acceptable” three days later, and activities commenced at Iran’s uranium conversion facility at Esfahan on August 8.14

After a flurry of diplomatic activity—in which many delegations to the IAEA tried in vain to convince Iran to return to its suspension—the IAEA Board of Governors adopted a resolution on September 24, 2005, finding Iran in noncompliance with its nuclear obligations under the IAEA Safeguards Agreement.15

A formal report to the UNSC was delayed until a later date so as to permit continued diplomatic initiatives, but it was clear to the United States (and to many others) that the Iranian government was committed to a more confrontational course of action. That night, the U.S. delegation celebrated a significant step forward in the campaign to address U.S. concerns with Iran’s nuclear activities, but it was a celebration tinged with the reality that an IAEA resolution would not itself accomplish this goal.

Instead of an ending, the IAEA Board of Governors’ decision signaled the beginning of a much more involved, pressure-infused diplomatic campaign.

On to Sanctions

The IAEA Board of Governors voted to report Iran to the UN Security Council for its nuclear violations on February 4, 2006, after the Iranian government restarted uranium enrichment activities in January 2006. This proved to be the final straw for governments which, to date, had been giving Iran the benefit of the doubt and space to make a return to the EU-3-led diplomatic process.

The vote to report Iran to the UN Security Council was lopsided, with twenty-seven members of the thirty-five-seat Board voting in favor of the report. Only Cuba, Syria, and Venezuela stood with Iran.16 Russia and China voted in favor, and Iran now appeared isolated in the UN Security Council.

George W. Bush’s State of the Union address given just days before the IAEA Board’s February 4 vote made clear that “America will continue to rally the world to confront” the threats presented by Iran, including “its nuclear ambitions.” President Bush declared that “the nations of the world must not permit the Iranian regime to gain nuclear weapons” and a statement issued by the president of the UN Security Council at the end of March 2006 underscored that the UNSC would remain seized of this matter until Iran complied with its nuclear obligations.17

But translating international interest into international action was easier said than done. The Bush administration decided to pursue an international sanctions path against Iran, convinced that UN-level action was a critical component of any successful sanctions effort (as the right UNSC language would require all UN member states to comply). But the other permanent members of the UN Security Council—whose veto-holding powers could preclude the adoption of UNSC sanctions—demanded a quid pro quo for consideration of UN sanctions: that Iran be first offered a clear choice between a package of incentives and the threat of an agreed list of sanctions.18

The choice was conveyed by EU High Representative for Common Foreign and Security Policy Javier Solana on June 6, 2006, on behalf of the Permanent Five members of the Security Council—China, France, Russia, the United Kingdom, and the United States—and Germany, an arrangement that became known as the P5+1.19 Through it starting in 2006, the United States and its partners sought to create a path for Iran to accept a diplomatic resolution to the crisis by combining an offer of negotiations with the threat of sanctions.

Iran was given two months to respond positively to the P5+1’s offer, a decision made stark with the adoption of UNSCR 1696 at the end of July 2006. Iran’s response on August 22, 2006, was contemptuous of the P5+1 incentives package, though Iran indicated it would be amenable to further talks with the P5+1.

By this time, I had moved from the DOE to the State Department, taking up my duties as one of the senior officers responsible for Iran’s nuclear program in the Bureau of International Security and Nonproliferation. The State Department was as dismissive of Iran’s counteroffer as the Iranians were of the P5+1 package, seeing little in the Iranian response—described as vague and rambling by one official—to commend it.20 Instead, we began working on the options for a UNSC resolution that would impose sanctions on the Iranian nuclear program; my own primary responsibility was to assemble the list of individuals and entities to target in the resolution.

The P5+1 package from June 2006 offered some help in framing possible sanctions, which were to focus on Iran’s nuclear and missile programs, its access to sensitive nuclear or missile-related goods, and the individuals and entities involved in running the nuclear and missile programs. There was consideration of wider, economic sanctions within the U.S. government, but consultations with the other members of the P5+1 suggested that these would be out of reach early on in the process.

However, there was little confidence within the U.S. government that UN sanctions would turn the tide with Iran (and, in fact, in some quarters outright disdain for the idea that sanctions in general would be useful). I recall a common view was that UN sanctions would never go far enough to affect Iranian thinking, let alone their strategic perception of the utility of a nuclear weapons option which was—at the time—assumed to be part of their ongoing research program.

This mindset changed somewhat after the adoption of UNSCR 1737 on December 23, 2006, when it became clear that the Iranians were perturbed both by the adoption of measures targeting them and the fact that Russia and China joined in support of 1737’s adoption. At that point, senior U.S. government officials suggested that the individual value of particular measures was secondary to the adoption of new sanctions altogether.

The United States began to contemplate a persistent series of UNSC resolutions, coming like clockwork after every report by the IAEA Director General that Iran remained in noncompliance with both the requirements of the UNSC—which included the suspension of all of Iran’s uranium enrichment, reprocessing and heavy water–related activities—and its NPT obligations. The tempo and the constant international condemnation had their own value to be exploited.

But there was also recognition in the United States that public, political pressure would be fleeting and that real economic pressure from the UNSC may be difficult to deliver even if Russia and China were supportive of sanctions in principle. The United States was also considering alternative ways of bringing together the international community, building on the lessons of ILSA.

This translated into a far more serious effort to impose innovative new sanctions on Iran’s economy by targeting the interconnections between it and the rest of the world. Such sanctions would be efficient—omitting as a direct result the sort of humanitarian catastrophe that came from the Iraq sanctions program—while also keeping the decision making in the hands of the United States.

Predating the UNSC process, the first action was the July 1, 2005, authorization of new financial sanctions against those involved in the proliferation of WMD by President Bush in Executive Order 13382. This order specifically authorized the secretary of the treasury, in consultation with the secretary of state, to freeze the assets of WMD proliferators.

Perhaps more important, it facilitates the inclusion of such targeted individuals and entities on the Treasury Department’s Specially Designated Nationals and Blocked Persons (SDN) list, which banks around the world use to screen against transactions that could involve illicit goods. Iran was a major target of this initiative, as is demonstrated by the fact that of the eight entities so designated first, four were Iranian.21

By the end of 2006, the United States had used the E.O. 13382 authority not only to expand the list of designated entities and individuals, but also to engage with banks and companies around the world diplomatically. Even without the formal legal requirement to do so, the United States sought to educate the world’s business community of the dangers of doing business with Iran (and—as a result—to dry up Iran’s ability to conduct such business altogether).22 And, perhaps most important, we began to tie together the strategy of using a combination of pressures—multilateral, national, diplomatic—to persuade Iran to change course.



1. State Department cable from Tehran, May 11, 1977, http://nsarchive.gwu.edu/nukevault/ebb268/doc14b.pdf.

2. Ariana Rowberry, “Sixty Years of Atoms for Peace and Iran’s Nuclear Program,” Up Front (blog), Brookings, December 18, 2013, http://www.brookings.edu/blogs/up-front/posts/2013/12/18-sixty-years-atoms-peace-iran-nuclear-program-rowberry.

3. State Department cable from Tehran, May 11, 1977.

4. Andrew Scott Cooper, The Oil Kings (New York: Simon and Schuster, 2011).

5. David Albright and Andrea Stricker, “Iran’s Nuclear Program,” Iran Primer (blog), United States Institute of Peace, September 2015, http://iranprimer.usip.org/resource/irans-nuclear-program.

6. IAEA Report to the Board of Governors, “Implementation of the NPT Safeguards Agreement in the Islamic Republic of Iran,” November 15, 2014, https://www.iaea.org/sites/default/files/gov2004-83.pdf.

7. Michael Laufer, “A. Q. Khan Nuclear Chronology,” Carnegie Endowment for International Peace, September 7, 2005, http://carnegieendowment.org/2005/09/07/a.-q.-khan-nuclear-chronology.

8. A CSA provides legal authority for the IAEA to conduct inspections of declared nuclear facilities within a country.

9. Thomas W. Lippman, “U.S. Defers Sanctions on Iran Gas Deal,”Washington Post, October 4, 1997, https://www.washingtonpost.com/archive/politics/1997/10/04/us-defers-sanctions-on-iran-gas-deal/6f4a72cb-f760-4eaa-9ea6-bdf3c2de52f2/?utm_term=.106afb70c72c

10. IAEA Report to the Board of Governors, “Implementation of the NPT Safeguards Agreement,” November 15, 2004, https://www.iaea.org/sites/default/files/gov2004-83.pdf.

11. Ibid.

12. Ibid.

13. IAEA Statute, https://www.iaea.org/about/statute.

14. “Iran Rejects Europe’s Nuclear Deal,” CNN, August 9, 2005, http://www.cnn.com/2005/WORLD/meast/08/06/iran.nuclear/index.html?; IAEA Report to the Board of Governors, “Implementation of the NPT Safeguards Agreement,” September 2, 2005, https://www.iaea.org/sites/default/files/gov2005-67.pdf.

15. IAEA Board of Governors resolution, September 24, 2005, https://www.iaea.org/sites/default/files/gov2005-77.pdf.

16. Paul Kerr, “IAEA Reports Iran to UN Security Council,” Arms Control Today, March 1, 2006, https://www.armscontrol.org/act/2006_03/MARCH-IAEAIran.

17. CQ Transcripts Wire, “President Bush’s State of the Union Address,”Washington Post, January 31, 2006, http://www.washingtonpost.com/wp-dyn/content/article/2006/01/31/AR2006013101468.html; UN Security Council, “Security Council, in Presidential Statement, Underlines Importance of Iran’s Re-Establishing Full, Sustained Suspension of Uranium-Enrichment Activities,” March 29, 2006, http://www.un.org/press/en/2006/sc8679.doc.htm.

18. The exact list of potential sanctions measures agreed to among the P5+1 has not been released publicly, although many of the measures were subsequently adopted by the UNSC in its four resolutions to impose sanctions against Iran. But the incentives offered have been made public (and are contained in an annex to resolution 1747).

19. Breffni O’Rourke, “Iran: Solana Delivers EU Offer on Nuclear Program,” Radio Free Europe / Radio Liberty, June 6, 2006, http://www.rferl.org/content/article/1068944.html.

20. Radio Free Europe / Radio Liberty, “Iran: U.S. Official Outlines Concerns About Nuclear Program,” October 23, 2006, http://www.rferl.org/content/article/1072217.html.

21. Executive Order 13382, July 1, 2005, http://www.state.gov/documents/organization/135435.pdf.

22. Robin Wright, “Stuart Levey’s War,” New York Times, October 31, 2008, http://www.nytimes.com/2008/11/02/magazine/02IRAN-t.html.


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