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Project Alpha
Centre for Science
and Security Studies
Interdicted Carbon Fibre
Proliferation Case Study Series
Nick Gillard1
26 September 2014
2
About Project Alpha
Alpha was established in 2011 at King’s College London’s Centre for Science and Security Studies
(CSSS) with government funding to improve the implementation of trade controls. Alpha conducts
research to understand both illicit trade and the effectiveness of supply-side controls in countering
such trade. This research forms the basis of Alpha’s outreach and capacity building activities.
About the Case Study Series
This series was developed to highlight individual cases of illicit trade so that broader policy lessons
can be identified an enacted. The series draws upon a variety of open source information, including
media reporting, trade data and social media information.
Acknowledgements
Alpha’s work is funded from a variety of sources, including the British Foreign and Commonwealth
Office and the MacArthur Foundation.
Copyright 2014 King’s College London
The author/s of this report invites liberal use of the information provided in it for educational
purposes, requiring only that the reproduced material clearly cite the source, using: ‘Interdicted
Carbon Fibre’, Proliferation Case Study Series, Nick Gillard, Project Alpha, 26 September 2014.
About the Authors
1. Nick Gillard is a Researcher working on Project Alpha at the Centre for Science and Security
Studies, Department of War Studies, King’s College London.
© King’s College London
All Rights Reserved
3
Summary
In December 2012, a shipment of high-strength carbon fibre bound for Iran was interdicted and
seized in Singapore. This case study provides an overview of the carbon fibre seizure and the
entities involved in the attempted shipment, which span Iran, mainland China, Hong Kong and
Georgia. While the end-user of the material remains unknown, the size of the seized goods –
7,200kg of high-strength carbon fibre – is easily sufficient to produce at least enough centrifuge
rotors to outfit a Fordow-size uranium enrichment facility. The case highlights the importance of
interdictions as well as other lessons for export control and non-proliferation professionals.
4
Case Study Outline
1. Introduction
2. The interdiction
3. The goods
4. The middlemen
5. The supplier
6. The shipping company and vessel
7. The end-user
8. Analysis and lessons
5
1. Introduction
In December 2012, a shipment of high-strength carbon fibre bound for Iran was interdicted and
seized in Singapore. The Panel of Experts established pursuant to UN Security Council Resolution
1929 has since concluded that the attempted shipment represented a breach of Resolution 1929,
which blocks, inter alia, the supply of items that could contribute to Iran’s uranium enrichment
programme.1 And while the end-user of the shipment is unknown, the size of the seized material –
7,200kg of high-strength carbon fibre – is sufficient to produce at least enough centrifuge rotors to
outfit a Fordow-size uranium enrichment facility.
This case study provides an overview of the carbon fibre seizure and the entities involved in the
attempted shipment. The Panel of Experts’ June 2014 report to the UN Security Council, which
describes the circumstances of the interdiction and some of the entities involved, forms the basis of
this Alpha case study. This case study also provides new insights drawn from open sources into
persons and companies associated with the attempted shipment, and draws lessons for the private
sector and non-proliferation professionals.
2. The interdiction
The broad details of the seizure are provided by the Panel of Experts in their June 2014 report to
the Security Council. 2
In December 2012, according to a member state’s report to the Panel, the Iranian-flagged vessel
Shahraz was intercepted and searched while en route from China to the main Iranian port of
Bandar Abbas. Part of the ship’s cargo was a consignment of carbon fibre, which the authorities
seized: it comprised of 1,800 bobbins of the material, weighing a total of 7,200 kg. Packing
materials and documents identified the carbon fibre as being made by the Japanese manufacturer
Toray. The listed consignee in the documentation was Mina Tejarat Sanabad, an Iranian company
in the eastern city of Mashhad, represented by an individual named Hamidreza Afzalian Shirvan.3
The Panel of Experts does not state where the interdiction took place. Press reporting, however,
indicates that the interdiction took place in Singapore. 4 5
1 UN Security Council, 20 March 2014, ‘Chair of Sanctions Committee on Iran Briefs Security Council
ahead of Debate on Recent Developments,’ http://www.un.org/News/Press/docs/2014/sc11333.doc.htm,
accessed 27 August 2014.
http://www.un.org/News/Press/docs/2014/sc11333.doc.htm 2 ‘Final report of the Panel of Experts established pursuant to resolution 1929 (2010),’
http://www.un.org/ga/search/view_doc.asp?symbol=S/2014/394, accessed 26 August 2014. 3 ‘Final report of the Panel of Experts established pursuant to resolution 1929 (2010),’ p. 10,
http://www.un.org/ga/search/view_doc.asp?symbol=S/2014/394, accessed 26 August 2014. 4 Edith M Lederer, ‘UN divided on Iran sanctions violations,’ Associated Press, 15 July 2013,
http://bigstory.ap.org/article/un-divided-iran-sanctions-violations, accessed 26 August 2014. 5 Security Council Report, ‘Chronology of Events,’
http://www.securitycouncilreport.org/chronology/iran.php, accessed 26 August 2014.
6
Figure 1. Intended route of carbon fibre shipment
7
3. The goods
The seized material has been identified by the Panel of Experts and confirmed by the manufacturer
as Toray-brand T700SC-12000 carbon fibre in a form known as tow or yarn. Tow is a string-like
form of carbon fibre consisting of thousands of individual carbon filaments. It is usually wound with
resin to form solid structures such as cylinders, or woven with resin to form fabric. T700-grade
carbon fibre is a high-strength form of the material, regarded by Toray as suitable for industrial use,
sporting goods, and aircraft secondary structures (including rocket components).6
T700-grade carbon fibre tow is also one of the few materials suitable for use in manufacturing
centrifuge gas rotors for uranium enrichment. According to the manufacturer’s website, Toray
T700 has an ultimate tensile strength of 4900MPa.7 By comparison, maraging steel and 7075-T6
grade aluminium – two other materials known to be used for centrifuge rotors – have ultimate
tensile strengths of 2410MPa8 and 572 MPa
9 respectively. Because of its utility for centrifuge rotor
manufacturing, T700-grade carbon fibre is controlled by the Nuclear Suppliers Group.
An image provided in the Panel’s report shows some of the seized carbon fibre in its packaging
(below). On both the boxes and bobbins, the manufacturer’s labels – which probably identified the
original buyer of the material – have been torn, most likely by a re-seller to hide the material’s
provenance.
(Source: ‘Final report of the Panel of Experts established pursuant to resolution 1929 (2010),’ p. 11,
http://www.un.org/ga/search/view_doc.asp?symbol=S/2014/394, accessed 26 August 2014)
6 Moriyuki Onishi, ‘Toray’s Business Strategy for Carbon Fibre Composite Materials,’
http://www.toray.com/ir/pdf/lib/lib_a136.pdf, accessed 27 August 2014. 7 ‘T700S DATA SHEET,’ Toray, http://www.toraycfa.com/pdfs/T700SDataSheet.pdf, accessed
26 August 2014. 8 Maher, ‘Maraging C350,’ http://www.maher.com/html/alloys/maraging/MaragingC350.html, accessed 27
August 2014. 9 Aerospace Specification Metals, ‘Aluminium 7075-T6; 7075-T651,’
http://asm.matweb.com/search/SpecificMaterial.asp?bassnum=MA7075T6, accessed 27 August 2014.
8
4. The middlemen
According to the Panel of Experts report, shipping documents identified the consignee for the
seized carbon fibre as Hamidreza Afzalian Shirvan, at the address Unit 2, No. 9 Biston 3 Alley,
Biston St., Dastgheib Blvd., Mashhad, Islamic Republic of Iran. 10
The report’s annex describes
Afzalian as representing Mina Tejarat Sanabad.
The Iranian company Mina Tejarat Sanabad (also known as Minaye Tejarat Sanabad or MTS) has
an extensive online presence. The MTS website (minayetejarat.com) describes the firm as being
involved in import and export of raw materials, and names the company’s manager, Amir Bidouyi.11
Domain registry information from the MTS website supported by social media information reveals
another MTS employee, Farshid Bidooee – possibly a relative of Amir Bidouyi, given the similarity
of their surname.12
13
MTS appears to focus on trade between China and Iran. In one online advert, MTS states that it
has been ‘active in the field of import-export between Iran and China for 8 years’. The same advert
provides the location of MTS’s Beijing office – at Room 417, Lee World, 57 Xing Fu Zhong Lu,
Chaoyang District14
– as well as an MTS contact in Beijing, Hamidreza Afzalian.
The individual named Hamidreza Afzalian or Hamidreza Afzalian Shirvan, has a substantial digital
footprint that confirms his association with MTS, and also suggests that he currently resides in
Beijing (see below).
10
‘Final report of the Panel of Experts established pursuant to resolution 1929 (2010),’ p. 38,
http://www.un.org/ga/search/view_doc.asp?symbol=S/2014/394, accessed 26 August 2014. 11
Minaye Tejarat Sanabad, http://minayetejarat.com/index.html, accessed 27 August 2014. 12
Web Analyzer, ‘minayetejarat.com,’ http://wa-com.com/minayetejarat.com, accessed 27 August 2014. 13
Facebook, ‘Farshid Bidooee,’ https://www.facebook.com/farshid.bidooee/about, accessed 27 August
2014. 14
MakePolo, ‘Minaye Tejarat Sanabad,; http://1343037.en.makepolo.com/informations/Minaye-Tejarat-
Sanabad-Co., accessed 27 August 2014.
9
(Sources: https://www.facebook.com/hamid.afzalian; https://enreg.reestri.gov.ge/main.php?c=mortgage&m=get_output_by_id&scandoc_id=546719&app_id=624394;
http://irbccn.com/core/wp-content/uploads/2013/11/IBCC-Members2.pdf; http://www.nanotejarat.com/index.php?div=private&page=534&sample=2§ion=contact&lan=2)
10
As the Wisconsin Project on Arms Control’s Iran Watch website has noted, in addition to Afzalian’s
interest in MTS, Afzalian is also director and majority shareholder in another company, Hong
Kong Pioneer International, which is registered in Hong Kong and Georgia.15
Georgian registration documents obtained by Project Alpha show that the Georgian branch of
Hong Kong Pioneer International was incorporated on 13 June 2013, some six months after the
seizure of carbon fibre in Singapore. These documents also provide Afzalian’s passport, which
notes his country of residence as China.
(Source: https://enreg.reestri.gov.ge/main.php?c=app&m=show_app&app_id=623863)
A business registry site shows that the Hong Kong branch of Hong Kong Pioneer International was
registered some time before September 2012.16
Documents obtained by Alpha show that as of
September 2013, the three shareholders of that company were Afzalian, Amir Bidouyi/Bidouei and
an individual named Farnoosh Bidouee (see below).17
15
Iran Watch, ‘Carbon Fiber Seized En Route to Iranian Businessman With Ties to Georgia and Hong
Kong,’ 20 August 2014, http://www.iranwatch.org/our-publications/international-enforcement-
actions/carbon-fiber-seized-en-route-iranian-businessman-ties-georgia-hong-kong, accessed 27 August 2014. 16
Cyber Search Centre of the Integrated Companies Registry Information System (ICRIS),
http://www.icris.cr.gov.hk/csci/, accessed 27 August 2014. 17
‘Annual Return – Hong Kong Pioneer International Co., Ltd,’ 11 September 2013, Cyber Search Centre of
the Integrated Companies Registry Information System (ICRIS), http://www.icris.cr.gov.hk/csci/, accessed
27 August 2014.
11
(Source: http://www.icris.cr.gov.hk/csci/)
While Amir Bidouyi/Bidouei and Hamidreza Afzalian are known to be associated with MTS, the
identity of Farnoosh Bidouee is less clear. Online records refer to an acupuncturist named
Dr Farnoosh Bidouee, who practises at an address in Mashhad and apparently studied recently at a
university in Beijing.18
It is unknown whether this is the same person as the third shareholder in
Afzalian’s Hong Kong company.
18
Dabi.ir, ‘Dr Farnoosh Bidouee,’
http://translate.googleusercontent.com/translate_c?depth=1&hl=en&prev=/search%3Fq%3D%2522%25D8
%25AF%25DA%25A9%25D8%25AA%25D8%25B1%2B%25D9%2581%25D8%25B1%25D9%2586%25D9%
2588%25D8%25B4%2B%25D8%25A8%25DB%258C%25D8%25AF%25D9%2588%25D8%25A6%25DB%2
58C%2522%26sa%3DX%26biw%3D1280%26bih%3D913&rurl=translate.google.co.uk&sl=fa&u=http://ww
12
5. The supplier
The Panel of Experts report states that shipment of seized carbon fibre originated in China, but the
Panel has not publicly identified the seller in China, nor the pathway by which the material came
to that seller from the Japanese manufacturer, Toray. A Japanese media outlet has stated that
Toray ‘exported the carbon fibers through appropriate channels to China.’19
Project Alpha has not been able to identify using open source information the Chinese seller of the
seized carbon fibre. It is possible that the carbon fibre changed hands more than once in China after
being exported from Japan by Toray.
While the Chinese seller of the seized carbon fibre remains unknown, the export of Toray
high-grade carbon fibre from China is likely a common practice. China probably has hundreds – if
not more – firms who use Toray carbon fibre tow as an input to weave carbon fibre fabrics or to
make other carbon fibre or composite structures, from golf clubs to aircraft bodies. Some of this
tow may end up sold as surplus; some is probably exported.
At least two Chinese carbon fibre fabric manufacturers – Shanghai Horse Construction Company
and Yixing Yitai Carbon Fibre Weaving Company – have adverts on an English-language trade
website that apparently offer for export tow material very similar to the type seized in Singapore.
An advert belonging to Shanghai Horse Construction Company apparently offers T700K-24K tow
with an ‘MOQ’, or medium order quantity, of ‘1 bobbin (6kg)’.20
An advert belonging to Yixing
Yitai apparently offers T700-12K tow packaged ‘6 roll one carton’, with a minimum order quantity
of 100kg. 21
It is not known whether these companies actually sell or export tow, as opposed to
fabric, but carbon fibre fabric is usually sold by length; carbon fibre tow is usually sold by weight.
And both companies list these apparent offers under a separate product category to their carbon
fibre fabrics.22
Within China, it seems that there is a thriving re-sale market for high-grade carbon fibre tow made
by Toray. A search of a Chinese-language domestic trade website apparently shows a number of
sellers offering Toray T700-grade carbon fibre tow.23
(Generally, a surfeit of carbon fibre might be
expected given recent slow-downs in Chinese industrial production.24
) These adverts do need to be
considered with caution, though. Some ostensible sellers may be false or unable to actually supply
Toray T700 material. Counterfeiters have been known to pass off other brands and strengths of
w.payamsara.com/10342193.html&usg=ALkJrhhS4xkvd_N6CYtwkNAkZo3kFYRWQQ, accessed 27
August 2014. 19
Kyodo News, ‘Heap of Japanese carbon fiber bound for Iran seized, U.N. report,’ 14 June 2014,
https://english.kyodonews.jp/news/2014/06/295778.html, accessed 26 August 2014. 20
http://shhorse.en.alibaba.com/product/1772618332-0/JAPANESE_MADE_t700_24K_carbon_fiber.html,
accessed 19 September 2014. 21
http://yttxw.en.alibaba.com/product/805490404-
214932400/carbon_fiber_12K_carbon_fiber_Toray_T700_12K_carbon_fiber.html, accessed 19 September
2014. 22
Project Alpha does not suggest that Shanghai Horse Construction Company or Yixing Yitai Carbon Fibre
Weaving Company were involved in any way with the carbon fibre that was seized in Singapore, nor are we
suggesting that they have been involved in any illicit activity whatsoever. 23
http://s.1688.com/selloffer/offer_search.htm?keywords=%B6%AB%C0%F6%CC%BC%CF%CB%CE%A
C+%B9%A9%D3%A6%B6%AB%C0%F6T700+%CC%BC%CF%CB%CE%AC24K+&button_click=top&
earseDirect=false&n=y, accessed 19 September 2014. 24
‘A test of will,’ The Economist, 20 September 2014, http://www.economist.com/news/finance-and-
economics/21618913-after-sharp-slowdown-stimulus-back-agenda-test-will, accessed 19 September 2014.
13
carbon fibre as Toray T700. At the very least, though, these advertisements appear to demonstrate
that there is a ready supply in China of Toray high-strength carbon fibre whose provenance may
not be easily assured or traceable.
Intriguingly, some of these sellers use in their advertisements – as does Shanghai Horse
Construction Company25
– a picture of Toray boxes with partly-excised labels. These boxes and
labels are similar to those that were examined by the Panel of Experts (see below).
While interesting, this is a frustrating lead. Because the photograph has been ‘borrowed’ by so
many sellers, it is impossible to tell which company or companies in China have actually had
custody of the boxes shown in the image. And, of course, these boxes may not be linked at all to
the material that was seized in Singapore.
6. The shipping company and vessel
Both the shipping company and vessel involved in the attempted carbon fibre shipment are closely
associated with – if not part of – Iran’s national shipping line, the Islamic Republic of Iran Shipping
Lines (IRISL).
The Panel of Experts report does not name the shipping company identified on the carbon fibre
shipment’s bill of lading, but states that the address and fax number of that company identified the
firm as being associated with South Shipping Line Iran (SSL). SSL has been named by multiple
authorities as an IRISL entity. In 2008, the US Treasury designated SSL as being ‘owned or
controlled by or acting or purporting to act for or on behalf of, directly or indirectly, IRISL.’26
In
25
http://shhorse.en.alibaba.com/product/1772618332-0/JAPANESE_MADE_t700_24K_carbon_fiber.html,
accessed 19 September 2014. 26
US Treasury, ‘Major Iranian Shipping Company Designated for Proliferation Activity,’ 10 September 2008,
http://www.treasury.gov/press-center/press-releases/Pages/hp1130.aspx, accessed 27 August 2014.
Detail of torn label of T700 carbon fibre
box from Singapore seized shipment.
Source: Panel of Experts
Toray T700 boxes with torn label
advertised by Chinese sellers.
Source: Trading website
14
2010, UN Security Council Resolution 1929 also sanctioned SSL and declared it to be ‘owned,
controlled, or acting on behalf of’ IRISL.27
The Shahraz, too, is an IRISL ship. The Panel named the vessel’s owner as Kish Roaring Ocean
Shipping Company PJS (Private Joint Stock), a company the Wall Street Journal in August 2011
identified as an IRISL front.28
Indeed, prior to the Singapore seizure, the Shahraz – under its
International Maritime Organisation (IMO) number, 9349576 29
– had been sanctioned under US
and EU designations for belonging to IRISL. (The US sanctioned the vessel in December 2010;30
the EU in May 2011.31
) However, following those measures, the vessel – originally named First
Ocean when it first sailed in 2008 – had its name and flag changed twice, most likely to try to
thwart the sanctions.32
7. The end-user
While much can be gleaned about many of the entities involved in this attempted shipment, the
same cannot be said about the intended end-user of the seized carbon fibre. The Panel of Experts
did not publicly identify the end-user, and may not know who it is. Project Alpha has not been able
to identify where the carbon fibre was destined for. It is unclear whether the material was bound
for Iran’s uranium enrichment programme, its missile programmes, aerospace efforts or another use
entirely – perhaps even a civil one, such as the manufacture of composite compressed natural gas
tanks.33
The Panel of Experts states that Iran is known to have attempted to procure high-grade
carbon fibre for use in manufacturing centrifuge rotors, but acknowledges too that such material
also has a number of commercial applications, particularly in the aerospace industry.34
If used for centrifuge rotor manufacturing, the quantity of carbon fibre seized would have been
sufficient to produce a very large number of centrifuges – most likely in the thousands of machines.
Experts consulted by Alpha suggest Iran’s carbon fibre rotor centrifuges most likely use about 1kg
of carbon fibre per machine. More conservative estimates – such as the one adopted by the
Washington Post in a different illicit procurement case – put the amount at just over 2kg of carbon
27
UN Security Council, Resolution 1929 (2010) (S/RES/1929), http://daccess-dds-
ny.un.org/doc/UNDOC/GEN/N10/396/79/PDF/N1039679.pdf?OpenElement, accessed 27 August 2014. 28
Claudia Rosett, ‘Tehran’s Ghost Fleet,’ The Wall Street Journal, 29 August 2011,
http://online.wsj.com/news/articles/SB10001424053111904875404576529860210045514, accessed 27 August
2014. 29
‘Shahraz,’ Marine Traffic,
http://www.marinetraffic.com/en/ais/details/ships/9349576/vessel:SHAHRAZ, accessed 26 August 2014. 30
US Treasury, ‘Recent OFAC Actions,’ http://www.treasury.gov/resource-center/sanctions/OFAC-
Enforcement/Pages/20100616.aspx, accessed 26 August 2014. 31
‘Council Implementing Regulation (EU) No 1245/2011 of 1 December 2011 implementing Regulation (EU)
No 961/2010 on restrictive measures against Iran,’ EUR-Lex, http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2011.319.01.0011.01.ENG, accessed 26 August 2014. 32
‘SHAHRAZ - 9349576 - CONTAINER SHIP,’ Maritime Connector, http://maritime-
connector.com/ship/marisol-9349576/, accessed 26 August 2014. 33
Chris Red, ‘The outlook for composite pressure vessels,’ Composites World, 22 January 2009,
http://www.compositesworld.com/articles/the-outlook-for-composite-pressure-vessels, accessed 27 August
2014. 34
‘Final report of the Panel of Experts established pursuant to resolution 1929 (2010),’ p. 14,
http://www.un.org/ga/search/view_doc.asp?symbol=S/2014/394, accessed 26 August 2014.
15
fibre per centrifuge.35
Taking into account factors including waste and likely faults during the rotor
manufacturing process, the actual required amount is probably somewhere between these two
figures.
On this basis, the seized material would have been sufficient for no less than 3,500 centrifuges and
perhaps as many as 7,600 centrifuges. This figure dwarves the number of composite-rotor
centrifuges that Iran currently has in its declared enrichment facilities. As of August, according to
the IAEA, Iran has 1,008 carbon fibre-rotor36
IR-2M centrifuges installed in its underground
Natanz Fuel Enrichment Plant, with a further 163 IR-2Ms and 188 carbon fibre-rotor37
IR-4
machines installed in the above-ground Natanz Pilot Fuel Enrichment Plant. (A further eight or so
advanced centrifuges which may use carbon fibre rotors are also installed there.)38
Another indication of the scale – and, potentially, the importance – of the seizure can be found by
comparison with Iran’s underground Fordow uranium enrichment facility, which is designed to be
capable of holding just under 3,000 centrifuges. 39
40
(As of August, according to the IAEA,
Fordow has 2,710 IR-1 aluminium-rotor centrifuges installed.41
) A shipment of 7,200kg of high-
strength carbon fibre could, therefore, easily supply enough carbon fibre to outfit a Fordow-sized
uranium enrichment facility with composite-rotor centrifuges – and perhaps even two facilities
equivalent to Fordow.
Missile parts – such as fins and airframes – are another potential use for the interdicted carbon fibre.
While known information provides no indication of ties in this case to Iran’s missile programmes,
Iranian ballistic missile entities have reportedly been interested in obtaining high-strength Toray
carbon fibre. In mid-2007, according to a leaked US cable, an Iranian entity provided specifications
for Toray T800HB-6000 and T800HB-12000 carbon fibre to an entity affiliated with Iran’s
ballistic missile program.42
(Toray T800-grade carbon fibre has a slightly higher ultimate tensile
strength than T700 material.43
)
35
Michael Birnbaum and Joby Warrick, ‘A mysterious Iranian-run factory in Germany,’ 15 April 2013,
http://www.washingtonpost.com/world/europe/a-mysterious-iranian-run-factory-in-
germany/2013/04/15/92259d7a-a29f-11e2-82bc-511538ae90a4_story.html, accessed 27 August 2014. 36
‘Final report of the Panel of Experts established pursuant to resolution 1929 (2010),’ p. 16,
http://www.un.org/ga/search/view_doc.asp?symbol=S/2014/394, accessed 26 August 2014. 37
David Albright and Christina Walrond, ‘Iran’s Advanced Centrifuges,’ http://isis-online.org/isis-
reports/detail/irans-advanced-centrifuges, accessed 27 August 2014. 38
IAEA Board of Governors, ‘Implementation of the NPT Safeguards Agreement and relevant provisions of
Security Council resolutions in the Islamic Republic of Iran,’ 5 September 2014, GOV/2014/43, http://isis-
online.org/uploads/isis-reports/documents/gov-2014-43.pdf, accessed 16 September 2014. 39
IAEA Board of Governors, ‘Implementation of the NPT Safeguards Agreement and relevant provisions of
Security Council resolutions in the Islamic Republic of Iran,’ 5 September 2014, GOV/2014/43, http://isis-
online.org/uploads/isis-reports/documents/gov-2014-43.pdf, accessed 16 September 2014. 40
David E. Sanger and William J. Broad, ‘Iran Said to Nearly Finish Nuclear Enrichment Plant,’ 25 October
2012, http://www.nytimes.com/2012/10/26/world/middleeast/iran-said-to-complete-nuclear-enrichment-
plant.html, accessed 27 August 2014. 41
IAEA Board of Governors, ‘Implementation of the NPT Safeguards Agreement and relevant provisions of
Security Council resolutions in the Islamic Republic of Iran,’ 5 September 2014, GOV/2014/43, http://isis-
online.org/uploads/isis-reports/documents/gov-2014-43.pdf, accessed 16 September 2014. 42
US State Department, ‘Iranian ballistic missile program’s interest in procuring Japanese-origin carbon
fibers,’ 23 June 2008, https://wikileaks.org/plusd/cables/08STATE67220_a.html, accessed 16 September
2014. 43
Torayca, ‘T800 data sheet,’ http://www.toraycfa.com/pdfs/T800HDataSheet.pdf, accessed 27 August
2014.
16
8. Analysis and lessons
This case highlights a number of lessons in the export control and non-proliferation domains.
8.1 The value of interdictions
Interdiction is an activity that can be unfruitful, fraught with risk, and sometimes even dangerous.
Not all interdictions are worth the effort – particularly those involving easily-obtainable dual-use
goods with uncertain end-users. But the Singapore seizure demonstrates the value that particular
interdictions can have: in this case, sufficient carbon fibre to potentially outfit a Fordow-size
uranium enrichment facility with centrifuges was prevented from reaching Iran.
8.2 Cradle-to-grave risks involved in proliferation-sensitive materials
The seized carbon fibre in this case re-sold at least once in China (and possibly more times) without
the consent of the manufacturer, Toray. Toray conducted its own investigation into the matter and
provided its findings to the Panel of Experts, along with suggestions for countermeasures against
misuse of its goods.44
Dual-use materials and technologies with proliferation-sensitive utility, such as high-strength
carbon fibre, are often very tradable commodities. End-use agreements and other legal measures –
even those specifically prohibiting re-sale – may not be sufficient to prevent diversion to illicit
programmes. Wherever practicable, antiproliferation practices like those of the instrumentation
company MKS, which has implemented a ‘Controlled Delivery Model’ that allows goods to be
only shipped to ultimate end-users (see
http://www.kcl.ac.uk/sspp/departments/warstudies/research/groups/csss/pubs/beyondcomplianc
e.pdf), are recommended to help ensure that sensitive goods are not diverted.
8.3 Adaptability of procurers
The network associated with Hamidreza Afzalian – like those of many involved in the trade of
dual-use goods – has shown to be adaptable and resilient. The loss of the seized cargo of carbon
fibre – conservatively valued at about $150,00045
– does not appear to have stopped Afzalian’s
business activities. Rather, Afzalian has established a new company in Georgia and apparently
continues to conduct business from Beijing.
8.4 IRISL’s continued role in proliferation-related trade
Despite various counter-proliferation measures against it, Iran’s national shipping line IRISL
continues to assist the supply of dual-use goods to Tehran. EU and US designations against IRISL
and even the designation by IMO number of the vessel Shahraz did not stop its passage from
China; these measures, though, may have assisted interdiction efforts in Singapore. Probably only
UN sanctions against IRISL would be sufficient to stop the shipping line’s proliferation-related
activities.
8.5 Value of Panel of Experts reports
The information provided in the June 2014 Panel of Experts report has been critical to the
production of this paper. More broadly, information made public by the Panel assists civil society to
44
Correspondence from Toray’s Carbon Fibre Business Division to Project Alpha, 4 September 2014. 45
Using approximate price of $20 per kg.
17
better characterise global proliferation networks, which in turn helps the private sector and
governments better assess proliferation risks.
18
www.acsss.info
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