A week ago, the State Department announced the imposition of sanctions for alleged supply of WMD and missile-related technology or destabilizing conventional weapons systems in accordance with the provisions of the Iran, North Korea and Syria Nonproliferation Act (P.L. 109-353). Sanctions were levied against 13 entities from seven countries, as this Global Security Newswire story summarized. And Russia’s Rosoboronexport got sanctioned for dealing with Iran again.
In October’s ACT, Wade Boese offered up a great analysis of the Bush administration’s nonproliferation sanctions policy complete with some neat quotes on sanctions aficionado and the darling of this blog, John Bolton. But because Wade’s article chiefly focused on sanctions of Chinese and Iranian entities, I wanted to write something about the sanctions levied against Russian entities for their trade with countries of concern.
What bugs me here is State’s timing of the sanctions. In a true John Bolton fashion, the Russians got poked in the eye just as they were gearing up to talk START with State. Belatedly sanctioning Russia’s state conventional arms intermediary Rosoboronexport for a transfer of a short range air defense system that was completed in early 2007 seems silly. Yet, this latest imposition notwithstanding, an analysis of the number of State’s sanctions against Russian entities during the last eight years delivers surprising results.
The Russians Say Grrr…
The Russian response to last week’s sanctions determination was quite predictable.
In a 24 October release rus, Rosoboronexport complained that by imposing sanctions, the U.S. was engaging in “unfair competition.” And President Dmitriy Medvedev clearly followed the company’s talking points when he used the same “unfair competition” line a few days later.
However, the Russian Ministry of Foreign Affairs’ official release and Sergey Lavrov’s personal reaction were more colorful.
We consider this absolutely unacceptable, as our entire trade and economic activities in Iran and military-technical cooperation with that country are strictly compliant with the norms existing in international law, with our international obligations and with the export control regime currently in force in Russia. Here there can be no explanations other than another instance of arrogant application by the United States in an exterritorial manner of its national American laws. If it seems to some people in Washington that the US will thus make Russia more pliant towards accepting the American approach to resolving the Iranian nuclear problem, this is a mistake.
The story got nice press coverage. WaPo’s Glenn Kessler even picked up on the peculiar fact that State apparently “granted [Rosoboronexport] a partial waiver to permit the sale of nearly two dozen Russian helicopters to Iraq.” This fact, by the way, was not mentioned by Russian officials or brought up in Russian press coverage.
However, Kessler’s story (along with many others) did not discuss what triggered the sanctions on Rosoboronexport. Kessler surprisingly settled for a non-response from State, writing that State officials “declined to specify why the companies were placed on the list, saying the reasons are classified.”
What Was Transferred and When?
The reason for the sanctions actually seems quite boring. The same Rosoboronexport press release rus, which got cited aplenty for the “unfair competition” line, says that
The decision of the State Department was triggered by Russia’s transfer of the 29 Tor-M1, which supposedly disrupted the balance of forces in the region, and could potentially threaten U.S. forces… The appearance of the Tor-M1 in Iran doesn’t do more than allow for enhancing the protection of most critical small-scale facilities of state and military administration, elements of infrastructure (including nuclear energy, chemical manufacturing, and electrical power stations) from precision weapons strikes.
What Rosoboronexport meant to say by issuing this clarification was that the Tor-M1 was the only thing the company had transferred since it was last sanctioned by State in December 2006. Thus, it had not (yet?) transferred the mighty S-300 to Iran.
On the face of it, State’s wrath for the seemingly defensive Tor-M1 is also not unusual. For about a decade, they’ve been compelled to sanction the Russians for every defense item ever sold — and not sold — to the Iranians. Yet, the Tor-M1 transfer was completed as far back as January 2007. The Russians were even preparing to get punished for the transfer that same month. Surprisingly, though, the sanctions didn’t come until a year and half later.
What’s the Deal With State’s Timing?
Short answer: Dunno. But I wonder…
It’s been pointed out to me that there is a bureaucratic delay between the time a determination is made that a transfer potentially punishable under U.S. law has occurred and the time the imposition of the sanctions is actually announced. Thus, it is quite plausible that the January 2007 transfer of the Tor-M1 was completed too late for State to punish Rosoboronexport as part of the April 2007 round of Iran and Syria Nonproliferation Act sanctions, the only round that seems to have preceded the October 2008 one.
But why haven’t we seen more rounds of Iran and Syria (and North Korea) Nonproliferation Act sanctions since April 2007? And does this have anything to do with a possible reshuffle in the Department of State’s bureaucracy as related to the imposition of sanctions? Just looking at the Federal Register notice, it’s quite clear that the point of contact is now at the Bureau of Verification, Compliance and Implementation instead of the usual Bureau of International Security and Nonproliferation.
The Russians were certain to growl about the sanctions. Yet, State officials had to have known that due to Moscow’s interest in re-starting START, there wouldn’t have been any unexpected policy shifts. And by imposing the sanctions now, some at State might have figured that the Russians would easily swallow them as a farewell present from the departing politicos.
A Concluding Note on Russian Proliferation Trends
If instances of sanctions are to be held as any determinant of State’s perception of Russian proliferation trends, then here are the stats (conventional and WMD-related technology sanctions combined):
For purposes of comparison, during a 1998-1999 Congressional sanctions binge, a total of 14 Russian entities were sanctioned.
Yet, during and after the John Bolton sanctions spree, the record of sanctions on Russian entities and individuals was as follows: three times in 2002, just once in 2003, five times in 2004, five times in 2006 (sanctions on Sukhoy were lifted), zero in 2007, and just once in 2008 (the latter for the Tor-M1, transferred in 2007).
Seems to me the Russian record of proliferation to countries of concern, and Iran in particular, is today less of a cause for concern, at least according to the State Department. And this, of course, is a very positive thing.

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