Anya LoukianovaBoltonesque Sanctions on Rosoboronexport

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.


  1. Yossi

    Why now?

    I think you can’t understand neocon thinking without the absolute dominance concept. Dominance is being able to influence the other in the way you want by trading interests with him etc. Absolute dominance is influencing the other side against its will.

    Neocon thinking is authoritative and coercive so they always strive for absolute dominance and undervalue the non-absolute type.

    How do you go about implementing absolute dominance ? You poke the other side in the eye before you start talking then try to pressure him to swallow this. If you succeed you achieved it.

  2. Pieter

    The speculation about State dept changing its behaviour is al very interesting, but a few critical comments are in place.

    1) states: ‘In early January 2007, the United States announced that it had imposed trade sanctions against 24 entities from several countries under Section 3 of the Iran and Syria Nonproliferation Act. The list of sanctioned entities included RosOboronExport. The sanctions, will be applied for a period of two years.’

    That sanction therefore would run out early 2009 and Rosoboronexport would not appear in the April 2007 determination because it was still under sanction of an earlier determination. So where is the bureacratic delay which is the core of this blog entry?
    Or am I missing something?

    2) The Russian GRRRR about the sanctions being ‘unfair competition’ and ‘another instance of arrogant application by the United States in an exterritorial manner of its national American laws’ does not move me very much and is just part of the usual Russian government whining about any restraints on arms trade which may hinder Russian arms exports being sinister plots by competitors to push Russia out of the arms market. The sanctions mean that Rosoboronexport cannot do business with US government agencies because Rosoboronexport is doing business with Syria, Venezuela or Iran. That is all. The sanctions do not involve any intercepting of Russian weapons on their way to to countries the USA is embroiled with or other direct actions such as blocking Rosoboronexport bank accounts in the USA to halt such supplies, are hardly extraterritorial and from the US government perspective quite understandable. (By the way the Russian helicopters for Iraq would fall under the sanctions because the US is involved in the procurement of those.) US companies are not allowed to do military business with Syria, Iran or Venzuela, so in a way the US government was unfair to its own industry until it demanded the same restraints from foreign companies it could potential do business with.
    The Russian complaints are hardly convincing in the light of its own lashing out towards countries supplying arms to Georgia. Putin’s own quote of he year, from early October, on the matter: ‘I think that there could not be a greater crime against the Ukrainian and Russian peoples than arms deliveries to the conflict zone.” The Russian government appears as neocon as the US government.

    3) It is also important to note that we really do not know what triggered the sanction, despite the fact that Rosoboronexport claims it does. Rosoboronexport may claim that the sanction relates to the TOR M1 air defence systems to Iran, but that can as well be propaganda aimed at creating an image of a harmless purely defence related relationship with Iran. The real reason for the determination might have been something completely different about which we can only speculate. May be it had to do with the rumours that Syria wants to buy Iskander SSMs? Or could it be related to the recent Iranian claim that it now has combat aircraft, which can fly 3000 kilometers without refuelling (regardless of the truthfellness of that claim) and earlier reports that Russian companies where upgrading Iranian combat aircraft. Or may be it relates to a delivery of components for ballistic missiles to either Iran or Syria we do not know anything about. Or may be its just a combination of all these factors?

  3. Anya L.


    Thanks for the comment!

    1. Multiple determination can be made on one entity and the duration can overlap (e.g. see 3 impositions in 2004 on NORINCO). When Rosoboronexport was sanctioned in December 2006 (the notice appeared in January 2007), it was already sanctioned under a July 2006 round.

    2. The Lavrov quote is nice, isn’t it? And last I checked one doesn’t get sanctioned for engaging in weapons trade with Venezuela.

    3. Maybe. But highly unlikely on all of your ideas.

  4. Pieter

    Thanks Anya,
    1. So what you are saying is that despite the still valid December 2006 determination you would have expected a specific determination regarding Rosoboronexport earlier as an explicit warning or statement towards Russia?

    2. You’re right, arms exports to Venezuela do not lead to US sanctions. I got confused by the fact that a Venezuelan company was also sanctioned under the same determination. Whatever its connection with Iran or Syria may have been.
    3. I still do not understand what makes you so convinced that (only) the TOR M1 delivery caused the determination? The Rosoboronexport press release is apparently the only and, considering the doubtful reliability of this source, rather meagre evidence for this assumption. Or do you know from other sources that the TOR M1 deliveries are the actual reason for the sanctions? I would be interested to know why you are so certain that the options I mentioned are so highly unlikely.
    To add to my may be’s, may be the sanction is related to the recent or on-going supply of Pantsyr SAMs to Syria in combination with negotations between Russia and Syria about contracts for a range of other weapons including combat aircraft?

  5. ataune (History)

    The only thing that came to my mind after reading your comment: if the next administration want to continue in this path then goodbye US-Iran coopertion and hello US global demise !! (You know that India and Brazil Foreign minister are in Iran right now don’t you ? and I guess you know that Iran’s number 2 executif – Davoodi – was meeting with Poutine yesterday)

  6. Anya L.

    Ataune, if you’re referring to my comment (not sure which one, though), I am somewhat sad that this is the way it came across. I certainly do not think any of those things, nor was I implying them.

    Pieter, thanks again for the follow-up questions.

    1.Indeed. But there is a general question here also — why haven’t there been additional impositions of sanctions under the Iran, Syria, and North Korea Nonproliferation Act since April 2007?

    2.I wasn’t saying that I am certain. I just find all of the scenarios you had described unlikely. (We can get into a discussion of what the Russians might or might not end up selling to the Syrians, but a lot of that would be a guessing game.)

    Bottom line: if I am wrong and if this sanctions designation for Rosoboronexport comes for something other than the Tor-M1 transfer to Iran, then I’d be quite happy that State gave the Russians a break on that one. And that they’ve finally started using more sophisticated tools than teh Google or their imagination. (Or, strike that, imagination is a good thing.)

  7. Pieter (History)

    Thanks for the explanation Anna.

    I don’t believe that in the case of monitoring arms transfers to Iran and Syria the US IC relies on Google. The case you refer to has to do with very sensitive intel related to highly secretive activities inside Iran, and as is mentioned in the blog entry, the googling excercise made sense in that particular case. (‘This actually makes sense: You have what you think is the real list, but you only nail people for whom you can make a public case.’) Trade in major arms is easier to monitor, if only because it is an international activity involving rather visible items and therefore much more difficult to keep secret.

    It would be very interesting for me to speculate based on open sources and some decent googling about what Russia is selling or may want to sell Syria and Iran.

    However the more pertinent to this debate on motives for the US sancyions is what the US state depeartment believes was delivered or believes was agreed to be delivered or believes was discussed to potentially to be delivered by Russia to Syria and Iran and which they felt was sufficient to legitimise sanctions. About that US government perception we do not have to speculate.

    From just published US government information it becomes clear that the US administration, presumbaly based on information gathered by the US intelligence services, believes or wants the world to believe that Russia has recently concluded some big arms contracts with Iran and Syria worth more than the TOR M1s for Iran or the Pantsyrs for Syria will have cost.

    Have a look at the CRS report ‘Conventional arms transfers to developing nations, 2000-2007’ at e.g.

    On page 42 and 53 you will find that the US government believes that during 2004-2007 Russia delivered arms worth USD 300 m to Syria and USD400 m to Iran and more important that Russia agreed to supply arms worth USD4900 m to Syria and USD 2100 m to Iran. There is alas no description of what is included in these alleged agreements and I have no way of verifying the information. (The delivery value of USD400 m for Iran seems by the way a bit low if it includes the TOR M1s)

    Just to be very clear about this, I personally have major doubts about these US government data. For example I doubt if the alleged agreements are actual contracts or merely possible contracts being discussed or MOUs which, as so often happens in arms trade, may not materialize.
    Still, the data show to me that the State department may believe there is more reason than just the TOR M1s for sanctioning Russia.

  8. Yossi

    Anya, I have a question that I think is relevant to the current discussion. It’s related to an issue that many ACW readers were interested in the past.

    Do you see any sanction the US government took to punish Syria or any another country for building the alleged Syrian nuclear reactor? I guess the connection between the crime and sanction may be explicit or implicit but you probably can estimate the degree of relatedness.

    I don’t have the expertise to do such analysis but it’s probably easy for you. I must warn you though that the answer may have implications on the reliability of US accusations against Syria and NK.

  9. Anya L.

    Pieter, I was joking on the reference to Google (I am very well aware that these are distinctly different situations). However, I was under the impression that Richard Grimmett’s report a) is based on open source information; b) is not necessarily representative of positions within the administration or the U.S. government as a whole (and is intended for the use by Congress first and foremost, though Grimmett has a big fan base outside of Congress); c) is not coordinated with the State Department in any way.

    Dear Yossi, great question, but I’ll have to think about this more carefully before responding.

  10. Pieter (History)

    Dear Anya,
    You are right regarding b and c. The CRS report is not the position of the US administration and is not coordinated with the State department. It is an independent CRS report. But at least as far as I can see and have understood, the report uses arms transfers data provided by government sources, i.e. intel organizations. All the tables and figures in the Grimmett report are given ‘U.S. Government’ as source.
    As far as I know only the information on specific deals and general analysis in the texts is from Grimmett and based partly on open sources. Grimmett gets the aggregate dollar values without being told details of the weapons which make up those figures. But I guess we have to ask Grimmett to be sure about what the report exactly is based on.

    Of course you are right that we cannot be sure that the State department has used the information which is the basis of the USD dollar figures in the report as the reason for its sanctions. May be the data is from the CIA and State department has different views for whatever reason. But to me it seems plausible they did use more or less the same information, and that they sanctioned Rosoboronexport believing that this entity was inlvolved in many more for the US unacceptable arms transfers or orders related to Syria and Iran than only the delivery of air defence systems to Iran almost 2 years ago.

    Finally a point related to Yossi’s question. In my understanding entities are under sanction because they have undertaken activities which can be linked to any WMD related activity in Iran or Syria. I presume that it will therefore be very difficult to assess if the sanctions are related to the alleged Syrian nuclear weapons project or its Chemical weapons activities.

  11. Ward Wilson (History)

    I think imagination is a good thing, too.