From September 1990 to September 1991, the U.S. Department of Commerce approved nearly $60 million dollars’ worth of sensitive exports to Iran. Most of these items were “dual use,” meaning that in addition to their civilian uses, they can be used to make nuclear weapons, long-range missiles or other military equipment. The record of these exports has just become available.
The Commerce Department granted these licenses despite Iran’s “terrorism” status under U.S. export law. For several years U.S. regulations have designated Iran as having “repeatedly provided support for acts of international terrorism.” As a result, the regulations provide that export licenses to Iran “will generally be denied” for a specific list of sensitive items. This amounts to a denial rule for items on that list.
From 1990 to 1991, however, the Commerce Department licensed the export of millions of dollars’ worth of these very items. The Commerce Department does not appear to be following its own regulations, and therefore is not implementing the U.S. policy against international terrorism.
Commerce approved one of these exports over the opposition of the State Department and another over the opposition of the Defense Department. Commerce also approved several other cases after either State, Defense or the Department of Energy recommended that the application “return without action.” According to a knowledgeable Defense Department official, “return without action” is usually a polite denial for a country like Iran. The government has information showing that the license should not be granted, but does not want to say so publicly with a rejection. The RWA is a polite way of informing the exporter of this fact. The unspoken implication is that the application will be rejected if submitted again. Applications may also be returned without action because the file is incomplete or because the application was filed for an item that does not require a license.
In the past, Commerce has deferred to the recommendations of State, Defense and Energy on dual-use licensing. These latter agencies, rather than Commerce, possess the diplomatic and strategic expertise to decide whether an export might be diverted to A-bomb or missile production. Now a new pattern has appeared: Commerce can ignore the judgement of other agencies in order to promote exports.
The following discussion is organized according to the items Commerce approved for export. Computers, the first category, have a number of military uses depending on their speed and configuration. They can powerfully aid in the design, development, and testing of both nuclear weapons and long-range missiles. Navigation, direction-finding and radar equipment, the second category, is necessary for missile guidance and military targeting. Oscilloscopes, the third category, are high-speed electronic diagnostic instruments that can be used to develop missile guidance systems and to process the rapid signals from nuclear weapon tests. Compasses, gyroscopes and accelerometers, the fourth category, are also necessary for missile guidance systems.
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Exports and Terrorism: U.S. Export Licenses to Iran: September 1990 to September 1991