As part of the nuclear agreement with Iran, 36 entities will be removed from the United Nations blacklist when the deal is implemented next year. This represents about one-third of the entities on the U.N. list and covers entities that have been linked to undeclared nuclear work or illicit nuclear procurement. The removals also set in motion similar action by the European Union and the United States. The troubling result is that early on in the lifetime of the agreement, most of these entities may not appear on international screening lists.
The first round of U.N. sanctions relief will arrive on Implementation Day, the date when the International Atomic Energy Agency (IAEA) verifies that Iran has fulfilled its first set of nuclear-related commitments under the deal. This is expected sometime in 2016. This sanctions relief is not contingent upon the findings of the IAEA’s investigation into Iran’s alleged past nuclear weapons work. And it will come well before the Agency has completed its longer-term assessment of Iran’s nuclear program and gives it a clean bill of health—the so-called “Broader Conclusion” that “that all nuclear material in Iran remains in peaceful activities.” This conclusion will be reached only if Iran is fully cooperative with inspectors, has resolved concerns about its past nuclear activities, and addresses all of the Agency’s questions about its ongoing nuclear program.
In addition to removal from the U.N. list, these 36 entities will also be cleared from the European Union blacklist on Implementation Day. And all but one of these entities will no longer be covered by U.S. secondary sanctions, meaning that non-U.S. entities may do business with them without risk of being sanctioned by the United States.
The majority of delisted entities are Iranian government officials and nuclear scientists and engineers (20). Removals also include nuclear research and production facilities (11), subsidiaries of Iran’s national shipping company (3), and the Malaysian branch of Iran’s Bank Mellat.
The initial set of removals from the U.N. list includes the Atomic Energy Organization of Iran (AEOI), the main Iranian organization for research and development in the field of nuclear technology. The AEOI and its subsidiaries have been repeatedly linked to undeclared nuclear work and illicit procurement. In addition to the AEOI, the following are the key nuclear-related entities in Iran among the 36 individuals and organizations that will be de-listed by the U.N. on Implementation Day.
- Esfahan Nuclear Fuel Research and Production Center (NFRPC) and Esfahan Nuclear Technology Center: The AEOI’s center for nuclear fuel development. It is the location of a conversion plant that produces the feedstock for uranium enrichment and of laboratories used for nuclear reactor fuel fabrication. This facility was used by Iran for undeclared work with uranium compounds in the 1980s and 1990s and to store suspicious heavy water and equipment used in undeclared plutonium separation experiments.
- Jabber Ibn Hayan: An AEOI department involved in nuclear technology training and located at the Tehran Nuclear Research Center. The location of undeclared uranium conversion experiments, including the production of uranium metal. Iran used the laboratory to separate irradiated reactor fuel and as a storage location for separated plutonium. This laboratory was also part of Iran’s undeclared laser enrichment program.
- Karaj Nuclear Research Center (aka Nuclear Research Center for Agriculture and Medicine): Part of the AEOI research division. Karaj has been linked to the procurement of vacuum pumps and mass spectrometers and has also been linked to laser and centrifuge enrichment activities. It was the storage location for a large vacuum vessel and dismantled equipment from a laser enrichment pilot plant. The Center also serves as a radioactive waste storage facility.
- Kavoshyar Company: A subsidiary of the AEOI involved in nuclear procurement. According to the United Nations, the company sought “glass fibres, vacuum chamber furnaces and laboratory equipment for Iran’s nuclear programme.” It has also tried to procure vacuum pumps and mass spectrometers and is a supplier of nuclear testing equipment to other entities in Iran.
- Mesbah Energy Company: An AEOI subordinate linked to illicit procurement for Iran’s IR-40 heavy water reactor at Arak. It has repeatedly attempted to procure export controlled nuclear equipment for the reactor, including valves and gauges, pressure switches, cooling towers, and steam traps.
- Modern Industries Technique Company (MITEC): An AEOI subordinate responsible for the design and construction of the IR-40 heavy water reactor in Arak. The company “spearheaded procurement” for the reactor, according to the United Nations. The United States will keep MITEC under sanctions, both primary and secondary, until eight years after the nuclear deal takes effect.
- Novin Energy Company: A company that operates within AEOI and has transferred millions of dollars on behalf of the AEOI to entities associated with Iran’s nuclear program.
- Pars Trash Company: A subsidiary of the Kalaye Electric Company, which was the primary site for Iran’s secret uranium enrichment program between 1997 and 2002. The company also acts on behalf of the AEOI and was used as a storage site for centrifuge components, including some with traces of highly enriched uranium.
- Pishgam (Pioneer) Energy Industries: The main consulting engineer for the AEOI, providing engineering and technical support for AEOI projects. It participated in the construction of the Uranium Conversion Facility at Esfahan, a yellowcake production plant, and a nuclear fuel manufacturing plant, among other projects.
- Tamas Company: An entity involved in uranium-enrichment activities that oversees four subsidiaries involved in uranium mining and milling, uranium processing, uranium enrichment, and radioactive waste.