Export Control:
Review of export license applications

Strategic Goods Control

The quickest route to a nuclear, chemical or biological weapon for a rogue state or terrorist group would be to acquire a whole weapon or an adequate stock of the required material—such as highly enriched uranium and plutonium for nuclear weapons. History shows, however, that proliferants are willing to take a longer road, poaching on international commercial markets to acquire the equipment, technology, and facilities needed to build nuclear and other weapons of mass destruction capabilities on their own.

As long as the demand for weapons of mass destruction persists, there will be relentless efforts to acquire the needed technologies on the international commercial market. Export controls combat those efforts and delay proliferation programs by regulating the supply of strategic materials, equipment, and technology that could contribute to the spread of nuclear, chemical, and biological weapons and missile systems for their delivery.

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Methods Used to Evade Export Control

Supplier

• Some suppliers willing to export illegally, out of ignorance, for economic reasons, or to provide clandestine assistance
• Inaccurate or vague commodity descriptions complicate enforcement

Agent/Broker

• Foreign procurement networks obtain goods, often with circuitous buying patterns, and ship without license
• Disguises or falsifies the final recipient country and/or the end user
• Exploit countries with ineffective export controls and other loopholes

Intermediate Consignees

• Diversion in transit and smuggling
• Use of other enterprises and universities to acquire facilities, equipment, technology and training

End User

• Front companies – diversion to unknown ultimate end user
• Utilization of dual-use or uncontrolled commodities to obscure the actual use in a weapons program
• False end use statements, connections to activities of concern

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Proliferation Risk Analysis

Argonne’s Export Control Program conducts technical “proliferation risk analyses” for NNSA of export applications submitted to the Departments of Commerce, Energy, and State, and the Nuclear Regulatory Commission.

These analyses are particularly complex when they involve “dual-use” items that have legitimate uses but can also be used to create weapons of mass destruction.

The export control specialist must think like a detective to uncover false statements of the product's end use, mismatches between the product's technical specifications and its stated end use, end uses that don't make technical sense or are not consistent with the end user's activities, and other such clues pointing toward illicit procurement.

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