Category Archives: News and Events

A Terrorist’s Stockroom?: The Effectiveness of e-Marketplace Prohibited Item Policies

Christina Krawec, Research Associate (


In attempts to regulate the trade of hazardous materials used in explosives or weaponry, internet marketplaces such as eBay, Amazon, and Alibaba have all implemented seller policies on their sites. Alibaba, for example, has a list of 410 radioactive, poisonous, toxic, flammable, explosive, and ozone-depleting substances that are prohibited from being listed.[1] Some work has been done to illustrate that, despite these regulations, sellers are able to sell hazardous materials. For example, Raymond A. Zilinskas and Philippe Mauger established in a 2015 study that biotechnology of concern could be acquired by non-state individuals via Alibaba.[2] Similarly, eBay has a list of 16 “explosives precursors” that are also restricted.[3] Despite eBay’s efforts to prohibit these substances, listings for some can still be found. This study shows that eBay’s listing policies are not effective in deterring users from selling what the site considers to be hazardous material.


Table 1 shows the availability of eBay’s restricted explosives materials across eBay, Amazon, and Alibaba. A listing was included in this table if the advertised substance was over 95% pure (if the purity was listed and with the exception of hydrogen peroxide), and was included regardless of quantity, physical state (e.g. liquid or solid), or marketed use. Therefore, laboratory-grade and food-grade substances in small quantities were included. This was done because eBay’s policy does not provide detail regarding the nature of the prohibited substances; it simply lists the names of the restricted compounds. Furthermore, this study assumed that the listings were truthful about the product being sold, which may not have been the case. Listings were also only included in this table if their advertised material was in stock and available for any user to purchase.

Table 1: Listings of restricted explosives precursor materials as of 4 January 2017

Explosives precursor restricted by eBay Listings on eBay Listings on Amazon Listings on Alibaba
Aluminium/aluminum powder 4 10+ 1000+
Ammonium nitrate* 0 10+ 5+
Calcium ammonium nitrate 0 0 100+
Calcium nitrate 0 10+ 100+
Hydrogen peroxide above 12% weight by weight 0 10+ 100+
Magnesium nitrate hexahydrate 3 2 100+
Magnesium powder 0 0 100+
Nitric acid** 0 0 100+
Nitromethane 0 0 50+
Potassium chlorate 10+ 0 2000+
Potassium nitrate (saltpetre) 10+ 10+ 1500+
Potassium perchlorate 0 0 500+
Sodium chlorate 3 0 1000+
Sodium nitrate 4 8 2000+
Sodium perchlorate 0 0 300+
Sulphuric/sulfuric acid 6 10+ 700+

*Material also prohibited by Alibaba                                                        **Material also prohibited by Amazon                                                                 Note that there were hundreds, if not thousands, of results for some of these chemicals. The + indicates that at least that number of listings was found, but there were so many results that there may have been more.


For the purposes of this study, searching for the prohibited materials on Amazon and Alibaba serves as a comparison of availability. Amazon, in its listing policies, has a section on explosives, but does not discuss precursors. The page does, interestingly, list nitric acid as a prohibited hazardous material, but this is the only substance that has crossover with eBay’s list.[4] In addition, the only chemical in both Alibaba’s and eBay’s lists is ammonium nitrate. Otherwise, Alibaba has thousands of legitimate listings for explosives precursors. It is notable that these lists do not correspond with internationally-recognised control lists, including those published by the export control regimes.

For Amazon, there were more listings than were included in the table. These listings either had items that were “currently unavailable” in which there was no timeline for restocking, were temporarily sold out, or they were only available for purchase by Amazon Business accounts. For example, there were over ten listings for calcium nitrate available for any user to buy on Amazon. However, with an Amazon Business account, at least five more listings became available. If a non-state actor is able to fabricate a front company and successfully create an Amazon Business account, then this could be an effective means of opening more pathways for hazardous material acquisition.

The availability of these substances despite their restricted nature illustrates eBay’s need for further oversight and more detailed policies. While monitoring e-marketplace activity is difficult due to the size of the user base and speed of transactions, the current policy does not deter users from listing certain substances. One difficulty arises from the dual-use nature of these goods. For example, potassium nitrate (saltpetre) is used in the process of curing meat, but can also be used to make gunpowder. The question of controlling the sale of dual-use items has long been a challenge for the international export control regime. How can e-marketplaces prove that buyers are obtaining saltpetre for their cured pork and not for the development of explosives?


These observations lead to possible recommendations for the improvement of e-marketplace prohibition policies.

  1. At present, listed chemicals can be bought by anyone on eBay. If the site were to restrict certain substances from being bought by anyone without a registered business (as is the policy on Amazon), this might lower the possibility of an individual with ill intent to obtain an explosives precursor. However, implementation of this policy would require careful oversight: it could also restrict innocent users from acquiring these materials for legitimate purposes.
  2. eBay could consider adding more detail to its restricted product policy. Determining an allowed quantity and purity would make the policy clearer; adding a section describing the dual-use nature of the goods would also be informative to eBay users. Having clearer policies does not solve the issue, but more detail would at least provide education for the eBay community.
  3. Standardising naming conventions would allow e-marketplaces to more easily track prohibited chemicals being posted on the site. On Amazon, eBay, and Alibaba, chemicals can be found by their written name, their formula, or their Chemical Abstracts Service (CAS) identification number. In many cases, chemicals are only listed by their written name. There are so many variations to names that it would be easier to identify listings for specific substances if they were required to include a searchable CAS number as well. The e-marketplaces could also screen postings against lists of keyword terms. In addition to preventing listings where the item might be prohibited, such an approach could be used to identify account holders who are intent on engaging in prohibited activity. In this context, retailers could be encouraged to submit some form of “suspicious activity report” similar to those used in the financial sector.

The issue of selling weapons precursor materials online has no easy answers. However, increasing awareness of these issues and the imperfections in current policies allows further discussions to be made. The international export control regime will continue to struggle with the case of dual-use goods, and e-marketplaces should be aware of the difficulties they face as part of the ongoing challenge.

[1] “Prohibited Chemicals Reference,” Rules Center, 2016.

[2] Raymond A. Zilinskas and Philippe Mauger, “E‐commerce and biological weapons nonproliferation,” EMBO, 2015.

[3] “Hazardous, restricted, or regulated materials,” eBay Rules & Policies, 2017.

[4] “Hazardous & Dangerous Items,” Amazon Seller Central, 2017.


“Hazardous & Dangerous Items.” Amazon Seller Central. 2017. Accessed January 4, 2018.

“Hazardous, restricted, or regulated materials.” eBay Rules & Policies. 2017. Accessed January 4, 2018.

“Prohibited Chemicals Reference.” Rules Center. 2016. Accessed January 3, 2018.

Zilinskas, Raymond A., and Philippe Mauger. “E‐commerce and biological weapons nonproliferation.” EMBO reports 16, no. 11 (2015): 1415-1420.

eBay, Alibaba, and Amazon search engines and results.

Whitepaper: Entity Screening and Vessel Tracking for UN Sanctions

Click here to access the whitepaper: Use of Entity Screening and Vessel Tracking to Assist Implementation of UN Sanctions – a Whitepaper

Many of the UN sanctions placed against North Korea since its first nuclear test in 2006 impose restrictions on North Korean merchant shipping. Most recently, the Security Council voted unanimously on 5 August 2017 to impose its harshest-yet economic sanctions on North Korea, prohibiting exports of coal, iron, iron ore, lead, lead ore and seafood.

However, the latest UN Panel of Experts report on North Korea (S/2017/150 published on 27 February 2017) found that “implementation remains insufficient and highly inconsistent.” The report identified and gave examples of various denial and deception measures practiced by North Korea and made a number of recommendations. These included building a register of North Korean vessels and the aliases under which they operate; proactive work by flag registries to refuse services to vessels crewed or commanded by North Koreans; states taking on the responsibility to check if North-Korea-crewed vessels hold valid insurance; for greater vigilance around the import of proscribed North Korean goods.

All of this suggests that the availability of information on vessels in breach of sanctions against North Korea and the capabilities to obtain such information needs to improve. Improvements in these areas would assist the UN Sanctions Committee, individual Member States, and businesses in implementing UNSCRs.

For a number of years, vessels and shore-based maritime entities have used the Automatic Identification System (AIS), originally designed for collision avoidance. Since about 2010, AIS data has started to become publicly available on the internet, and this has given rise to a number of new applications and services, particularly in the field of vessel tracking and screening. This paper aims to assess the potential usefulness of entity screening and vessel tracking for sanctions compliance, implementation, and enforcement in three broad areas:

  • For the private sector (particularly banking, freight, or insurance) in its efforts to comply with export control and sanctions legislation;
  • For states in their work to prevent the facilitation and movement of illicit trade from, to, or across their territories;
  • And for intelligence analysts to improve the information available on illicit freight forwarding networks and methodologies.

The paper looks at a range of vessel screening and tracking resources. It restricts its scope to North Korea, although the entity screening and vessel tracking capabilities have relevance to sanctions in force against other countries of interest, and builds upon previous work undertaken by Project Alpha in partnership with the Australian government as published through the UN Security Council.

Final Report: Typologies of Proliferation Finance

Click  here to access the report: Study of Typologies of Financing of WMD Proliferation

Disrupting the financing of proliferation (FoP) is potentially a key tool to combat state-sponsored WMD programs. However, detecting FoP is difficult. The majority of governments and financial institutions are unclear about what FoP looks like and how to identify it, so the tool is rarely exploited. This report describes typologies of financing the proliferation of WMD to address this issue.

The most comprehensive study of FoP to date was published by the Financial Action Task Force (FATF) in 2008. This includes a list of 20 “indicators of possible proliferation financing,” including, for example, transactions connected with designated individuals or entities or with countries of proliferation concern. Since then, more information has become available, particularly related to the proliferation programs of DPRK and Iran.

Project Alpha has carried out an analysis of data relating to DPRK, Iran, Syria, Pakistan and India provided by governments and financial institutions, contained in records of judicial proceedings, UN Panel reports, and media reports. The analyses are summarized in the form of 60 case studies. They enable identification of common elements between networks set up to finance proliferation or to circumvent financial sanctions, and of ways networks may mutate in response to sanctions.

Based on the 60 cases, the indicators in the FATF 2008 Report have been modified and categorised as “potentially highly indicative,” “potentially moderately indicative” or “potentially poorly indicative” of FoP. The study identified additional possible indicators, including transactions involving individuals connected with countries of proliferation concern, the use of cash, the involvement of small trading or intermediary companies, and others. By illustrating different types of FoP, the case studies are intended to support the work of governments and financial institutions worldwide in identifying FoP.  They are intended to facilitate FoP risk assessments, to support regulators in providing guidance to financial institutions and to support financial institutions in complying with sanctions or other WMD controls.

Above all, combating proliferation of WMD by identifying and disrupting the financing is most likely to be successful when governments and the private sector cooperate and coordinate in sharing information. It is hoped that the FoP case studies included in this report will help this process.

Alpha: Internship Opportunity

Project Alpha works to understand and counter procurement of technologies with a use in UN-restricted nuclear and missile programmes, as pursued by Iran, North Korea, and others. The Project has numerous strands that contribute to this objective, including educating industry on export controls and proliferation risks, researching the techniques used by proliferators to acquire goods illicitly, and conducting international outreach to improve the implementation of trade controls in third countries. Alpha also actively supports the work of UN organisations, the IAEA, and national governments.

The Alpha team are looking for one or more interns to work with the project for the academic term, with possible extension over the summer. Continue reading Alpha: Internship Opportunity

India’s Strategic Nuclear and Missile Programmes – A Baseline Study

Click here to access the report –  Alpha in Depth (India) Public Release – final

What is the report?

This ‘Alpha in Depth’ report uses open-source research to identify and characterise entities involved in India’s strategic weapons programme. Relatively little analysis has been conducted since the US normalised relations with India and lifted the majority of sanctions by 2005 – 2008. This report aims to update the record on Indian entities and will be of interest to government and private sector customers dealing with proliferation issues, particularly with regards to sensitive and dual-use items headed for end-users in India.

This baseline study examines the visible activity of 243 entities that have contributed to India’s strategic nuclear and missile programmes as key weapon stakeholders, unsafeguarded nuclear fuel cycle entities, defence supply chain entities, developers of auxiliary systems such as vehicles, and entities conducted dual-use research of concern. In many cases, entities are openly known to be  major stakeholders in strategic weapons programmes. However, this report finds a wider  and deeper network of suppliers and researchers involved in this system. The extent of this network is laid  bare in this report, and includes more than the original list of entities designated as involved in nuclear and missile activities by the US in 1998 – 2001.

The Restricted version of the report includes the full range of entity profiles sorted by Governmental department, major and minor industry suppliers, and entities conducted dual-use research of concern. An accompanying data file in table format provides a collated record of identifying information such as phone numbers, fax numbers, addresses and key individual names.

The Public version of this report includes the key findings, contextual overview, and informational charts.

Why does India warrant examination?

India is a burgeoning, de facto nuclear weapons power which is beginning to achieve force modernisation through a triad of delivery systems (air, ground and sea) designed to deter through assured retaliation.  In line with this, the Indian arsenal has been increasing, and has diversified to utilise highly enriched uranium, previously the product of enrichment facilities serving the civil energy programme and submarine reactor needs. However, there are multiple areas of concern, some of which might destabilise the intended path towards a stable mutually deterrent relationship between India and its neighbours. Furthermore, an acute nuclear crisis in South Asia would see India mobilise its science and technology potential to undergo a new massive expansion of nuclear capabilities (a ‘third breakout’).

What are the key points of this report?

First, India’s unique nuclear status mimics that of a Non-Proliferation Treaty (NPT) recognised nuclear weapon state. India has a waiver from the Nuclear Suppliers Group (NSG), permitting trade without requiring it to have NPT membership. India has chosen to selectively engage with international non-proliferation agreements, such as the NSG, whilst eschewing others,  such as the Fissile Material Cut-Off Treaty and Comprehensive Test Ban Treaty. Continued special treatment threatens to erode the interlinked non-proliferation regime by demonstrating the viability of achieving nuclear weapon state status outside the NPT and the possibility of Indian reintegration without significant concessions.

India’s continued efforts to join the NSG are primarily based on a desire to secure nuclear trade for its ambitious three-stage fuel cycle (which allows them to harness thorium as fuel). Admission to the NSG will necessitate a delicate balancing act between India’s national interest and commercial value of on one hand, and the concerns of India’s neighbours about proliferation and the second-stage of the fuel cycle. The second stage of Fast Breeder Reactors could be utilised to produce plutonium, and goods provided under an NSG membership waiver could enable India to pursue nuclear proliferation.

Second, India’s strategic weapons complex has the potential to push India’s nuclear capabilities to a full spectrum of weapon systems. India has so far focused on the establishment and enhancement of its ground and sea-based delivery systems:  the construction of four nuclear-powered ballistic submarines for continuous at-sea deterrent and ground-based intercontinental range capable missiles. Beyond this, this report highlights that India’s strategic weapons complex has explored and developed additional weapons systems that could be made nuclear-capable should there be political will. Historically, periods of capability breakout occurred around India’s milestone nuclear tests (1974 and 1998). In such instances, the initiative of the strategic weapons complex in developing ‘technology demonstrators’ (science feasibility projects that scale-up to a potential system), has pre-empted political decision making to adopt such technologies as military capabilities. The development pathway of the Agni is one such example wherein the decision to adopt ground-based long-range missiles as a nuclear delivery system was taken after scientists had demonstrated the feasibility of an indigenous nuclear‑capable ballistic missile, rather than the science and technology sector being directed by decision making authority.

The process of Indian science developments taking the lead over policy direction is why India’s technological latency should raise concerns. Beyond the establishment and further enhancement of India’s existing triad capabilities, new technologies developed into  capabilities in line with the capabilities of major nuclear weapons powers would allow India to drift towards a ‘maximalist’ nuclear arsenal utilising both tactical and strategic nuclear weapons in a graduated escalation posture. For example, air-launched supersonic/hypersonic cruise missiles, tipped with low-yield nuclear warheads, and coupled with new fifth generation fighter aircraft  could be considered by Indian policy makers in the near future as a means to conclusively end conventional conflict. India’s commitment to ‘No First Use’ and to a maximum retaliation-only posture would be eroded by these new possible capabilities.

This report also highlights the possible erosion of political control of the nuclear arsenal. Generally, the Indian interpretation of a nuclear weapon includes the mating of the fissile material pit with the warhead and delivery system itself .Traditionally, India’s nuclear weapons have been kept de-mated and under the control of different bodies, necessitating an inter-agency system commanded firmly by a political body (the Nuclear Command Authority chaired by the Prime Minister) to assemble and deploy the nuclear arsenal. The Agni V intercontinental range capable ballistic missile is pre-mated in the same manner as the pre-mated ballistic missiles used on-board Arihant-class SSBNs. This will have a significant impact on nuclear policy and command and control

Third, India’s scientific complexes (nuclear, missile, and space) are poorly separated. The nuclear programme in India has been partially submitted to international safeguards, but this remains limited and allows India to exercise de facto nuclear weapons state privileges regarding the production of special fissile material. India has invested in new special fissile material production facilities. This large unsafeguarded nuclear fuel cycle encompasses a number of entities performing dual civil and military functions.

India’s space programme is dedicated to civil and peaceful purposes, and for the most part this remains the case. Instances of historical technology transfer from civil rocketry to military missile programmes is perhaps no longer an active concern as  missile programmes are self-sustaining and have achieved key milestones. An inverse technology flow, from military to civilian sector, remains a possibility. Military and civil scientists and engineers continue to meet discreetly in forums and conferences, which should raise concerns about cross-field blurring. Domestic students and international guests are frequent attendees and these science and technology spaces are a proliferation risk.

Fourth, poor separation in these strategic sectors should sharpen the need for tight export controls on intangible transfers and tangible trade to India. Whilst end-user monitoring agreements are in effect for some entities, this report drives forward the imperative for sensitive industries to adopt ‘Know Your Customer’ best practices. This report highlights the complex relationships of India’s domestic technological base, and provides information on the degree of complicity to the nuclear weapons programme.

Fifth, Indian entities are at onward-proliferation risk. The potential danger lies with the re/export of sensitive items and knowledge out of India to foreign powers. The domestic industry supplying India’s  strategic weapons complex and the country’s nuclear programme have reached sufficient technical maturity to export expertise and tangible nuclear and missile-related goods. The Indian government’s support for its domestic industry in the face of international sanctions and technology denial has continued since the normalisation of trade relations in 2008. A science and technology culture of self-reliance and import substitution has formed, and although India’s strategic sectors remain reliant on imports, the balance of domestic supplied goods and foreign imports will tend towards domestic provisions in the coming years. This is one compelling reason why drawing India into firm non-proliferation commitments would enhance international security for the longer term. India has taken strong steps towards implementing a control list (SCOMET), synchronising it with key control regimes, and adopting best practices for businesses; this effort must be sustained.

In sum, greater care and attention needs to be paid to the current issues with India’s nuclear power while also anticipating a future shift in India’s capabilities. Looking forward, there remains room for India to be drawn into firm non-proliferation compliance.


Project Alpha to Host Workshop on Trade Finance and Proliferation Finance

On June 20, 2017, Project Alpha will host the workshop “Trade Finance and Proliferation Finance – Mitigating the Risks,” in London.The workshop’s aim is to better understand how trade finance might be exploited to finance WMD proliferation and will build upon a typologies study of proliferation finance currently being carried out by Project Alpha. The report is available here.

The objectives of the workshop are to:

  1. Review current mechanisms for trade finance and identify how these may be exploited for financing proliferation;
  2. Identify possible measures governments and financial sector could take to mitigate risks;
  3. Consider mechanisms for information sharing to support risk mitigation.

Workshops participants will include experts and practitioners from the financial sector, consulting firms with experience advising clients in trade finance or proliferation finance contexts, banking association representatives, government agencies, and research and academic organisations.

For inquiries regarding attending the workshop as a speaker or participant, please contact Andrea Viski through email to

Brexit and Strategic Trade Controls: key implications

Quentin Michel and Ian Stewart

On 24/25 April, Quentin Michel from the University of Liege and Ian Stewart from King’s College London convened a small group of government officials, academics, and industry practitioners with the purpose of examining the implications of Brexit on strategic trade controls. The workshop was conducted under Chatham House rules with participation in private capacities. The purpose of this short article is to capture the key impressions and issues identified by the hosts. This document does not reflect the views or comments of any specific participant.

The main finding of the workshop was that the exit of the UK from the European Union strategic trade control system will have an impact that goes far beyond trade control law regulations and procedures. Much attention was given to the implications of the trading arrangement that will replace the UK’s access to the ‘single market’. Concerns abound that board tariffs will be adopted by both the EU and UK. However, while the issue of export controls will likely receive scant public attention, inadequate arrangements could have a negative impact that is even more significant than the effect of tariffs. The EU, and separately the UK, must devise mechanisms to ease transfer and, more specifically, licensing of dualuse goods after Brexit. It is unclear presently whether the EU will have the capacity to take the steps required, while also conducting an unrelated review of its own dual-use items export control Regulation, 428/2009. Considering the usual two years delay necessary to finalise the process to adopt a regulation, it is strongly recommended to integrate already the Brexit into the review process.

During the course of the workshop, numerous specific implications were identified. These can broadly be categorised into five areas:

  • The legal basis and the ‘Norway issue’: Before addressing other issues related to Brexit, an answer is needed on what legal basis the UK will use to implement export controls in the future. One alternative would be that the UK will adopt national legislation (initially through the ‘Great Repeal Act’) implementing the requirements of the international export control regimes directly, rather than drawing on the EU regulation applicable in all EU Member States. If this is the case, UK and EU export controls can thus be expected to diverge over time after Brexit. The alternative would be for the UK to align systematically its national provisions to the EU regulation, perhaps following the path of Norway. However, Norway at present cannot take part in EU working groups on export controls and therefore has not possibilities to defend its views when the regulation is amended or updated. Moreover, Norway is excluded from information sharing arrangements whereas that will change probably soon.
  • Harmonisation of controls and competition: There is a real possibility that EU and UK export controls will diverge post-Brexit and that this could result in unhealthy competition and a ‘race to the bottom’ in terms of controls. This might could result in an increase in undesirable transactions, for example. It could also distort markets, particularly if the EU moves forward with the adoption of an autonomous control list in relation to human security issues, as proposed by the European Commission under the recast review, which the UK did not adopt.
  • Information sharing: trade facilitations between States and effective implementation of export controls is contingent on various types of information being shared. This includes not only information on licence denials, which is necessary to prevent ‘undercutting’ and a race to the bottom, but also more sensitive intelligence or other information related to specific transactions. In many cases such information sharing could take place through other channels. However, there would be specific advantages to a structured exchange of information in relation to denial notifications and the updating of any relevant control lists. Ideally, the UK will continue to have access to the DUeS platform.
  • Licensing conditions: The UK is to leave the single market which will mean that the transfer of all strategic items will require licensing to and from the UK and not only a limited number (e.g. Annex IV of Dual Use Regulation 428/20009). This will affect a substantial range of goods and sectors. A solution will be required to allow such items to be easily transferred while minimising the burden on industry. The easiest option might well be to create ‘general’ or ‘open’ licences. However, this would generally require companies to report transfers to authorities and be subject to audit, which might in itself be a substantial burden for industry and licensing authorities. Alternatives include reliance on individual licences (which could be burdensome for companies and authorities) or the creation of some new mechanism intended to record transfers in a low-burden way.
  • Technical capacity: Presently, it is the UK that drafts the EU control list. The UK also provides vital expertise and advice to EU Member States in assessing technical parameters of certain items. While the UK might still be in a position to provide such support post-Brexit, the EU27 might nonetheless need contingency plans.

An additional key area of consideration relates to sanctions. Presently, the UK is a principle actor in relation to EU sanctions. It is understood that the UK has produced several of the evidentiary packages that have been used in relation to specific sanctions designation listings, for example. As one of the largest global economies (equal in size to the 20 smallest EU States) and as a central player in the global financial system, UK adherence to sanctions has been central to their effectiveness. Any move away from harmonisation of sanctions with the European Union could thus undermine either common foreign policy goals or the effectiveness of sanctions. Moreover, practical questions related to sanctions such as who will maintain evidentiary packages for EU sanctions submitted by the UK before Brexit and who will produce evidentiary packages for EU sanctions in the future, if not the UK, must also be considered.

Two important final questions emerged from the discussions. The first concerns how the EU will devise a response to the issues outlined above. It seems apparent that only a group of officials, such as the Council’s Dual-use Working Party, will have the necessary expertise to examine these issues in depth and devise a policy for future dual-use trade between the EU and UK. The second question, which is related, is whether it is feasible to advance both Brexit and the recast of the EU export control regulation (428/2009) in parallel. Given the sheer volume of the dual-use trade implications of Brexit and the fact that the recast, which has now been underway for more than 4 years is the main way in which the EU could adopt a new or amended general export licence for the UK, it seems at the least that it would be useful to consider Brexit issues as part of the recast

Report of the UN Panel of Experts on North Korea

The UN Panel of Experts on North Korea at the end of February released a substantial report on North Korea’s proliferation-related activities.

The report contains a significant number of cases concerning North Korean illicit trade and sanctions violations. The report also notes a ‘significant increase’ in the number of national implementation reports by UN Member States since the adoption of UNSCR 2270.

The report contains numerous recommendations to the UN Security Council as listed below. It is notable that the intensely political Security Council in recent years has often failed to adopt the recommendations of its Panel of Experts. The Security Council has nonetheless now renewed the mandate of the Panel of Experts for a further 12 months. The recommendations contained in the new resolution are also reproduced below.

Continue reading Report of the UN Panel of Experts on North Korea

DPRK successful ballistic missile test 12 February

Image courtesy of AFP/KCNA

On 12 February 2017 the Democratic People’s Republic of Korea (DPRK) carried out a successful ballistic missile test of a medium range ballistic missile, the Pukguksong-2. The missile reached a height of 550 kilometers before impacting in the East Sea. This is the first such provocation by the DPRK since Donald Trump became President of the US and will be a first test of the administration. The test itself according to a number of analysts is concerning. The Pukguksong-2 shares significant similarities with the KN-11 (Pukguksong-1), a submarine based solid fuel ballistic missile. This represents a new capacity for the DPRK and one that is potentially more robust and manoeuvrable. The use of a cold-launch canister system being carried on a tracked transporter-erector launcher vehicle provides substantially greater cross-country mobility than many other North Korean ballistic missiles. Being solid fuel also means this ballistic missile would not require tanker trucks giving it a smaller foot print and making it quicker to launch. The test clearly shows the DPRK is looking to increase its ballistic missile capabilities and has the ability to do so.


North Korea: 2016 in review and the challenges of 2017

By Ian K. Bolton, Research Associate Interdictions and PSI (

2016 was an exceptionally busy year for the world of counter-proliferation (CP); in January, Implementation Day of the Joint Comprehensive Plan of Action with Iran was reached. By November, the United Nations’ First Committee voted to begin negotiations in 2017 on a global legally binding instrument to prohibit nuclear weapons for all countries. However, it was North Korean events which were the most dramatic.

On 6 January 2016, North Korea conducted its fourth nuclear test, with a yield believed to be in the region of 10 kilotons[1]. The nuclear test was widely condemned; notably China seemed to be genuinely angered by the test[2]. Before the world had been able to respond through the United Nations, North Korea escalated matters. On 7 February, North Korea confirmed it had launched a long-range rocket from its Sohae site, claiming the rocket was carrying a satellite for its space program. However under Security Council resolutions, North Korea is prohibited from conducting any such activity which is contributing to their ballistic missile programme.

The International Community delivered its response to the January nuclear test on 2 March, passing a new UN Security Council Resolution – UNSCR 2270. This resolution created one of the most wide‑ranging sanctions regimes against North Korea in the UN’s history. The restrictions adopted under UNSCR 2270 are broad and include entire sectors, such as coal and iron ore. The exception to these restrictions were when they would impact on the livelihoods of North Korean nationals. UNSCR 2270 also introduced an obligation on UN Member States to inspect all cargoes originating in, or destined for, North Korea.

Before the ink of UNSCR 2270 was dry, North Korea was once again challenging the resolve of the International Community. On 15 April, they tested the Musudan Intermediate Range Ballistic Missile. Although the test was seen by the CP community as having failed, this was indicative of things to come. On 23 April, North Korea tested a Submarine Launched Ballistic Missile[3]. By the end of August there been 7 further ballistic missile tests, ranging in their success. One North Korean watcher described this pattern of testing as Mr. Kim having ‘missile lust’, and not giving up on efforts to develop them further[4].

The next significant provocation came on 9 September when the regime conducted their fifth and largest‑to‑date nuclear test[5]. The test sparked international condemnation and heightened tensions across the region, with the US conducting an overflight of South Korea by two US B-1B Strategic Bombers. Once again the International Community looked to take decisive action. On 30 November 2016, the UN Security Council passed a new resolution, UNSCR 2321, which built on UNSCR 2270.

Adopted unanimously by the UN Security Council, resolution UNSCR 2321 tightened even further the sanctions and controls on North Korea[6]. The new resolution looked to address some of the issues which had come to light in the aftermath of UNSCR 2270, such as easy work-arounds on sectoral sanctions. New restrictions were put in place on mineral sectors, including copper, nickel, silver and zinc. The amount of coal North Korea could export was also restricted to defined amounts. It introduced restrictions on North Korean workers based overseas, as well as the provision of statues from North Korea. Additionally the UNSCR raised concerns about the activities of North Korean diplomatic missions and holdings and how these could be misused. All in all UNSCR 2270 and UNSCR 2321 together have created one of the most extensive UN sanctions regimes ever to be passed.

Challenges in 2017

It is clear that international condemnation, pressure and sanctions have not deterred North Korea from carrying out further provocations. Proof of this can be seen in the ballistic missile test that took place yesterday, 12 February 2017. The successful testing of the Pukguksong-2 missile will be an early test of the International Community’s resolve and ability to respond. Indeed satellite imagery and evidence[7] suggests North Korea has restarted its nuclear reactor at Yongbyon, the reactor used to produce plutonium for North Korea’s nuclear weapons programme[8]. This action would seem to indicate North Korea is preparing to conduct further nuclear tests.

The Trump administration has been sabre rattling in the region, both during the recent visit by Defence Secretary Mattis[9], in President Trump’s tweets[10], and during the visit of the Japanese Prime Minister. The critical question is what will the International Community, and the Trump administration, do in response to further provocations? It is hard to see what further scope there is for tightening sanctions on North Korea, and were such tightening to be suggested there would be concern regarding the humanitarian impact, a key concern for many countries, including Russia and China. Trump has already pointed the finger at China for failing to control North Korea[11], but traditionally China has resisted pressure to tighten its sanctions implementation. Given the antagonistic relationship between Trump and China so far, the US may undertake some form of unilateral military action against North Korea, though highly unlikely. Apart from further sanctions and possible military action, the best hope for a change in direction is the potential restarting of 6-party talks; the US administration has said they are willing to talk to North Korea. In practice it is difficult to see what this could accomplish, but the same was said by many before the start of Iran talks.

Another key challenge in 2017 will be the full implementation of both UNSCRs 2270 and 2321. UNSCR 2321 followed so quickly on the heels of UNSCR 2270 that many countries have not yet fully implemented UNSCR 2270, and as such have not submitted implementation reports to the UN as set out in the resolution[12]. Individual national legislation will need to be adopted by many in order to enforce the sanctions. This legislation will need to give countries powers to seize vessels and cargoes as prescribed by the UNSCRs. Countries will need legislation and capacity to allow all cargoes going to, or originating in, North Korea to be inspected. Furthermore, countries will need to ensure they can inspect cargo travelling via land and rail transportation, as well as sea and air, an often overlooked area. For many countries, especially in South East Asia given the high traffic of North Korean activity, there may be a need to dramatically increase customs enforcement capacity. Countries will need to be able to enforce the sectoral controls introduced by the UNSCRs, this will include an ability to analyse and identify what materials/ores they may be dealing with and if they are sanctioned.

Even more complicated will be how restrictions on coal, which essentially provides export limits, will actually be enforced, especially by China, North Korea’s biggest coal customer. North Korea watchers are already pointing out the potential frailties of this[13]. Domestic ship, registries, agents, insurers and companies will need to be looked at to ensure they are not misused by North Koreans. Countries will also need to examine their ship registries to de-list North Korean owned, operated or controlled vessels. Countries will need to take action to prevent public and private financial support to North Korea by persons or entities within their jurisdiction, unless by prior approval of the UN North Korean Sanctions Committee. And all of this is just a snapshot of the many new obligations and capacities countries will have to undertake.

Given this huge implementation challenge, the international community, and in particular countries like the US and UK, along with institutions, such as the European Union and United Nations, must have a focus on providing critical assistance to other countries, especially those with limited enforcement capacity. It is this that really will be the biggest challenge of 2017. Without this, having extensive and wide ranging sanctions on North Korea is worthless.




[4] Thomas Karako, director of the Missile Defense Project at the Center for Strategic and International Studies, told Business Insider:








[12] Currently just over 60 countries have completed implementation reports of UNSCR2270 as evidence on the UN website: