Dr Khan and the Keystone Cops

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It appears that the story of Dr Khan provides a nearly endless saga for those seeking to discern lessons to be learned from his experiences. In that regard the newest batter to step up to the plate is the US Government Accountability Office, which just today, released the report Nonproliferation: US Efforts to Combat Nuclear Networks Need Better Data on Proliferation Risks and Program Results (GAO-08-21, October 31) .

It appears that one reason Dr Khan was so successful was not just because of his shrewdness and acumen, formidable as they were, but also because of the sheer incompetence of the Keystone Cops, aka the national nonproliferation bureaucracy.

Let's look at some excerpts from the report:

US agencies engaged in export control enforcement activities are impaired from judging their progress in preventing nuclear proliferation networks because they cannot readily identify basic information on the number, nature, or details of all their enforcement activities involving nuclear proliferation. The Departments of Homeland Security, Justice, and Treasury cannot readily identify which of their enforcement activities involve nuclear proliferation because they do not categorize their activities in a way that would allow them to do so. Furthermore, some agencies that maintain lists of individuals and companies that have violated export control laws or engaged in weapons of mass destruction (WMD) proliferation could not identify all listed parties that engaged in nuclear proliferation. For example, none of the entities publicly identified in relation to the AQ Khan nuclear proliferation network appears on Treasury's specially designated nationals list.

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Furthermore, some agencies that maintain lists of individuals and companies that have violated export control laws or engaged in WMD proliferation could not identify which parties were placed on the lists for nuclear proliferation reasons. For example, Treasury, which maintains a specially designated nationals list containing the individuals and entities that have been designated under its Office of Foreign Assets Control's (OFAC) various sanctions programs, reported it cannot identify all entities that have been placed on the list for nuclear proliferation reasons. Treasury officials said that they maintain records on the rationale for placing an entity on the list, but do not necessarily denote the type of WMD proliferation entities are engaged in or support. In addition, Treasury confirmed that none of the entities publicly identified in relation to the AQ Khan nuclear proliferation network appears on the specially designated nationals list or in the Annex to Executive Order 13382. Commerce stated that it does not maintain readily available information that would allow it to identify individuals or entities placed on its denied persons list for nuclear proliferation reasons. This list includes individuals and entities that have been denied export privileges. In contrast, State reported periodically to Congress that, between 2003 and 2006, it had sanctioned foreign persons for engaging in nuclear proliferation activities with Iran or Syria.

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Treasury did not comment on our recommendations. However, Treasury stated that it can and does identify which entities have been designated for nuclear proliferation reasons at the time of designation. However, this statement misses our point. As our report stated, US government agencies that engage in enforcement activities to counter nuclear proliferation networks are impaired from judging their progress in this effort because they cannot readily identify basic information on the number, nature, or details of their enforcement activities involving nuclear proliferation. If Treasury cannot readily retrieve this information, then the information is not useful for assessing the impact of its sanctions specifically on nuclear proliferators. Despite its assertion, Treasury did not provide us with a list of all listed entities designated for nuclear proliferation reasons, as we had requested. In commenting on our finding that Treasury did not designate any entities publicly identified with the AQ Khan network, Treasury stated that its designation decisions involve an interagency process that identifies, assesses, and prioritizes targets. Therefore, it appears that Treasury did not designate any AQ Khan network entities because an interagency process did not identify and assess them as priority targets.

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