Four companies and five individuals have been charged by the US Department of Justice for allegedly devising an international network that supplied the Iranian military and Iran’s nuclear programme with $24 million worth of controlled goods between 2010 and 2015. The case illustrates how such networks function at an international level and draws attention to some interesting factors regarding Iran’s illicit procurement capabilities and the evasion of controls in light of the recently agreed Joint Comprehensive Plan of Action (JCPOA). Several financial and technical aspects of the network’s alleged operations are taken into consideration in this regard. A current update on the status of the case is also provided.

The full Alpha case study can be downloaded at the link below.



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The Kyodo News has reported the arrests in Japan on 26 May of three men who are suspected of supplying export-controlled carbon fibre to China without a licence.

The Strategic Trade Review is now accepting unsolicited manuscripts for future issues.

Before submitting, please read the relevant “Instructions for Authors” section. Submissions to be included in the first edition must be submitted by June 30, 2015 for consideration. Manuscripts received thereafter will be considered for subsequent editions.

For more information visit: 

Project Alpha and the Association of University Legal Practitioners are pleased to release today a guidance document for universities and the higher education sector on export controls and the UK Government's student vetting scheme (ATAS).


On 12 September 2014, the Governments of Australia and Singapore hosted a symposium in Singapore for the shipping and maritime transportation sector to raise awareness of United Nations sanctions and explore issues relating to compliance with such sanctions. More than 100 representatives participated from across the supply chain and related services, including ship owners and agents, freight forwarders, insurance companies, brokers and port operators, as well as industry associations, regulators and think tanks.

Together with Project Alpha, Singapore and Australia have documented the good practices in compliance identified at the symposium to produce the attached report. We expect that the report will be useful not only to industry but also to Member States and Security Council committees in better understanding the role and good practices of the maritime transportation sector, which is an essential partner in realizing the effective implementation of United Nations sanctions.

This report has been circulated to Member States by the Security Council. It can be downloaded below.




The Diplomat has published a new article by Project Alpha's Nick Gillard on the problem of illicit dual-use trade in Southeast Asia. The cases of Parviz Khaki and Daniel Frosch have highlighted the need for ASEAN members to implement laws regulating trade in dual-use goods with proliferation utility.

 In late December of 2014, a 32 year old Austrian named Daniel Frosch appeared in a courtroom in Graz and pleaded guilty to violating Austria's federal trade laws. For more than a decade prior, Frosch had been a dynamic young international exporter, trading high-tech equipment and technology from bases in Austria, the UAE and the Philippines.

US authorities, meanwhile, accused Frosch of being a key supplier to Iran's ballistic missile programme. 


Nonproliferation goals are in danger of being undermined by online trade in proliferation-related goods. Project Alpha is pleased to be working with governments, international organisations and the private sector in addressing this problem of 'weapons of mass e-commerce'.

Project Alpha's analysis of online trade in proliferation-sensitive dual-use goods has featured in outlets including The Bulletin of the Atomic Scientists and Bloomberg Business.

Our work in identifying potential proliferation channels on Internet-trading platforms and assisting e-commerce sites to manage their compliance obligations is ongoing.

In particular, we commend Alibaba for having removed several US- and EU-sanctioned entities from their website. This is a strong first step towards improving compliance and combatting proliferation.

Other Internet-trading platforms, particularly those based in China, have yet to follow Alibaba's lead in removing known proliferators from their sites. A review by Project Alpha found that at least 15 China-based e-commerce sites still host adverts belonging to serial proliferator Li Fang Wei (aka Karl Lee), despite his public designation as a supplier to Iran's missile programme.

For further information, see the following resources:

In December 2012, a shipment of high-strength carbon fibre bound for Iran was interdicted and seized in Singapore. This case study provides an overview of the carbon fibre seizure and the entities involved in the attempted shipment, which span Iran, mainland China, Hong Kong and Georgia. While the end-user of the material remains unknown, the size of the seized goods – 7,200kg of high-strength carbon fibre – is easily sufficient to produce at least enough centrifuge rotors to outfit a Fordow-size uranium enrichment facility. Download the full Alpha report at the link below.

Iran Sanctions Update

Alpha's Ian J. Stewart provides an overview of the current status and future of sanctions against Iran.

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Sectoral Guidance