This article was published in the Indian Pugwash Society's in-house journal Proliferation and Arms Control, Vol. 3, no. 3, March 2006, pp. 1-5.
As reported in The Washington Times and The New York Times the United States has recently imposed sanctions on nine firms worldwide, which includes two Indian firms under the Iran Nonproliferation Act 2000, for supplying chemicals that the US claims could assist Iran’s chemical weapons program. However, there is more to it than what meets the eye in the recent US decision [1]. The list of sanctioned companies includes six Chinese firms, two Indian firms and an Austrian Steyr-Mannlicher, which makes high-quality assault weapons. The sanctions have been imposed under section 3 of the Iran Nonproliferation Act, which Congress passed in 2000 to deter international support for Iran's nuclear, chemical and biological weapons programs and missile-delivery systems [2]. The sanctions run till December 2007 and bar the companies from doing business with the U.S. government and prohibit U.S. firms from obtaining export licenses to sell sensitive products to these companies. However, a closer look of this issue is warranted because not all the facts of the case match up. Especially, in the case of the Indian companies it seems as if the State Department could have its concerns misplaced.
The Facts of the Case
The two Indian companies that were sanctioned are Sabero Organic Chemicals Gujarat Ltd. and Sandhya Organic Chemicals Pvt. Ltd. The Federal Register does not mention any details about the materials that were transferred. However, things do look amiss when one gives a brief glance to the media reports as well as the press releases of the two Indian firms. The press releases put out by the two firms does list out the chemicals that were exported by them. Sandhya Organic Chemicals Pvt. Ltd. had exported approximately 1.5 MT of Phosphorus oxychloride – POCl3 and Sabero Organic Chemicals had exported 112 MT of Tri-Methyl Phosphite (TMP) in 2003 to Raja Shimi Industrial Manufacturing Centre, Iran. Both these chemicals come under the Schedule III of the Chemical Weapons Convention (CWC). [3]
Phosphorus oxychloride like Tri-Methyl Phosphite is a chemical weapons precursor. Both these chemicals find a mention under Section III of the CWC. This is mainly due to the widespread recognition of the fact that these chemicals have a lot of innocuous industrial uses. Apart from this even the Australia Group [4] that follows the CWC classification places these chemicals under Schedule III. [5]
Interestingly, even under the US export classification system the two chemicals are listed under Schedule III. [6] This brings up the question of the rationale behind sanctioning the Indian companies in the first place. Why does the U.S. need to sanction two Indian firms for supplying material that they themselves do not see as dangerous? One question that needs to be asked is whether the US sanctions are a reflection of the paranoia surrounding Iran that exists in the United States.
Understanding the Iran Nonproliferation Act 2000
Given this information it is imperative that the Iran Nonproliferation Act 2000 be studied a little closer. It was on 14 March 2000 that President Clinton signed the Iran Nonproliferation Act of 2000, which authorizes him to take punitive action against individuals or organizations known to be providing material aid to weapons of mass destruction (WMD) programs in Iran. By appending his signature on the Act, President Clinton thus ended a two year long stand off with the U.S. Congress on the issue. Earlier, Clinton had vetoed a 1998 version of the bill that focused on missile proliferation to Iran because it required the imposition of sanctions on Russian entities unless the president determined that a waiver of sanctions was "essential" to U.S. national security. The administration argued that the legislation, the Iran Missile Proliferation Sanctions Act of 1998, would harm the administration's effort to garner Russian cooperation on a wide range of proliferation issues. [7]
However, having taken such a position, President Clinton quickly moved to assuage the concerns of the Congress by amending Executive Order 12938, the 1994 order that declared a national emergency with regard to WMD proliferation, to allow the executive branch to impose financial penalties on proliferators. Subsequently, hoping to override the 23 July 1998 veto, the administration moved to sanction seven Russian entities on 15 July 1998 for their assistance to Iran's ballistic missile program. The US move came a day after the Russian announcement that nine companies (including the seven targeted for sanctions) were going to be investigated by a new Export Control Commission for violations of Russian export control laws. The US and Russian announcements did not come a day too soon and managed to buy the Clinton administration some time in the House of Representatives that was planning an override vote which had been scheduled for 17 July 1998. [8]
On 12 January 1999, the U.S. announced the imposition of sanctions on three Russian firms, for sharing nuclear and missile technology with Iran. National Security Adviser Samuel Berger announced the imposition of sanctions on the Moscow Aviation Institute, the Mendeleyev University of Chemical Technology, and the Scientific Research and Design Institute of Power Technology (known as NIKIET). However, by this time the U.S. - Russian relations were on a downswing, and the move was highly criticised by Russia, which was already quite angry with the US over the air strikes on Iraq in December. Prime Minister Yevgeny Primakov described Washington's decision as "counterproductive to U.S.-Russian relations." A Foreign Ministry statement on January 14 declared the U.S. allegations "completely groundless" and said the three entities' activities are "fully consistent with Russia's domestic legislation and its international obligations in the area of missile and nuclear non-proliferation." [9]
Coming, back to the Iran Nonproliferation Act of 2000, as compared to the Iran Missile Proliferation Sanctions Act of 1998, that Clinton vetoed, the language of the new law is substantially less restrictive than the 1998 legislation. Every six months it requires the President to submit to Congress a list of entities known to be providing material assistance to Iranian WMD programs. The President is then authorized and encouraged to utilize Executive Order 12938 provisions, arms export prohibitions, and dual-use export prohibitions on those entities. But the onus for action remains soundly with the president. Should he decide not to take action against a particular entity, congressional notification and a written explanation is required, but a waiver is not. Apart from expanded reporting requirements, the legislation will not require any demonstrable action by the administration against Russian entities.
To understand the 2000 Act better, the question to be asked is which entities or person will be reported to the Congress under the Act and what is the criteria for a violation under the Act. The 2000 Act specifies that foreign persons who, on or after January 1, 1999, have transferred to Iran: (1) controlled goods, services, or technology; or (2) non-controlled goods, services, or technology that nevertheless would be, if they were U.S. goods, services, or technology, prohibited for export to Iran because of their potential to make a material contribution to the development of nuclear, biological, or chemical weapons, or ballistic or cruise missile systems. [10] There are however two exceptions to the above rule; first, persons who were previously identified; secondly, persons who have acted on behalf of, or in concert with, the U.S. Government.
Outlining the criteria for violations the Act stipulates, that persons who have after 1 January 1999 have supplied to Iran:
1. goods, services or technology listed on:
2. goods, services, or technology not listed on any list identified in paragraph (1) but which nevertheless would be, if they were United States goods, services, or technology, prohibited for export to Iran because of their potential to make a material contribution to the development of nuclear, biological, or chemical weapons, or of ballistic or cruise missile systems.
The Loose Ends
To understand the discrepancy in the case of the sanctioning of the two Indian firms its is important to compare the criteria for reporting outlined in the 2000 Act with the facts on the ground that have come into light about the nature of materials transferred by the Indian firms.
The relevant provisions in this case is of the Chemical Weapons Convention, wherein only chemicals and precursors listed in Schedule I and II and the export control list of the Australia Group come under the purview of the Act. However, what is interesting in the Indian case is the fact that the all the chemicals that were supplied to the Iranian company are listed under Schedule III of the Chemicals Weapons Convention, Australia Group List, and the US domestic list mirroring the CWC. This seems to be the biggest oversight on the US’s part in the case of sanctioning the two Indian firms.
As reported in The Washington Times and The New York Times the United States has recently imposed sanctions on nine firms worldwide, which includes two Indian firms under the Iran Nonproliferation Act 2000, for supplying chemicals that the US claims could assist Iran’s chemical weapons program. However, there is more to it than what meets the eye in the recent US decision [1]. The list of sanctioned companies includes six Chinese firms, two Indian firms and an Austrian Steyr-Mannlicher, which makes high-quality assault weapons. The sanctions have been imposed under section 3 of the Iran Nonproliferation Act, which Congress passed in 2000 to deter international support for Iran's nuclear, chemical and biological weapons programs and missile-delivery systems [2]. The sanctions run till December 2007 and bar the companies from doing business with the U.S. government and prohibit U.S. firms from obtaining export licenses to sell sensitive products to these companies. However, a closer look of this issue is warranted because not all the facts of the case match up. Especially, in the case of the Indian companies it seems as if the State Department could have its concerns misplaced.
The Facts of the Case
The two Indian companies that were sanctioned are Sabero Organic Chemicals Gujarat Ltd. and Sandhya Organic Chemicals Pvt. Ltd. The Federal Register does not mention any details about the materials that were transferred. However, things do look amiss when one gives a brief glance to the media reports as well as the press releases of the two Indian firms. The press releases put out by the two firms does list out the chemicals that were exported by them. Sandhya Organic Chemicals Pvt. Ltd. had exported approximately 1.5 MT of Phosphorus oxychloride – POCl3 and Sabero Organic Chemicals had exported 112 MT of Tri-Methyl Phosphite (TMP) in 2003 to Raja Shimi Industrial Manufacturing Centre, Iran. Both these chemicals come under the Schedule III of the Chemical Weapons Convention (CWC). [3]
Phosphorus oxychloride like Tri-Methyl Phosphite is a chemical weapons precursor. Both these chemicals find a mention under Section III of the CWC. This is mainly due to the widespread recognition of the fact that these chemicals have a lot of innocuous industrial uses. Apart from this even the Australia Group [4] that follows the CWC classification places these chemicals under Schedule III. [5]
Interestingly, even under the US export classification system the two chemicals are listed under Schedule III. [6] This brings up the question of the rationale behind sanctioning the Indian companies in the first place. Why does the U.S. need to sanction two Indian firms for supplying material that they themselves do not see as dangerous? One question that needs to be asked is whether the US sanctions are a reflection of the paranoia surrounding Iran that exists in the United States.
Understanding the Iran Nonproliferation Act 2000
Given this information it is imperative that the Iran Nonproliferation Act 2000 be studied a little closer. It was on 14 March 2000 that President Clinton signed the Iran Nonproliferation Act of 2000, which authorizes him to take punitive action against individuals or organizations known to be providing material aid to weapons of mass destruction (WMD) programs in Iran. By appending his signature on the Act, President Clinton thus ended a two year long stand off with the U.S. Congress on the issue. Earlier, Clinton had vetoed a 1998 version of the bill that focused on missile proliferation to Iran because it required the imposition of sanctions on Russian entities unless the president determined that a waiver of sanctions was "essential" to U.S. national security. The administration argued that the legislation, the Iran Missile Proliferation Sanctions Act of 1998, would harm the administration's effort to garner Russian cooperation on a wide range of proliferation issues. [7]
However, having taken such a position, President Clinton quickly moved to assuage the concerns of the Congress by amending Executive Order 12938, the 1994 order that declared a national emergency with regard to WMD proliferation, to allow the executive branch to impose financial penalties on proliferators. Subsequently, hoping to override the 23 July 1998 veto, the administration moved to sanction seven Russian entities on 15 July 1998 for their assistance to Iran's ballistic missile program. The US move came a day after the Russian announcement that nine companies (including the seven targeted for sanctions) were going to be investigated by a new Export Control Commission for violations of Russian export control laws. The US and Russian announcements did not come a day too soon and managed to buy the Clinton administration some time in the House of Representatives that was planning an override vote which had been scheduled for 17 July 1998. [8]
On 12 January 1999, the U.S. announced the imposition of sanctions on three Russian firms, for sharing nuclear and missile technology with Iran. National Security Adviser Samuel Berger announced the imposition of sanctions on the Moscow Aviation Institute, the Mendeleyev University of Chemical Technology, and the Scientific Research and Design Institute of Power Technology (known as NIKIET). However, by this time the U.S. - Russian relations were on a downswing, and the move was highly criticised by Russia, which was already quite angry with the US over the air strikes on Iraq in December. Prime Minister Yevgeny Primakov described Washington's decision as "counterproductive to U.S.-Russian relations." A Foreign Ministry statement on January 14 declared the U.S. allegations "completely groundless" and said the three entities' activities are "fully consistent with Russia's domestic legislation and its international obligations in the area of missile and nuclear non-proliferation." [9]
Coming, back to the Iran Nonproliferation Act of 2000, as compared to the Iran Missile Proliferation Sanctions Act of 1998, that Clinton vetoed, the language of the new law is substantially less restrictive than the 1998 legislation. Every six months it requires the President to submit to Congress a list of entities known to be providing material assistance to Iranian WMD programs. The President is then authorized and encouraged to utilize Executive Order 12938 provisions, arms export prohibitions, and dual-use export prohibitions on those entities. But the onus for action remains soundly with the president. Should he decide not to take action against a particular entity, congressional notification and a written explanation is required, but a waiver is not. Apart from expanded reporting requirements, the legislation will not require any demonstrable action by the administration against Russian entities.
To understand the 2000 Act better, the question to be asked is which entities or person will be reported to the Congress under the Act and what is the criteria for a violation under the Act. The 2000 Act specifies that foreign persons who, on or after January 1, 1999, have transferred to Iran: (1) controlled goods, services, or technology; or (2) non-controlled goods, services, or technology that nevertheless would be, if they were U.S. goods, services, or technology, prohibited for export to Iran because of their potential to make a material contribution to the development of nuclear, biological, or chemical weapons, or ballistic or cruise missile systems. [10] There are however two exceptions to the above rule; first, persons who were previously identified; secondly, persons who have acted on behalf of, or in concert with, the U.S. Government.
Outlining the criteria for violations the Act stipulates, that persons who have after 1 January 1999 have supplied to Iran:
1. goods, services or technology listed on:
- the Nuclear Suppliers Group Guidelines for the Export of Nuclear Material, Equipment and Technology (published by the International Atomic Energy Agency as Information Circular INFCIRC/254/Rev.3/Part 1, and subsequent revisions) and Guidelines for Transfers of Nuclear-Related Dual-Use Equipment, Material, and Related Technology (published by the International Atomic Energy Agency as Information Circular INFCIRC/254/Rev.3/Part 2, and subsequent revisions);
- the Missile Technology Control Regime Equipment and Technology Annex of June 11, 1996, and subsequent revisions;
- the lists of items and substances relating to biological and chemical weapons the export of which is controlled by the Australia Group;
- the Schedule I or Schedule II list of toxic chemicals and precursors the export of which is controlled pursuant to the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on Their Destruction; or
- the Wassenaar Arrangement list of Dual Use Goods and Technologies and Munitions list of July 12, 1996, and subsequent revisions; or
2. goods, services, or technology not listed on any list identified in paragraph (1) but which nevertheless would be, if they were United States goods, services, or technology, prohibited for export to Iran because of their potential to make a material contribution to the development of nuclear, biological, or chemical weapons, or of ballistic or cruise missile systems.
The Loose Ends
To understand the discrepancy in the case of the sanctioning of the two Indian firms its is important to compare the criteria for reporting outlined in the 2000 Act with the facts on the ground that have come into light about the nature of materials transferred by the Indian firms.
The relevant provisions in this case is of the Chemical Weapons Convention, wherein only chemicals and precursors listed in Schedule I and II and the export control list of the Australia Group come under the purview of the Act. However, what is interesting in the Indian case is the fact that the all the chemicals that were supplied to the Iranian company are listed under Schedule III of the Chemicals Weapons Convention, Australia Group List, and the US domestic list mirroring the CWC. This seems to be the biggest oversight on the US’s part in the case of sanctioning the two Indian firms.
The Indian responses
The Indian Ministry of External Affairs (MEA) made a fairly detailed response to the sanctioning of the two Indian firms under the Iran Nonproliferation Act, 2000. The MEA spokesperson said that “the transfer of such chemicals is not in violation of our regulations or our international obligations.” It pointed out that India’s commitment to prevent onward proliferation is second to none and also the fact that India has instituted a rigorous system of export controls and that its track record in this regard is well known. The MEA response went out to point out that India is working with the international community including with the US as a partner against proliferation. In this context “the imposition of sanctions by the US on our firms, which in our view have not acted in violation of our laws or regulations, is not justified.” [11]
The press releases put out by the two Indian firms let the cat out of the bag about what exactly they had supplied to Tehran and whether these materials could provide any assistance to the Iranian Weapons of Mass Destruction (WMD) programme. [12] Going through the details provided by the companies it becomes amply clear that the chemicals supplied by them are listed even in the CWC under Schedule III; materials under this Schedule are considered to have a lot of innocuous industrial uses. The chemicals Phosphorus oxychloride – POCl3 has been used for many years now as flame retardants and plasticizers for PVC and is also used in the pharmaceuticals industry and Tri-Methyl Phosphite (TMP) on the other hand is used in the plastics industry.
Conclusion
If one sees the sanctioning of the two Indian firms as an err in judgement on the part of the U.S. it is not the first time that this has occurred. In the past U.S. had similarly, sanctioned a former Chairman and Managing Director of Nuclear Power Corporation (NPC) Dr. C. Surendar in September 2004 on charges of allegedly transferring sensitive technology or equipment to Iran. The Indian government had even at that time had maintained that the sanctions had no justification and they should be lifted. [13]
The U.S. administration on 23 December 2005 removed the sanctions, saying that they were “no longer warranted”; a decision that has been welcomed in New Delhi. Another scientist who was also sanctioned with Dr. Surendar, however was not so fortunate. Y S R Prasad, continues to remain blacklisted under the Iran Non-Proliferation Act 2000. He had visited Iran but has maintained that his trips were always under the aegis of the International Atomic Energy Agency a claim has been backed by the government.
One can only hope that after going through the facts of the case, the U.S. administraton sees reason and rescinds its decision to sanction the two Indian firms, Sandhya Organic Chemical Pvt. Ltd. and Sabero Organic Chemical Gujarat Ltd.
The Indian Ministry of External Affairs (MEA) made a fairly detailed response to the sanctioning of the two Indian firms under the Iran Nonproliferation Act, 2000. The MEA spokesperson said that “the transfer of such chemicals is not in violation of our regulations or our international obligations.” It pointed out that India’s commitment to prevent onward proliferation is second to none and also the fact that India has instituted a rigorous system of export controls and that its track record in this regard is well known. The MEA response went out to point out that India is working with the international community including with the US as a partner against proliferation. In this context “the imposition of sanctions by the US on our firms, which in our view have not acted in violation of our laws or regulations, is not justified.” [11]
The press releases put out by the two Indian firms let the cat out of the bag about what exactly they had supplied to Tehran and whether these materials could provide any assistance to the Iranian Weapons of Mass Destruction (WMD) programme. [12] Going through the details provided by the companies it becomes amply clear that the chemicals supplied by them are listed even in the CWC under Schedule III; materials under this Schedule are considered to have a lot of innocuous industrial uses. The chemicals Phosphorus oxychloride – POCl3 has been used for many years now as flame retardants and plasticizers for PVC and is also used in the pharmaceuticals industry and Tri-Methyl Phosphite (TMP) on the other hand is used in the plastics industry.
Conclusion
If one sees the sanctioning of the two Indian firms as an err in judgement on the part of the U.S. it is not the first time that this has occurred. In the past U.S. had similarly, sanctioned a former Chairman and Managing Director of Nuclear Power Corporation (NPC) Dr. C. Surendar in September 2004 on charges of allegedly transferring sensitive technology or equipment to Iran. The Indian government had even at that time had maintained that the sanctions had no justification and they should be lifted. [13]
The U.S. administration on 23 December 2005 removed the sanctions, saying that they were “no longer warranted”; a decision that has been welcomed in New Delhi. Another scientist who was also sanctioned with Dr. Surendar, however was not so fortunate. Y S R Prasad, continues to remain blacklisted under the Iran Non-Proliferation Act 2000. He had visited Iran but has maintained that his trips were always under the aegis of the International Atomic Energy Agency a claim has been backed by the government.
One can only hope that after going through the facts of the case, the U.S. administraton sees reason and rescinds its decision to sanction the two Indian firms, Sandhya Organic Chemical Pvt. Ltd. and Sabero Organic Chemical Gujarat Ltd.
Endnotes
[1] Gertz, Bill, ‘U.S. puts sanctions on Chinese firms for aiding Tehran,’ The Washington Times, 27 December 2005, available at http://www.washingtontimes.com/national/20051227-124948-5253r.htm and Sanger,. David E., ‘U.S. to Punish 9 Companies Said to Help Iran on Arms,’ The New York Times, 28 December 2005, available at http://www.nytimes.com/2005/12/28/international/asia/28china.html?ei=5070&en=10cfd33e2ab955a5&ex=1136955600&adxnnl=1&adxnnlx=1136794097-oYOFyzl9G4w7Pnse3+tR7A&pagewanted=print
[2] Federal Register: December 30, 2005, Volume 70, Number 250, pp. 77441-77442, available at http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/2005/E5-8116.htm
[3] Chemical Weapons Convention, Annex on Chemicals, Guidelines for Schedules on Chemicals, available at http://www.opcw.org/html/db/cwc/eng/cwc_annex_on_chemicals.html
[4] The Australia Group is an informal arrangement which aims to allow exporting or transshipping countries to minimise the risk of assisting chemical and biological weapon (CBW) proliferation. The Group meets annually to discuss ways of increasing the effectiveness of participating countries’ national export licensing measures to prevent would-be proliferators from obtaining materials for CBW programs. All states participating in the Australia Group are parties to the Chemical Weapons Convention (CWC) and the Biological Weapons Convention (BWC). For more details please refer to the Australia Group Website at http://www.australiagroup.net/en/intro.htm
[5] Export control list: Chemical Weapons precursors available at http://www.australiagroup.net/en/control_list/precursors.htm
[6] The complete US classification is available at http://www.access.gpo.gov/bis/ear/txt/ccl1.txt
[7] Rice, Mathew, ‘Clinton Signs Iran Nonproliferation Act,’ Arms Control Today, April 2000, available at http://www.armscontrol.org/act/2000_04/irnap00.asp
[7] Diamond, Howard, ‘Clinton Vetoes Sanctions Bill; Sets, Imposes New Sanctions on Russia,’ Arms Control Today, June/July 1998, available at http://www.armscontrol.org/act/1998_06-07/srsjj98.asp
[8] Diamond, Howard, ‘U.S. Sanctions Russian Entities for Iranian Dealings,’ Arms Control Today, January/February 1999, http://www.armscontrol.org/act/1999_01-02/rujf99.asp
[9] Iran Nonproliferation Act 2000, Summaries, Library of Congress, available at http://thomas.loc.gov/cgi-bin/bdquery/z?d106:HR01883:@@@D&summ2=m&
[10] On the visit of President of Sri Lanka and reaction to reports about imposition of sanctions on two Indian firms under the US-Iran Proliferation Act, 28 December 2005, Ministry of External Affairs, http://meaindia.nic.in/pressbriefing/2005/12/28pb01.htm
[11] ‘Imposition of sanctions on two Indian firms under the US-Iran proliferation Act 2000,’ Press Release, available at www.sandhya-group.com , http://www.armscontrolwonk.com/919/indian-firms-sanctioned-for-chemical-sale-to-iran
[12] On the visit of President of Sri Lanka and reaction to reports about imposition of sanctions on two Indian firms under the US-Iran Proliferation Act, 28 December 2005, Ministry of External Affairs, http://meaindia.nic.in/pressbriefing/2005/12/28pb01.htm
[13] ‘US sanctions against two Indian firms not justified: Govt,’ Outlook, 28 December 2005, available at http://www.outlookindia.com/pti_print.asp?id=344843
[2] Federal Register: December 30, 2005, Volume 70, Number 250, pp. 77441-77442, available at http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/2005/E5-8116.htm
[3] Chemical Weapons Convention, Annex on Chemicals, Guidelines for Schedules on Chemicals, available at http://www.opcw.org/html/db/cwc/eng/cwc_annex_on_chemicals.html
[4] The Australia Group is an informal arrangement which aims to allow exporting or transshipping countries to minimise the risk of assisting chemical and biological weapon (CBW) proliferation. The Group meets annually to discuss ways of increasing the effectiveness of participating countries’ national export licensing measures to prevent would-be proliferators from obtaining materials for CBW programs. All states participating in the Australia Group are parties to the Chemical Weapons Convention (CWC) and the Biological Weapons Convention (BWC). For more details please refer to the Australia Group Website at http://www.australiagroup.net/en/intro.htm
[5] Export control list: Chemical Weapons precursors available at http://www.australiagroup.net/en/control_list/precursors.htm
[6] The complete US classification is available at http://www.access.gpo.gov/bis/ear/txt/ccl1.txt
[7] Rice, Mathew, ‘Clinton Signs Iran Nonproliferation Act,’ Arms Control Today, April 2000, available at http://www.armscontrol.org/act/2000_04/irnap00.asp
[7] Diamond, Howard, ‘Clinton Vetoes Sanctions Bill; Sets, Imposes New Sanctions on Russia,’ Arms Control Today, June/July 1998, available at http://www.armscontrol.org/act/1998_06-07/srsjj98.asp
[8] Diamond, Howard, ‘U.S. Sanctions Russian Entities for Iranian Dealings,’ Arms Control Today, January/February 1999, http://www.armscontrol.org/act/1999_01-02/rujf99.asp
[9] Iran Nonproliferation Act 2000, Summaries, Library of Congress, available at http://thomas.loc.gov/cgi-bin/bdquery/z?d106:HR01883:@@@D&summ2=m&
[10] On the visit of President of Sri Lanka and reaction to reports about imposition of sanctions on two Indian firms under the US-Iran Proliferation Act, 28 December 2005, Ministry of External Affairs, http://meaindia.nic.in/pressbriefing/2005/12/28pb01.htm
[11] ‘Imposition of sanctions on two Indian firms under the US-Iran proliferation Act 2000,’ Press Release, available at www.sandhya-group.com , http://www.armscontrolwonk.com/919/indian-firms-sanctioned-for-chemical-sale-to-iran
[12] On the visit of President of Sri Lanka and reaction to reports about imposition of sanctions on two Indian firms under the US-Iran Proliferation Act, 28 December 2005, Ministry of External Affairs, http://meaindia.nic.in/pressbriefing/2005/12/28pb01.htm
[13] ‘US sanctions against two Indian firms not justified: Govt,’ Outlook, 28 December 2005, available at http://www.outlookindia.com/pti_print.asp?id=344843
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