Arms Control and International Security Papers 

Volume 11 Numbers 

May S, 2020

Iranian Nuclear Safeguards 

Concerns and the Integrity 

of the IAEA Safeguards 

System 

by Christopher A. Ford 

The Arms Control and International Security Papers are produced by the Office of the Under Secretary of State for Arms Control 

and International Security in order to make U.S. State Department policy analysis available in an electronically-accessible 

format compatible with "social distancing" during the COVID-19 crisis. 
Arms Control and International Security Papers 

Iranian Nuclear Safeguards Concerns and the Integrity of the IAEA 

Safeguards System 

Volume I, Numbers I May 5, 2020 

Iranian Nuclear Safeguards Concerns and the 

Integrity of the IAEA Safeguards System 

by Christopher A. Ford1 

In this issue of the ACIS papers, Assistant Secretary Ford discusses new 

evidence that has emerged suggesting the possible presence of undeclared 

nuclear material or activity in Iran, and what this information means, not just for 

Iran diplomacy but for the integrity of the global nuclear safeguards regime. 

Over the last year and a half, many Iran nuclearwatchers have been preoccupied by the United States' 

maximum pressure campaign on Tehran, the Iranian 

regime's gradual repudiation of the nuclear limits imposed 

upon it by the Joint Comprehensive Plan of Action 

(JCPOA), and the gradual expansion of that country's fissile 

material production and stockpile. These are very 

important issues, and they highlight the growing 

proliferation threat from Tehran. Most observers, 

however, forget that Iran's expansion of its fissile material 

production capabilities and material stockpile was 

foreordained, and was in fact legitimized, under the JCPOA 

itself. Iran has merely sped up the clock on the expiration 

of many of the deal's temporary restrictions. 

By its own terms, the JCPOA would permit Iran to do 

exactly what it is presently doing with its enrichment 

program, and more, in the coming years. None of the 

participants in the JCPOA have ever had a serious plan to 

deal with this problem, much less one that would involve 

actually pressuring Iran to accept enduring limits on its 

enrichment capacity. In fact, European diplomats 

staunchly resisted U.S. efforts to collaborate on such 

planning in late 2017 and early 2018, when Brian Hookwho is now the U.S. Special Representative for Iran - and I 

engaged in a long series of shuttle diplomacy engagements 

in hopes of securing such European cooperation. (After the 

Europeans' refusal to countenance placing long-term limits 

on Iran's program, the United States moved to reimpose 

sanctions it had previously lifted or waived in connection 

with the JCPOA.) 

Today, the United States remains committed to a 

diplomatic solution that meets this critical nonproliferation 

need. We have offered Iran the extraordinary step offull 

diplomatic normalization and sanctions relief if it abandons 

its range of provocative and destabilizing behaviors, and 

we are using every tool at our disposal to pressure the 

Iranian regime to come to the table. As committed as we 

are to a diplomatic solution, however, Tehran's ongoing 

and persistent refusal to cooperate fully with the 

International Atomic Energy Agency (IAEA) and to address 

questions about its possible undeclared nuclear material or 

activities doesn't exactly inspire confidence in Iran's ability 

to be a good-faith negotiating partner. 

For many observers, the critical issue of Iran's 

compliance with IAEA safeguards - and its compliance with 

Article Ill of the Nuclear Nonproliferation Treaty (NPT), 

which requires every non-nuclear-weapon State Party to 

accept IAEA safeguards for the purpose of verifying the 

fulfillment of its NPT obligations - has been lost in the 

diplomatic and political noise that has surrounded the 

JCPOA's failures. While most pundits and foreign 

diplomats have been wringing their hands over JCPOA 

issues, worrisome new nuclear safeguards concerns have 

1 Dr. Ford serves as U.S. Assistant Secretary of State for International Security and Nonproliferation, and is additionally peiforming the Duties of 

the Under Secretary for Arms Control and International Security. He previously served as Special Assistant to the President and Senior Director for 

Weapons of Mass Destruction and Counterproliferation on the U.S. National Security Council staff 
Arms Control and International Security Papers 

Iranian Nuclear Safeguards Concerns and the Integrity of the IAEA 

Safeguards System 

arisen in Iran for the first time in years. These recently 

reported Iranian safeguards issues deserve the world's 

attention: how they are handled will have huge 

implications not just in connection with the IAEA's "Iran 

file," but also for the future of the broader global nuclear 

safeguards system, the integrity of which is critical to 

international peace and security. 

The issue of potential undeclared nuclear material or 

activities in Iran has special salience in light of the 

extraordinary "nuclear archive" of documents and data 

from Iran's former weapons program - information that the 

Iranian regime had secretly stashed away, but that Israel 

acquired in early 2018 and that the IAEA and 

nonproliferation experts in various countries are now 

analyzing. One also cannot forget that Iran has retained 

not just the records but also many of the scientists and 

technicians who were previously involved in its illegal 

weapons program, embedding them in an organization 

known by the acronym of SPND and a number of its known 

subordinate and affiliated entities, where they are still 

working on nuclear weapon-relevant dual-use technical 

activities. Furthermore, as we noted in the State 

Department's 2019 Compliance Report. Iran also still kept 

them working under the leadership of the same official who 

formerly ran the Iranian weapons program, Mohsen 

Fakhrizadeh. 

Iran persists in denying that the archive even exists, 

while some have dismissed it as irrelevant ancient history. 

Others, however, have suggested that it represents a 

"shrink-wrapped" nuclear weapons program - inactive, but 

stored on the shelf, as it were - ready to be re-applied to 

actual weapons development and fabrication activity as 

soon as Supreme Leader Ali Khamenei chooses to give the 

order (such as when the expiration of JCPOA restrictions 

would have allowed Iran to accumulate enough suitably 

enriched material to move rapidly to fabricate a nuclear 

weapon). Determining what's really been going on will 

require full transparency and cooperation from Iran. In this 

context, the advent of new Iranian nuclear safeguards 

concerns suggesting the possible presence of undeclared 

nuclear material or activity, especially when coupled with 

the regime's gradual expansion of its fissile material 

production and stocks of enriched uranium, represents an 

enormous challenge for international peace and security. 

I. The Safeguards System 

The IAEA's global safeguards system was established 

more than six decades ago, inspired by President Dwight 

Volume I, Number 5 I May 5, 2020 

Eisenhower's famous "Atoms for Peace" speech at the 

United Nations in 1953, and it has since been dedicated 

both to promoting the peaceful uses of nuclear energy and 

to ensuring that peaceful nuclear technology and materials 

are not diverted for military purposes - specifically, to the 

development of nuclear weapons. The system of IAEA 

safeguards has always been critical to this endeavor. 

IAEA safeguards originated in connection with the 

emerging trade in nuclear technology that developed in the 

1950s and 1960s in order to increase supplier states' 

confidence that the nuclear technology they provided was 

not diverted to support nuclear weapons programs. As 

time has gone by, the IAEA and its Member States have 

incorporated lessons learned from real-life experience with 

proliferation challenges in order to make the safeguards 

system ever more effective. That system took on a new 

global significance in early 1970 after the entry into force of 

the NPT, which requires all NPT Parties that are nonnuclear-weapon states to accept IAEA safeguards on all 

nuclear material in peaceful activities in their states. After 

discoveries about the secret nuclear weapons program 

undertaken by Saddam Hussein in Iraq before the 1991 Gulf 

War, the IAEA undertook strengthening measures to 

provide improved IAEA verification authorities vis-a-vis 

ensuring the absence of undeclared material and facilities. 

Today, with its state of the art and de facto global 

standard represented by a combination of a 

Comprehensive Safeguards Agreement (CSA) and the 

Additional Protocol (AP) to that agreement, the IAEA 

safeguards system is of unsurpassed importance to 

monitoring nuclear activities worldwide and helping ensure 

that nuclear material and technology is not secretly in use 

for nuclear weapons work. This is what makes the current 

Iranian safeguards issues so worrisome, for a threat to the 

safeguards system anywhere is a threat to the safeguards 

system everywhere, especially when that threat comes 

from a country with Iran's woeful record over multiple 

decades of secretly undertaking nuclear weapons work and 

hiding nuclear material and activities from the IAEA. 

Today, the IAEA is continuing its vital worldwide 

safeguards missions in the face of unprecedented 

challenges from the COVID-19 pandemic, which has 

required special focus on protective equipment to keep 

inspectors safe and involved the navigation of international 

travel quarantine policies and transportation restrictions. 

The United States is working closely with the IAEA, to 

include providing important financial assistance, to ensure 

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Iranian Nuclear Safeguards Concerns and the Integrity of the IAEA 

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that the Agency can continue this crucial work around the 

world even in the present time of crisis. 

When it comes to Iran, however, the biggest threat to 

the safeguards system is the regime in Tehran itself, which 

seems to be once again - or perhaps more accurately, stillhiding information from the IAEA. This is important not 

only on account of the obvious proliferation risks that 

continued Iranian deception helps perpetuate, but also 

because such deception precludes the transparency and 

verification that is essential to the comprehensive 

diplomatic solution with Iran that we continue to seek. 

II. New Iranian Safeguards Problems 

The first public signs that new safeguards difficulties 

had arisen in Iran came in August 2019, at which point the 

IAEA reported to its Board of Governors that it was seeking 

cooperation from Iran on unspecified matters of concern 

related to Iran's implementation of its CSA and AP. The 

world learned more details in November 2019, at which 

point it emerged that the Agency had detected uranium 

particles of anthropogenic origin (i.e., originating from 

human activity) at a location in Iran that it had not declared 

to the Agency. This was reported to the IAEA's Board of 

Governors at a special session for that purpose on 

November 7, followed by a brief write-up of the matter in 

the IAEA's quarterly report on Iran. 

In fact, however, this latest saga of Iranian safeguards 

deception had begun much earlier. The IAEA inspectors 

found these man-modified uranium particles in 

environmental samples collected in February 2019 during a 

complementary access visit at a location that Iran had not 

declared to the Agency. For that complementary access to 

have occurred, the Agency's investigation had to have 

actually begun earlier- perhaps in late 2018, after public 

allegations surfaced that Iran had been hiding material and 

equipment at a site in Tehran called Turquzabad, only three 

miles from where the infamous "nuclear archive" had been 

stored. 

While the IAEA continues to evaluate Iran's latest 

explanation for the presence of these uranium particles, it 

is both worrying and very telling that well over a year into 

the Agency's investigation into this location - and despite 

multiple letters of inquiry and senior-level visits from the 

IAEA- Iran has thus far still proven unable or unwilling to 

conclusively answer the Agency's questions about the 

activities that occurred there, the origin and presence of 

those particles at this location, and the current 

Volume I, Number 5 I May 5, 2020 

whereabouts of any contaminated items that may have 

been their source. Iran has told a shifting, inconsistent, and 

incoherent array of stories to explain these sample results 

in some way that doesn't involve there potentially being 

nuclear material and activities still hidden in Iran. But it has 

failed thus far. And so the Agency's investigation 

continues. For well over a year. 

At present, in part because Iran has refused to 

cooperate honestly with the IAEA, it is impossible to assess 

how much nuclear material, if any, may have been 

previously present at that site and is now unaccounted for. 

Unexplained evidence of chemically processed uranium is a 

central concern of the IAEA safeguards system, of course, 

since it potentially indicates not just activities in violation of 

safeguards required under Article Ill of the NPT, but 

possibly even activities in violation of Article 11, the Treaty's 

central prohibition upon manufacturing or otherwise 

acquiring nuclear weapons. 

And as disturbing as this is, it is rather remarkably not 

the only safeguards question the IAEA is now investigating. 

The first signs of additional issues began to appear in late 

2019, but the world officially learned of more Iranian 

safeguards problems in March 2020, when IAEA Director 

General Grossi reported to the Board of Governors that Iran 

is also stonewalling the IAEA on new questions that have 

arisen about possible undeclared nuclear material or 

activities at three additional locations in Iran. Moreover, 

the regime in Tehran seems to have denied IAEA access to 

two of those sites while, as the United States noted during 

the Board proceedings, reportedly undertaking activities 

that look like sanitization -that is, the active concealment 

and removal of things that might allow Agency inspectors 

to ascertain what had been going on there. This is 

apparently the first case of Iran refusing verification 

required under the Additional Protocol. As the Director 

General put in recently, "This is a case of denial of access 

under the Additional Protocol. We never had a thing like 

this before." 

Many IAEA Member States recognized the gravity of 

the situation, speaking forcefully at the March meeting of 

the Board of Governors to urge Iran to improve its 

cooperation with the IAEA. However, it is amazing that all 

this Iranian obstruction of the IAEA has not received more 

public attention. This is the first time since the 2015 

adoption of the JCPOA that questions have arisen about 

Iran's compliance with its IAEA safeguards obligations and 

potentially also Article Ill of the NPT. Set in the context of 

Iran's gradual expansion of its nuclear capabilities, its 

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Iranian Nuclear Safeguards Concerns and the Integrity of the IAEA 

Safeguards System 

retention of the "nuclear archive" information, and its 

maintenance for so long of a cadre of ready-to-reemploy 

experts on nuclear weapon-related technologies under Mr. 

Fakhrizadeh that we publicly described in the 2019 

Compliance Report, this new evidence of potential 

undeclared material or activity and signs of Iranian 

safeguards deception deserves full-throated condemnation 

from everyone who cares about nonproliferation and the 

integrity of the global nuclear safeguards system. 

This new evidence of safeguards concerns in Iran 

suggests that the Iranian regime has returned to its welltrodden prior path of nuclear lies, obstruction, and 

safeguards non-compliance. As the IAEA itself 

summarized as early as 2003, 

"it is clear that Iran has failed in a number of instances 

over an extended period of time to meet its obligations 

under its Safeguards Agreement with respect to the 

reporting of nuclear material and its processing and its 

use, as well as the declaration of facilities where such 

material has been processed and stored." 

This activity included things that in light of the current 

problems will sound depressingly familiar: IAEA evidence of 

and concerns about undeclared material, followed by a 

parade of convoluted and unconvincing Iranian pseudoexplanations that serve to kill time while denials of 

inspector access permit sites to be sanitized and evidence 

to be hidden. 

To be sure, Iran's sanitation efforts while delaying or 

refusing inspector access failed to conceal evidence from 

the IAEA at the Kalaye Electric facility in 2003, but they 

were more successful in removing signs of the previously 

extant facility at Lavisan-Shian and Parchin, in 2004 and 

2015 respectively, before the IAEA was able to obtain 

samples at the sites. Recent events suggest that Iran has 

not stopped using this playbook. 

What is new today that was at least somewhat less 

clear on the public record in the early 2000s when those 

Iranian safeguards violations first surfaced, however, is that 

we all understand the context much better. This context 

situates Iran's pursuit of uranium enrichment capability at 

that time as the sine qua non engine for its past secret and 

illegal nuclear weapons program, which stretched all the 

way back to Iran's first steps to obtain centrifuge 

technology from the Pakistani nuclear weapon scientist 

A.O. Khan in the 1980s. As the IAEA reported in 2015. 

Volume I, Number 5 I May 5, 2020 

"a range of activities relevant to the development of a 

nuclear explosive device were conducted in Iran prior 

to the end of 2003 as a coordinated effort, and some 

activities took place after 2003." 

Thanks to revelations about the previously-secret 

"nuclear archive" acquired by Israel, even more is now 

publicly known about this Iranian nuclear weapons 

program, and about how disturbingly far this effort 

progressed before Tehran prudently suspended it under 

threat of U.S.-led United Nations sanctions - and perhaps 

more - in 2003. In light of what can now be seen in the 

"nuclear archive" about the nature and extent of Iran's 

previous nuclear weapons effort, it is clear that Iran's 

acknowledgments under the IAEA's "roadmap" for 

addressing outstanding issues related to the Possible 

Military Dimensions of Iran's nuclear program were grossly 

incomplete. 

The new safeguards issues that have arisen 

demonstrate that significant questions still remain about 

what nuclear materials, equipment, and information from 

Iran's past illegal nuclear weapons program remain hidden 

in Iran. It is possible that any such hidden nuclear material 

could contribute to renewed weapons R&D, should the 

Iranian regime make a decision to pursue such efforts, even 

if the quantity is "small" or the material is "old." 

Investigating evidence of potential undeclared nuclear 

material is the core mission of IAEA safeguards inspectors. 

Iranian deception, denials, and non-cooperation in the face 

of such evidence and in reply to Agency access requests 

must be viewed with the gravest concern. 

Ill. A Diplomatic Challenge 

All of this presents a serious diplomatic challenge for 

the entire international community. If Iran is allowed to 

refuse the IAEA access to which it is legally entitled, much 

less to continue doing so for months without repercussions, 

a dangerous message may be sent to all other states with 

safeguards obligations that those obligations are, in effect, 

optional. Therefore, irrespective of one's feelings about 

contentious JCPOA-related issues, no serious person 

should be unconcerned about these emerging Iranian 

safeguards challenges and the context in which they are 

embedded. 

As I have long lamented in both public and private 

capacity, the international community has a history of 

overcoming its collective action problems and responding 

to Iranian proliferation challenges more slowly than the 

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rate at which such Iranian provocations have themselves 

developed. But the nations of the world can do better, and 

the current safeguards problems that have arisen in Iran 

provide a chance to do so. These problems must therefore 

not be ignored, no matter how politically inconvenient they 

may be for the JCPOA's most ardent defenders. It is 

imperative that all countries join in insisting that Iran 

change course and start cooperating fully and completely 

with the IAEA in order to resolve all these concerns. 

And despite these challenges, there does remain a 

viable path forward to a peaceful and equitable solution 

with Iran. As Secretary Pompeo has long made clear. and 

as I and others have echoed. we believe it possible, and 

indeed highly desirable, to reach a negotiated settlement 

that imposes enduring constraints on Iran's nuclear 

program, and that reins in a range of malign Iranian 

behaviors that imperil regional peace and security. In 

return, we are willing to offer the Islamic Republic of Iran 

what no U.S. Administration ever has before: full 

normalization of diplomatic relations, including the 

exchange of Ambassadors, and full sanctions relief, if it 

agrees to a comprehensive deal. 

* * 

Arms Control and International Security Papers 

Volume I, Numbers I May 5, 2020 

This is no pipe dream. Indeed, I would think that the 

Iranian regime today- crippled by U.S. sanctions and its 

own corruption and economic incompetence, feared and 

detested by so many of its own people, bankrupting itself 

on foreign adventurism and destabilizing and costly missile 

proliferation, and now suffering tremendously from the 

COVID-19 pandemic - has every reason to sit down with us 

to work out such an answer. 

What no one needs - including Iran - is for safeguards 

concerns to linger and complicate this diplomatic challenge 

still further. For the sake of keeping alive the possibility of 

a diplomatic solution, for the sake of the integrity of the 

safeguards system, and for the sake of international peace 

and security, Iran must immediately come clean and truly 

cooperate with the IAEA. If Iran continues to refuse, the 

international community must stand shoulder-to-shoulder 

in support of the IAEA, including by imposing renewed 

international sanctions until Tehran provides such 

cooperation and finally establishes the basis for 

international confidence that Iran is no longer preserving 

elements of its past nuclear weapons program. 

* 

The Arms Control and International Security Papers are produced by the Office of the Under Secretary of State for Arms Control 

and International Security in order to make U.S. State Department policy analysis available in an electronically-accessible 

format compatible with "social distancing" during the COVID-19 crisis.