INKSNA requires the President to provide reports on March 14 and September 14 of each year to the Senate Committee on Foreign Relations and the House Committee on Foreign Affairs, in which he or she identifies every foreign person for whom there is credible information that the person has transferred to or from Iran, North Korea, or Syria certain goods, services, or technologies mostly those controlled through four multilateral export control regimes and one treaty. Table 1 provides details on the purpose and items restricted in each one. In addition to these controlled items, INKSNA also includes a category of reportable items for goods, services, or technology, on a case-by-case basis, have the potential to make a material contribution to the development of nuclear, biological, conventional, or chemical weapons, or of ballistic or cruise missile systems. According to State officials, INKSNA’s broad list of reportable transfers and acquisitions and discretionary authority to impose sanctions provide the U.S. government an important and flexible tool to achieve its nonproliferation objectives and sanctioning capabilities found in no other U.S. law. INKSNA’s scope includes any transfers to or from Iran on or after January 1, 1999; Syria on or after January 1, 2005; and North Korea on or after January 1, 2006. INKSNA also authorizes the President to apply a range of measures against any foreign person the President has identified in a report he or she has provided to the congressional committees. The measures include (1) a prohibition on U.S. government procurement of goods or services from the person and a ban on imports of products produced by that person, except to the extent the Secretary of State otherwise may determine; (2) a prohibition on U.S. government provision of assistance, except to the extent the Secretary of State otherwise may determine; (3) a prohibition on U.S. government sales of any item on the U.S. Munitions List, and the termination of any ongoing sales of any defense articles, defense services, or design and construction services controlled under the Arms Export Control Act; and (4) that new licenses will be denied, and any existing licenses suspended, for transfers of items controlled under the Export Administration Act of 1979 or the Export Administration Regulations. Once imposed, INKSNA sanctions are in effect for 2 years at State’s discretion. In addition, INKSNA requires the President to notify the congressional committees of his or her rationale for not imposing sanctions against foreign persons identified in the report. Under INKSNA, the President cannot apply sanctions to reported persons if he or she finds that (1) the person did not “knowingly transfer to or acquire from Iran, North Korea, or Syria” reportable items; (2) the goods, services, or technology “did not materially contribute to the efforts of Iran, North Korea or Syria, as the case may be, to develop nuclear, biological, or chemical weapons, or ballistic or cruise missile systems, or weapons listed on the Wassenaar Arrangement Munitions List,” (3) the person is subject to the jurisdiction of a government that is an adherent to “one or more relevant nonproliferation regimes” and the transfer was consistent with such regime’s guidelines; or (4) the government of jurisdiction “has imposed meaningful penalties” on the identified person. The President has delegated INKSNA authorities to State. The Deputy Secretary of State exercises this authority by making sanctions determinations, and authorizing delivery of INKSNA reports to the committees. State arranges to have the names of the foreign persons deemed to have engaged in the sanctioned transfers or acquisitions published in the Federal Register soon after it delivers the reports to the committees. From 2006 to May 2015, State imposed sanctions on 82 foreign persons under INKSNA deemed to have engaged in reportable transfers to or acquisitions from Iran, North Korea, and Syria, primarily on persons located in China, Iran, Syria, and Sudan (see table 2). Seventeen of these foreign persons had INKSNA sanctions imposed on them more than once. State is not providing reports to the two cognizant congressional committees in accordance with INKSNA’s 6-month reporting requirements. Since 2006, it has provided six reports covering a 6-year period (2006 through 2011), instead of 18 reports covering a 9-year period (2006 through 2014), as required by INKSNA. If State had submitted a report every 6 months during this 6-year period as required by law, they would have produced 11 reports. Instead, each of the six reports covered a period spanning an entire calendar year and focused on transfers that first came to State’s attention in one of the six calendar years occurring between 2006 and 2011(see fig. 1). State provided these six reports at irregular intervals that have averaged 16 months, ranging between 7 and 22 months apart. It provided its most recent report in December 2014, 22 months after its previous report. The interval between the last two reports was the longest interval between reports since the beginning of 2006. State has not established a process that would allow it to comply with the 6-month reporting cycle required by INKSNA. State uses a complex and lengthy process that involves multiple interagency and internal reviews to compile credible information about a group of reportable transfers that first came to its attention in a single calendar year, and to determine whether to impose sanctions on foreign persons associated with those transfers. Because its process focuses on a group of transfers that came to its attention in a single year, State delays providing a report to the committees until it has resolved concerns it may have regarding any of the transfers in the group covered in the report and determined whether to sanction persons associated with any of those transfers. State officials begin preparing a new report every December, regardless of whether they have completed and provided all previous reports. State officials have told GAO they sometimes must delay work on one draft report to work on another, and that they can make only a limited amount of progress toward completing a new report before they have completed earlier reports. According to State, they use this approach because each report builds on the previous installment, including any determinations to defer a decision on sanctions and any determinations on whether to add nonlisted items to reportability on a case-by-case basis. As a result, State required almost 3 years to prepare its December 2014 report, which addressed transfers that first came to its attention in 2011. According to officials in the office responsible for producing the report— State’s Bureau of International Security and Nonproliferation’s Office of Missile, Biological, and Chemical Nonproliferation (ISN/MBC)—State’s process for implementing INKSNA consists of the12 following steps, as depicted interactively in figure 2 and described in appendix II. State officials told us that while the four State-led interagency working groups (named in figure 2 above) meet on a regular basis to evaluate reporting from a wide variety of sources on transfers and flag activity that might trigger INKSNA or other legal authorities, State typically begins the report preparation process, starting with compiling the activity for the draft report, once the relevant calendar year ends. The State Bureau of International Security and Nonproliferation/State Office of Missile, Biological, and Chemical Nonproliferation (ISN/MBC), working with other agencies and the Intelligence Community, compiles a list of transfers that first came to its working groups’ attention during the previous calendar year and then provides the list along with any diplomatic histories associated with each transfer to the Intelligence Community for fact checking and to determine whether the names of the foreign persons associated with the transfers are releasable to the Federal Register if State imposes sanctions. State then distributes the corrected package of transfers and any other information to the relevant interagency working group that includes the other federal departments involved in this process—the Department of Defense (DOD), the Department of Energy (DOE), and the Department of Commerce (DOC). Next, State chairs an interagency Policy Committee meeting (held at the deputy assistant secretary or office director level), where State and other members of the interagency working groups provide advice on whether each transfer is reportable under INKSNA and whether it should result in sanctions. This meeting is followed by reviews by State officials in geographic and functional bureaus. ISN/MBC includes the result of these reviews in an action memo that it sends to the Deputy Secretary of State for the final determination as to which transfers to include in the report and which persons to sanction in connection with those transfers. Following the Deputy Secretary’s determinations, State officials prepare the final version of the report, transmit it to the cognizant congressional committees, and arrange to have sanctions notices published in the Federal Register. Using this process, State has required, on average, more than 2 years to produce each of the six INKSNA reports that it provided to the cognizant congressional committees between 2006 and 2015. It required almost 3 years to complete the report it provided to the committees in December 2014 covering calendar year 2011. Our analysis of the production times of State’s six INKSNA reports indicates that the three longest stages of State’s process involve State’s compilation of potential reportable transfers into a single list (steps 1 and 2); State’s scheduling and holding of the sub-Interagency Policy Committee meeting (held at the deputy assistant secretary or office director level) to discuss the transfers (steps 4 and 5); and the Deputy Secretary’s review of the action memo in making his or her determinations (steps 8 and 9). For example, concerning the report State provided in December 2014, the Deputy Secretary required more than a year to review the action memo for transfers State learned of in 2011 and to determine which persons to identify in the report and whether to apply sanctions. State officials told us that a variety of political concerns, such as international negotiations and relations with countries involved in transfers, can delay State’s INKSNA process.