New Language in the 2019 report on “Adherence to and Compliance with Arms Control, Nonproliferation, and Disarmament Agreements and Commitments.”

This is a selection of major new content found in the 2019 Compliance Report versus the 2018 Compliance Report.

This document is prepared by the U.S. Department of State annually as, “a report providing a detailed assessment of the adherence of the United States and other nations to obligations undertaken in all arms control, nonproliferation, and disarmament agreements or commitments to which the United States is a participating state. The report is prepared with the concurrence of the U.S. Intelligence Community and in consultation with the U.S. Departments of Defense and Energy, and the Joint Chiefs of Staff.”



Country profiles are new this year except Russia, which was the only country covered last year. This is the most significant analysis since the 2015 compliance report, when 7 countries were covered.

United States

In compliance. New language describing Russian concerns over Lugar Center for Public Health Research in Tbilisi, Georgia that Russia claims “carries out double purpose research activities in the field of highly dangerous infectious diseases.” and U.S.-registered patents for “devices that appear to be prohibited by the BWC, as well as the Chemical Weapons Convention (CWC).” 


“Information indicates that the People’s Republic of China (China) engaged during the reporting period in biological activities with potential dual-use applications, which raises concerns regarding its compliance with the BWC… the United States does not have sufficient information to determine whether China eliminated its assessed biological warfare (BW) program, as required under Article II of the Convention”

“In 2017 and 2018, the United States engaged China on issues related to the BWC. The United States will continue to monitor China’s biological activities in relation to its BWC obligations.”


“The United States assesses that Iran has not abandoned its intention to conduct research and development of biological agents and toxins for offensive purposes”

North Korea

“The United States assesses that the Democratic People’s Republic of Korea (North Korea) has an offensive BW program and is in violation of its obligations under Articles I and II of the BWC.”


Same as 2018, “Available information does not allow the United States to conclude that Russia has fulfilled its Article II obligation to destroy or to divert to peaceful purposes BW items specified under Article I of its past BW program”



United States

In 2018, the United States continued to refute false Russian allegations of U.S. noncompliance with the INF Treaty associated with U.S. ballistic target missiles, armed UAVs, and the Aegis Ashore missile defense system. The U.S. side explained how its actions related to the use of ballistic target missiles fully comply with U.S. obligations under the INF Treaty and explained how and why the Aegis Ashore missile defense system is likewise fully in compliance with the INF Treaty. Additionally the Russian charge that armed UAVs violate the INF Treaty is unfounded as they perform as any other aircraft, where they launch, fly a mission and return to base upon completion. On December 4, 2018, Secretary Pompeo announced the U.S. intent to suspend its obligations under the Treaty within 60 days, should Russia fail to return to compliance.


  • Finding: The United States has determined that in 2018, the Russian Federation (Russia) continued to be in violation of its obligations under Articles I, IV, and VI of the INF Treaty not to possess, produce, or flight-test a ground-launched cruise missile (GLCM) with a range capability of 500 kilometers (km) to 5,500 kilometers, or to possess or produce launchers of such missiles.  On December 4, 2018, Secretary of State Michael Pompeo announced that the Russian Federation’s continued production, possession, and deployment of such a GLCM constituted a material breach of the Treaty. Secretary Pompeo also announced the United States would suspend its obligations under the Treaty in 60 days as a remedy for the Russian Federation’s material breach unless the Russian Federation returned to full and verifiable compliance.  The Russian GLCM in question is the SSC-8 SCREWDRIVER, which the United States assesses to be designated by the Russian Federation as the 9M729. For over five years, the United States has made very clear its concerns about the Russian Federation’s violation and the risks it poses to European and Asian security. The Russian Federation must verifiably eliminate all SSC-8/9M729 missiles, all SSC8/9M729 launchers, and all associated support equipment in order to come back into full and verifiable compliance with its INF Treaty obligations. On February 2, 2019, the United States notified the Russian Federation that the United States had suspended its obligations under the Treaty as a remedy for Russia’s material breach, as announced on December 4.  The United States also announced it would withdraw from the Treaty in six months in accordance with Article XV of the Treaty. The United States retains the right to revoke its notice of withdrawal from the Treaty before the end of the six-month period, and we would be prepared to consider doing so should Russia return to full and verifiable compliance.  Should Russia fail to do so, the U.S. decision to withdraw will stand, and the U.S. withdrawal will take effect August 2, 2019.  
  • Conduct Giving Rise to Compliance Concerns: The INF Treaty bans the possession, production, and flight-testing of intermediate- and shorter range missile systems, because the United States and the Soviet Union shared the view that these systems threatened peace and stability in the European region.  The Treaty required the complete elimination of the approximately 800 U.S. and approximately 1,800 Soviet ground-launched missiles with maximum ranges between 500 and 5,500 kilometers, their launchers, and their associated support equipment and structures. All such items were eliminated by May 28, 1991. The INF Treaty established a verification regime using national technical means of verification (NTM), notifications, and an on-site inspection regime to detect and deter violations of Treaty obligations.  The inspection regime concluded on May 31, 2001 – that is, 13 years after the Treaty’s entry into force – in accordance with Article XI of the Treaty. As stated in all editions of this Report since 2014, the United States has determined that Russia is in violation of its obligations under the INF Treaty not to possess, produce, or flight-test a GLCM with a range capability of 500 kilometers to 5,500 kilometers, or to possess or produce launchers of such missiles.  
  • Russia’s Motive: The United States assesses that Russia’s decision to violate the INF Treaty was born out of years of frustration with being prohibited from possessing ground-launched intermediate-range missiles even as perceived threats within these ranges were increasing around its borders.  Russia first raised this concern with the United States during a meeting between Russian Defense Minister Sergey Ivanov and U.S. Secretary of Defense Donald Rumsfeld in October 2004. At this meeting, Ivanov indicated that Russia wanted to exit the INF Treaty. By 2006, senior Russian officials began to voice publicly their frustration with the Treaty and raise interest in fielding ground-based intermediate-range missiles.  In March 2006, Major General Vladimir Vasilenko noted that “the deployment of a group of ground-based medium-range missiles may be considered as an additional means of ensuring national security.”  The following month, Defense Minister Ivanov said: “[t]he treaty is a Cold War relic. It has nothing to do with the contemporary environment whatsoever.”By 2007, Russia was open in its desire to end or change the INF Treaty.  In February 2007, Defense Minister Ivanov raised the possibility of mutual withdrawal from the INF Treaty with U.S. Secretary of Defense Robert Gates.  This was the first of multiple approaches by Russia during this timeframe that the United States declined. At the Munich Security Conference that same month, President Vladimir Putin voiced frustration with the Treaty’s limits and suggested that Russia was considering withdrawal, stating “[i]t is obvious that in these conditions we must think about ensuring our own security.” The Chief of the General Staff, Yuriy Baluyevskiy, added: “[t]he possibility of withdrawing from it does exist, if one of the sides provides persuasive evidence of the need for withdrawal…. Today this persuasive evidence exists.” More recently, at the Valdai Conference in October 2017, President Putin described the Treaty as “unilateral disarmament by the Soviet side” and rued the subsequent suicide of the Soviet Union’s chief missile engineer.

    When the United States refused Russia’s overtures to withdraw jointly from the INF Treaty, Russia shifted its focus to advocating for a “global” INF Treaty. The United States was open to this proposal, provided that other key states signed on. At the 62nd Session of the United Nations General Assembly, Russia and the United States issued a joint statement that marked the 20th anniversary of the signing of the INF Treaty and called on all countries to renounce ground-launched missiles banned by the INF Treaty.  Russia followed by submitting a written proposal for globalizing the INF Treaty at the 2008 Conference on Disarmament. France also proposed a global INF Treaty. Neither proposal went anywhere. Having failed in its attempts to mutually end or globalize the INF Treaty, Russia refused to remain constrained and focused on plans to violate the Treaty covertly. 

  • Russia’s Violation: Russia began the covert development of an intermediate-range, ground-launched cruise missile (the SSC-8/9M729) probably by the mid-2000s. The Novator design bureau was tasked to develop the missile. Although the 9M729 closely resembles and has features in common with other cruise missiles that Novator was developing at the time, specifically Russia’s R-500/9M728 ground-launched cruise missile for the Iskander system, as well as Kalibr naval cruise missiles, it is clearly a separate and distinguishable weapon.  As of the end of 2018, the United States assesses that Russia has fielded multiple battalions of SSC8/9M729 missiles. Russia was ready to test the SSC-8/9M729 cruise missile in the mid- to late 2000s in such a way that appeared purposefully designed to disguise the true nature of the activity.  Developers installed a fixed missile launcher for the SSC-8/9M729 at one of the test pads at the Kapustin Yar missile test range. This portion of the range historically has been used to test other missiles, which have been treaty compliant.Russia used the fixed launcher to flight test the SSC-8/9M729 cruise missile to distances well over 500 kilometers.  The flight-testing of cruise missiles to such ranges is allowed by the Treaty under certain conditions, but only if the missile is not being developed for ground-based use. The purpose of this exception is to permit the land-based testing of missiles not subject to the Treaty, such as submarine-based ballistic or cruise missiles. By using a fixed launcher for tests beyond 500 kilometers, Russia was attempting to conceal the fact that the SSC-8/9M729 missile is designed to be a ground-launched missile, and is therefore a violation of the Treaty.

    At a certain point in its development of the SSC-8/9M729, Russia needed to flight test the missile from its intended ground-mobile platform to verify the capability. These tests also occurred from Kapustin Yar. To mask the purpose of these tests, Russia was careful to fly the SSC-8/9M729 only to distances less than 500 kilometers rather than to its maximum range capability.  Russia probably assumed that its parallel development and deployment of the Iskander cruise missile—also tested from the same site—would provide sufficient cover for its INF violation. 

    By 2015, Russia had completed a comprehensive flight test program consisting of multiple tests of the SSC-8/9M729 missile from both fixed and mobile launchers at Kapustin Yar.  In March 2017, Novator’s General Director publicly acknowledged the successful test program for the SSC-8/9M729 and several other missiles during a Kapustin Yar anniversary ceremony, but provided no details on its capabilities.  Compared to its other modern cruise missiles, Russia remained conspicuously silent about the details of the SSC-8/9M729.

    To be clear, the SSC-8/9M729 represents a flagrant violation of the INF Treaty that Russia intended to keep secret. The U.S. finding is not based on a misunderstanding of this system or its capabilities. A cruise missile does not need to be tested from a mobile launcher to ranges over 500 kilometers to violate the INF Treaty. The Treaty also does not discriminate based on warhead type, although the SSC-8/9M729 is both conventional and nuclear capable.

    The history of Russia’s anti-INF overtures leading up to missile tests, its attempt to covertly exploit a Treaty exception permitting ground-based flight tests of intermediate-range for missiles not subject to the Treaty, its lack of an explanation for these tests, and its overall secrecy about the SSC-8/9M729 missile provide important context for Russia’s violation.   

    • SS-N-30a Naval Cruise Missile: Beginning in 2013, Russian defense industry and military officials publicly suggested that they would arm select ship classes with a cruise missile system designed to resemble a standard 40foot shipping container and notionally called Kalibr-K, but they did not specify which weapons it would contain.Among other weapons, the Kalibr missile complex includes the intermediate-range RS-SS-N-30a land-attack cruise missile (LACM), according to a Western defense journal report, which Russia has employed from naval platforms against targets in Syria.In early February 2019, several senior Russian officials, including President Vladimir Putin, publicly endorsed proposals to base sea-based Kalibr missiles on land. 
    • Analysis of Compliance Concerns: 
      • Relevant Treaty Provisions: Paragraph 2 of Article XV provides that each Party shall have the right to withdraw from the Treaty if it decides that extraordinary events related to the subject matter of this Treaty have jeopardized its supreme interests. It shall give notice of its decision to withdraw to the other Party six months prior to withdrawal from the Treaty. Such notice shall include a statement of the extraordinary events the notifying Party regards as having jeopardized its supreme interests. 
      • SSC-8/9M729 Ground-Launched Cruise Missile: As noted above, the INF Treaty prohibits States Party from possessing, producing, or flight testing cruise or ballistic missiles subject to the Treaty, or possessing or producing launchers of such missiles. There are four criteria that determine whether a State Party’s cruise missile is subject to the Treaty: 1) the cruise missile is considered to be ground-launched; 2) the cruise missile meets the Treaty definition (Article II, paragraph 2) of a cruise missile; 3) the cruise missile is a weapon-delivery vehicle; and 4) the cruise missile has a range capability equal to or greater than 500 kilometers, but not greater than 5,500 kilometers. Based on U.S. intelligence assessments, the United States has determined that the SSC-8/9M729 meets all four criteria. The United States has also determined that all launchers of the type that has contained, launched, or been tested for launching the SSC-8/9M729 are prohibited under the provisions of the INF Treaty. The United States has determined that the SSC-8/9M729 is an intermediate-range GLCM subject to the INF Treaty and that the possession, production, and flight-testing of this GLCM by Russia is in violation of obligations under the INF Treaty not to possess, produce, or flight-test such missiles (Articles I, IV, and VI).  As these obligations are essential to the accomplishment of the Treaty’s object and purpose, the United States found Russia’s violation to constitute a material breach. 
    • Efforts to Resolve Compliance Concern: Since declaring the Russian Federation in violation of the INF Treaty in July 2014 for the possession, production, and flight-testing of the SSC-8/9M729 ground-launched cruise missile system, the United States has pressed the Russian Federation to return to compliance with its obligations under the Treaty.  U.S. officials have raised U.S. concerns with the Russian Federation on repeated occasions and at various levels and departments within the Russian government, engaged the highest levels of the Russian government, and provided detailed information to the Russian Federation outlining U.S. concerns. They stressed that the Russian Federation’s continuing violation and failure to take concrete steps to return to compliance were impediments to improving bilateral relations and created an untenable situation whereby the United States complied with the INF Treaty while the Russian Federation violated it. 

      Since May 2013, the United States has taken the following concrete steps to address the Russian violation: 

      • Over 30 engagements with Russian officials at senior levels;  
      • Six expert-level meetings to discuss Russia’s violation (these included two sessions of the Special Verification Commission (SVC), the Treaty’s implementation body, and four bilateral meetings of technical experts;  
      • Two Russian entities involved in the violation were added to the U.S. Department of Commerce Entity List;  
      • Secured from Congress funding to start Treaty-compliant research and development on conventional, ground-launched, intermediate-range systems to show the Russian Federation the cost of endangering the INF Treaty; 
      • More than a dozen meetings within NATO regarding the INF issue.  
      • Since 2014, NATO has called on Russia to preserve the viability of the INF Treaty and since 2017 called on Russia to provide more transparency.  Within the last six months, NATO has issued two statements in which Allies expressed their strong support for the U.S. determination of material breach and full support for the U.S. suspension and notice of intent to withdraw;  
      • Multiple engagements going back to 2014 with Indo-Pacific allies, such as Japan, the Republic of Korea, and Australia, in bilateral dialogues to explain Russia’s violation of the INF Treaty and discuss the U.S. approach to bringing Russia back into compliance;   
      • Multiple engagements with allies since President Trump’s October 20, 2018, announcement, including with NATO at the highest levels, and 
      • Five annual compliance reports to Congress reflecting the U.S. finding of Russia’s noncompliance with the Treaty. 

        In an effort to resolve U.S. concerns at the technical level, the United States has convened multiple sessions of the INF Treaty’s implementation body, the Special Verification Commission (SVC).  Prior to 2016, the SVC had last met in October 2003 following the conclusion of the INF Treaty’s inspection regime in 2001. The November 15-16, 2016 SVC session was attended by Russia, Belarus, Kazakhstan, and Ukraine, and provided a multilateral technical venue for the United States to raise the issue of Russia’s violation of its obligations under the INF Treaty not to possess, produce, or flight-test a GLCM with a range capability of 500 kilometers to 5,500 kilometers, or to possess or produce launchers of such missiles.To assess Russian willingness to return to compliance with its obligations under the Treaty, the United States called for another session of the SVC from December 12-14, 2017. The North Atlantic Council issued a December 15, 2017 public statement, affirming U.S. compliance with the Treaty and urging Russia to address the serious concerns raised by its missile system “in a substantial and transparent way, and actively engage in a technical dialogue with the United States.”

        The United States continues to pursue resolution of U.S. concerns with Russia and is consulting with allies to review a range of appropriate options should Russia persist in its violation.  The United States has made clear to Russia that the United States will protect U.S. security and the security of U.S. allies, and that Russian security will not be enhanced by continuing its violation.  Additional information is provided in the higher classification Annex.



North Korea

  • Testing: North Korea has not conducted a nuclear test since its sixth nuclear test on September 3, 2017, which it claimed was of a hydrogen bomb. On January 1, 2018, Kim Jong Un announced that during 2017 North Korea had accomplished the goal of “perfecting the national nuclear forces.” 

    The United States assessed that the September 3, 2017, test produced a nuclear yield over 100 kilotons, making it significantly larger than previous North Korean tests.So far, the P’unggye Nuclear Test Site is the only assessed underground nuclear test site in North Korea. North Korea has conducted six nuclear tests at the P’unggye Nuclear Test Site: on October 9, 2006, May 25, 2009, February 12, 2013, January 6, 2016, September 9, 2016, and September 3, 2017.Kim Jong Un announced on April 20, 2018, that North Korea would discontinue all nuclear and ICBM tests and dismantle the P’unggye Nuclear Test Site. North Korea announced on May 25, 2018, that the P’unggye Nuclear Test Site had been “completely dismantled.” In a separate statement, the Nuclear Weapons Institute of the DPRK noted that “dismantling the nuclear test ground was done in such a way as to make all the tunnels of the test ground collapse by explosion and completely close the tunnel entrances.” Foreign journalists were invited to witness the “dismantlement” during a ceremony on May 24; however, international inspectors were not invited to verify the process, so the United States is unable to confirm the extent to which the site has been dismantled. Kim Jong Un’s commitment to allow a visit by U.S. experts to the P’unggye Nuclear Test Site has yet to occur.

    North Korea announced it would collapse the test adits, closing the entrances, and held a ceremony for journalists on May 24, 2018. During the ceremony, North Korea demolished the buildings in the adit support area.

    It is assessed that the results of the detonations at P’unggye Nuclear Test Site on May 24, 2018, are almost certainly reversible. It is possible that North Korea could develop another nuclear test site, if it chose to do so. 

  • Analysis of Compliance Concerns: Alternatively, North Korea could develop another nuclear test site. This, combined with North Korea’s failure to permit qualified international inspectors to observe and verify the dismantlement, calls into question North Korea’s long-term commitment to forego further nuclear explosive tests and the broader denuclearization process.
  • Efforts to Resolve Compliance Concerns: Following intensive diplomatic engagement and a thaw in relations between North and South Korea during the reporting period, President Donald J. Trump and Chairman Kim Jong Un held a first, historic summit in Singapore on June 12, 2018, and signed a joint statement in which Chairman Kim committed to work toward complete denuclearization of the Korean Peninsula. Since the summit, the United States has continued to engage with North Korea to work toward implementation of the commitments made in Singapore. On September 19, 2018, South Korean President Moon Jae-in and North Korean leader Kim Jong Un signed the Pyongyang Joint Declaration, in which North Korea expressed its willingness to take additional steps, including the permanent dismantlement of its Yongbyon nuclear facility if the United States “takes corresponding measures in accordance with the spirit of the June 12 U.S.-DPRK Joint Statement.” North Korea also committed in the Joint Declaration to “permanently dismantle the Dongchang-ri missile engine test site and launch platform under the observation of experts from relevant countries.” During the reporting period, in several multilateral fora, including the UN General Assembly, the UN Security Council, the Asia-Europe Meeting, the East Asia Summit, and the IAEA General Conference, countries from every region of the world recognized the unacceptable threat North Korea’s nuclear weapons program poses to international peace and security. The United States has also taken enforcement action, including U.S. Treasury sanctions designations, against those involved in UN and U.S. sanctions evasion.

    The United States continues to closely monitor North Korea’s nuclear activities. The denuclearization of North Korea remains the overriding U.S. objective, and the United States remains committed to continued diplomatic negotiations with North Korea toward the goal of achieving the final, fully-verified denuclearization of North Korea. The United States also continues to work with a broad range of partners and the international community on the need for continued pressure on North Korea – including full implementation of UN Security Council Resolutions (UNSCRs) on North Korea, continued diplomatic isolation of North Korea, and the need for continued vigilance against its proliferation activities worldwide – in order to impede its ability to sustain and advance its unlawful nuclear and ballistic missile programs and to incentivize negotiating progress. The United States remains engaged with the IAEA and welcomes the IAEA’s efforts to enhance readiness to resume monitoring and verification — 29 — activities in North Korea at the appropriate time. 


  • Finding: Although these violations remain resolved as of the end of 2015, new developments during the reporting period raise serious questions with respect to whether Iran intends to resume nuclear weapon-related activities at some point in the future. In April 2018, Israeli Prime Minister Netanyahu publicly disclosed that Israel had seized a vast archive of documents from Iran’s past nuclear weapons program. Efforts to evaluate the information in the archive are ongoing. However, the fact that Iran retained these materials in secret raises questions about whether Iran has taken active measures to deliberately deceive IAEA officials regarding activities related to possible military dimensions (PMD) of Iran’s past nuclear activities. As noted in the IAEA’s December 2015 Final Assessment on Past and Present Outstanding Issues regarding Iran’s Nuclear Program, moreover, Iran has yet to fully/satisfactorily answer significant questions regarding its past nuclear weapons program. Given Iran’s history of denial and deception, information acquired in 2018 could suggest efforts by Iran to conceal past activities that were nuclear-related, raising serious questions with respect to Iran’s compliance with its safeguards obligations and Article III of the NPT. 

    Iran preserved information from its historical efforts to aid in any future decision to pursue nuclear weapons, if a decision were made to do so.

  • Joint Comprehensive Plan of Action: In previous Compliance Reports, the United States reported on implementation by Iran of the non-legally binding JCPOA. On May 8, 2018, President Trump announced that the United States would no longer participate in the JCPOA, and on November 5, 2018, all U.S. sanctions lifted or waived pursuant to the JCPOA were re-imposed. The Trump Administration has made clear that the United States will continue to impose maximum pressure on Iran until it returns to the negotiating table and concludes a comprehensive deal that resolves all U.S. concerns, including those related to Iran’s past nuclear weapons program. Given that the United States is no longer participating in the JCPOA but did participate in the deal for part of the reporting period, this Compliance Report will examine, as a matter of discretion, Iran’s activities that are relevant to its JCPOA commitments without making adherence assessments.
  • Activity During the Current Reporting Period: The U.S. Intelligence Community assesses that Iran is not currently undertaking the key nuclear weapons development activities judged necessary to produce a nuclear device. However, Iran has retained files, documents, and personnel related to its past nuclear weapons program that it might leverage in support of a renewed nuclear weapons development effort following any decision to do so. In April 2018, in fact, Israeli Prime Minister Netanyahu publicly disclosed that Israel had seized from Iran a vast archive of documents from its past nuclear weapons program. In addition, Prime Minister Netanyahu announced in September 2018 at the UN General Assembly that Iran had maintained a warehouse facility located in Tehran thought to contain additional equipment and materials associated with Iran’s past nuclear weapons program. Netanyahu claimed that the warehouse once contained 15kg of nuclear material that had since been removed. 

    In December 2018, senior Iranian leaders warned that Iran is prepared to restart full-scale enrichment “to meet the country’s needs at any level and volume.“

  • Analysis of Compliance/Adherence Questions: Notwithstanding these assessments, Iran’s retention of files, equipment, and information dating from its pre-2004 nuclear weapons program, its efforts to conceal this information from the international community, and its reassignment of key Amad Program-era scientists and officials into a new organizational structure affiliated with Iranian military entities, suggest that Iran deliberately preserved information from its historical efforts to aid in any future decision to pursue nuclear weapons. New efforts by Iran to manufacture or otherwise acquire a nuclear weapon would be inconsistent with Iran’s obligations under Article II of the NPT. Information acquired in 2018 could suggest efforts by Iran to conceal past activities that were nuclear-related, raising serious questions with respect to Iran’s compliance with its safeguards obligations and Article III of the NPT. As the IAEA continues its investigation of the nuclear archive materials, any information confirming the existence of undeclared nuclear materials and/or activities for which Iran is not able to provide a defensible explanation would raise additional concerns with respect to its compliance with both its safeguards obligations and Article III of the NPT. In addition, any attempts by Iran to deny IAEA requests for information and access or otherwise interfere with the IAEA’s monitoring and verification activities would be a cause for significant concern.
  • Efforts to Resolve Compliance Concerns: On May 8, 2018, the President announced that the United States would no longer participate in the JCPOA, and would begin the process of re-imposing U.S. sanctions on Iran. As of November 5, 2018, all U.S. nuclear-related sanctions that were lifted or waived in connection with the JCPOA are back in full effect. The United States is also applying financial pressure on the Iranian regime to address the totality of its malign behavior. On October 11, 2018, the U.S. Department of Treasury’s Financial Crimes Enforcement Network issued an advisory to help financial institutions better protect against potentially illicit transactions related to Iran. U.S. sanctions re-imposed on November 5 target critical sectors of Iran’s economy, such as its energy shipping and shipbuilding sectors, as well as the provision of insurance and transactions involving the Central Bank of Iran and designated Iranian financial institutions. On May 21 2018, Secretary Pompeo made clear that it is the objective of the United States to use sanctions and other pressures upon Iran to incentivize it to accept a new, more comprehensive, and more enduring deal that would address the full range of Iran’s malign activities. He made clear that the U.S. objective is for Iran to cease all fissile material production, abandon its heavy water reactor project, and fully disclose its past nuclear weapons activities. The United States is working toward such a deal and has imposed unprecedented pressure upon Iran to this end, and has emphasized that pending such a negotiated solution, Iran must not expand its nuclear activities and capacities in any way.On March 22, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), together with the U.S. Department of State, designated 31 individuals and entities linked to Iran’s Defense Research and Innovation Organization (SPND), an organization subordinate to the Iranian Ministry of Defense and Armed Forces Logistics and led by Moshen Fakhrizadeh, the head of Iran’s pre-2004 nuclear weapons program. SPND has employed as many as 1,500 individuals — including researchers associated with the Amad Plan, who continue to carry out dual-use research and development activities, of which aspects are potentially useful for nuclear weapons and nuclear weapons delivery systems.


  • Finding: Given the IAEA’s finding of anthropogenic uranium particles at the site, we have compliance concerns with regard to whether any undeclared nuclear material might exist in Syria.
  • Efforts to Resolve Compliance Concerns: The IAEA BOG resolution also referred the matter to the United Nations Security Council (UNSC). The Security Council met once in 2011, following the IAEA’s referral, but took no action. The Security Council did not address Syria’s nuclear activities in 2012, 2013, 2014, 2015, 2016, 2017, or 2018. For the reporting period, in the face of clear Russian and Chinese opposition, the United States did not pursue UNSC action. However, the United States did ensure that the issue remains on the IAEA BOG’s agenda. For 2018, the IAEA noted there were no new developments, and continued to urge Syria to cooperate fully with the IAEA in connection with all unresolved issues. The United States did not hold any bilateral discussions with Syria on its nuclear program in 2018. At IAEA Board of Governors’ meetings during the reporting period, the United States and likeminded partners have regularly reiterated the need for Syria to urgently cooperate with the IAEA to remedy its longstanding NPT safeguards noncompliance, and called for continued reporting from the DG and maintaining the item on the Agenda for each quarterly Board of Governors’ meeting. The United States also raised the issue of Syria’s NPT noncompliance in national statements at the 2018 NPT Preparatory Committee meeting.




  • Finding: Based on available information, Russian activities during the 1995-2018 timeframe raise questions about Russia’s compliance with its TTBT notification obligation.
  • Conduct Giving Rise To Compliance Concerns: However, during the 1995-2018 timeframe, Russia probably conducted nuclear weapons-related tests at the Novaya Zemlya Nuclear Test Site. Depending on the nature of these tests, they could raise concerns regarding Russia’s compliance with its TTBT notification obligations. Additional information is provided in the higher classification version of this report. 
  • Efforts to Resolve Compliance Concerns: Efforts have been made to raise this issue in a P-5 context; so far they have been unsuccessful. Nonetheless, the United States will continue to monitor Russian activities at Novaya Zemlya and hold nuclear weapons states accountable with their TTBT obligations. The United States will pursue senior level bilateral dialogues with Russia on test site transparency and other confidence building measures.



In the 2018 Compliance Report, the section was titled “Moratoria on Nuclear Testing” and stated that the information in the section was classified. It did not discuss the “zero-yield” standard in the unclassified report. 


  • Finding: The information raised by DIA Director LTG Robert Ashley in his remarks at the Hudson Institute on May 29, 2019, including China’s possible preparation to operate its test site year round and its use of explosive containment chambers, coupled with China’s lack of transparency on their nuclear testing activities, raise questions regarding its adherence to the “zero-yield” nuclear weapons testing moratorium adhered to by the United States, United Kingdom, and France.
  • Conduct Giving Rise to Compliance Concerns: China probably carried out multiple nuclear weapon-related tests or experiments in 2018. Additional information is provided in the higher classification version of this report.
  • Efforts to Resolve Adherence Concerns and Next Steps: The United States has in previous years attempted to engage China in discussions about test site transparency, as a confidence building measure, and sought to begin the process by inviting the P5 States (China, France, the UK, and Russia) to the Nevada National Security Site. In addition, the United States will continue to monitor activities in China.


  • Finding: The United States assesses that Russia has not adhered to its nuclear testing moratorium in a manner consistent with the U.S. “zero-yield” standard. The United States, including the Intelligence Community, has assessed that Russia has conducted nuclear weapons tests that have created nuclear yield.
  • Efforts to Resolve Adherence Concerns and Next Steps: The United States has in previous years attempted to engage Russia in a discussion on test site transparency measures, as a confidence building measure, and sought to begin the process by inviting the P5 States (China, France, the UK, and Russia) to the Nevada National Security Site. In addition, due to ongoing activities in Russia, the United States will continue to monitor Russia for evidence of nuclear testing activities. 
  • Implications for U.S. Security and Other Interests: Russia’s development of new warhead designs and overall stockpile management efforts have been enhanced by its approach to nuclear testing. Our understanding of nuclear weapon development leads the United States to assess that Russia’s testing activities would help it to improve its nuclear weapons capabilities. The United States, by contrast, has forgone such benefits by upholding a “zero-yield” standard.



North Korea 

  • Additionally, North Korea continues to develop its ballistic missile programs. Because of North Korea’s proliferation, and as part of our efforts to take steps to impede its programs, we have continued to impose sanctions measures against entities and individuals involved in North Korea’s programs of concern. The United States regularly works with MTCR Partner Countries to combat North Korean missile proliferation. 


  • This failure to adhere to its November 2000 commitment is clearly reflected in its lack of action to address known and continued proliferation activities in support of Iran’s missile program by serial proliferator Karl Lee (a.k.a. Li Fangwei) despite repeated and consistent U.S. demarches for many years, U.S. steps to sanction entities associated with Lee, and a public U.S. offer of $5 million for information on Lee under the Rewards for Justice Program. In addition to the ongoing activities of Lee, Chinese entities continue to supply MTCRcontrolled items to missile programs of proliferation concern, including those in Iran, North Korea, Syria, and Pakistan in 2018, further raising questions about China’s adherence to its November 2000 commitment to the United States.
  • China’s Assistance to Iran: Nowhere is the current challenge posed by missile proliferation and the expansion of missile capabilities more clear than in the case of Iran. Iran possesses the largest missile program in the Middle East and continues to work to increase the size, sophistication, range, accuracy, and lethality of its missile arsenal. It is developing an array of solid and liquid propellant short-range and medium-range ballistic missile systems, and continues to push to expand its capabilities. We also remain concerned about the continuing ties between Chinese suppliers, and missile development efforts in places such as Iran – especially the activities of the infamous Chinese missile technology broker and fugitive from justice Karl Lee (a.k.a. Li Fangwei). Lee continues to shelter in China while serving as the most important overseas supplier of items and material for Iran’s missile program. Lee is a key broker for Iran’s ballistic missile program and provides significant assistance in supporting Iran’s ongoing efforts to develop more sophisticated missiles. The equipment and components that Lee has provide to Iran have contributed to Iran’s continued development of more sophisticated missiles with improved accuracy, range, and lethality.Despite a warrant out for his arrest, and more than a decade of imposing sanctions on Lee under the Iran, Syria, and North Korea Nonproliferation Act (INKSNA), including most recently in April 2018, the Chinese government, to date, has not taken effective action to end his proliferation activity. 
  • Efforts to Resolve Adherence Concerns: For this reason, Lee’s assistance to Iran in 2018 demonstrates the failure of China to adhere to its November 2000 bilateral commitment to the United States not to assist “in any way, any country in the development of ballistic missiles that can be used to deliver nuclear weapons (i.e., missiles capable of delivering a payload of at least 500 kilograms to a distance of at least 300 kilometers).” Separately, throughout 2018, the United States raised a number of cases with China concerning transfers of missile technology by Chinese entities to programs of concern in Iran, Syria, North Korea, and Pakistan. Although the United States has asked that China investigate and put a stop to such activities, most of these cases remain unresolved. In April 2018, the United States imposed sanctions against seven Chinese entities pursuant to the INKSNA for transferring missile technology to Iran.




The Republic of Tajikistan (Tajikistan) has joined the consensus adoption of each version of the Vienna Document (1990, 1992, 1994, 1999, and 2011) and of subsequent “Vienna Document Plus” Decisions. This is the first time Tajikistan’s adherence to the Vienna Document is being addressed in the Compliance Report.

  • Finding: Tajikistan failed to notify at least one major military exercise or activity for calendar year 2018.
  • Conduct Giving Rise to Adherence Concerns: Tajikistan failed to provide notification of at least one major military exercise or activity during calendar year 2018.
  • Analysis of Adherence Concerns: VD11, Chapter V, paragraph 38 states that participating States will provide notification in writing to all other participating States 42 days or more in advance of the start of notifiable military activities. Per the Vienna Document Plus Decision No. 9/12, at least one major military exercise or activity is to be notified annually if no military activity meets Chapter V notification thresholds. In March 2018, Tajikistani media reported that joint regional defense and mobilization drills involving 40,000 Tajikistani military personnel, Russian soldiers, and local personnel from across the region were held from March 6-14 at training grounds in the southern Tajikistani region of Khatlon. The exercises had not been notified in Tajikistan’s annual calendar nor in any separate Tajikistani notification, but Tajikistan allowed the United States to conduct an inspection in the area from March 12-15. Tajikistan also accepted two other Vienna Document inspections in 2018. In July 2018, the Tajikistani media reported on a joint Russian-Tajik military exercise in the Gorno-Badakhshan Autonomous Region lasting from July 17-21. The exercise reportedly involved some 10,000 Tajikistan and Russian military and security personnel, local reservists, and armored vehicles. It was not clear how many personnel were determined to be subject to VD11 and therefore subject to VD11 thresholds for notification and observation (over 9,000 and 13,000 personnel, respectively). The United States cannot determine conclusively if either exercise exceeded the VD11 notification threshold of 9,000 troops at any point during the exercise, or whether the exercises were conducted as a single activity or were under a single operational command. Even if Tajikistan concluded that this exercise was not subject to notification under VD11, Tajikistan could have reported it to fulfill the VD11 requirement to notify at least one major military exercise or activity annually even if no military activity meets Chapter V notification thresholds.
  • Efforts to Resolve Adherence Concerns: The United States discussed bilaterally with Tajikistan its VD11 commitments and shared concerns about lack of transparency for large-scale exercises. The United States will continue to highlight with Tajikistan, bilaterally and at OSCE meetings, the importance of complete and timely notification of military activities, particularly annual notification of at least one exercise or activity in the absence of any that exceed Chapter V thresholds. Military activities that are unreported or incompletely reported undermine the Vienna Document’s objective of building confidence through increased transparency. We will continue to encourage Tajikistan to be more transparent about its exercises to include providing additional details about their size and purpose.