Sanctions Fail to Halt North Korean, Iranian Nuclear Ambitions: Top Expert

WASHINGTON — International sanctions are failing to contain dangerous North Korean and Iranian nuclear ambitions and proliferation efforts, according to a former top U.N. and U.S. expert (see GSN, Feb. 3).

Citing “insufficient accountability and insufficient consequences,” Victor Comras said more attention must be paid to monitoring forbidden WMD and arms trade around the world. “We often talk the talk, but what’s required is the application of appropriate resources and a political will to carry out these measures,” Comras told Global Security Newswire.
“North Korea continues to actively pursue a nuclear weapons program and a ballistic missile delivery system,” he added. The regime in Pyongyang is “completely flouting” the will of the U.N. Security Council.
Iran has also been undeterred by U.N. sanctions imposed over the nation’s nuclear defiance, Comras said.
“North Korea and Iran are very proficient at masking transactions and seeking to circumvent the sanctions,” he declared. “That’s big business.”
Comras was a longtime U.S. diplomat who worked on sanctions, terrorism and WMD issues. During his career, Comras also served on U.N. panels relating to sanctions and terrorism financing. Until late last year, he was Washington’s representative on the Panel of Experts that advised the U.N. Security Council on sanctions against North Korea related to the nation’s nuclear and proliferation activities.
In an extensive interview, Comras discussed the rising nuclear threat from North Korea, how the regime evades U.N. and international sanctions, efforts to curb Iran’s nuclear ambitions and the state of sanctions efforts on both countries. In the edited excerpts below, Comras also offered insight on other issues including the effectiveness of the U.N. experts panel he served on and the nuclear proliferation threat in the future.
Q: North Korea could have one or maybe more secret nuclear sites, according to the U.N. experts panel. What does that mean in terms of the threat from North Korea’s nuclear program?
Comras: It increases the danger of their capabilities in terms of military applications of nuclear weapons. The further they go down the line of developing a nuclear weapons capability, the more difficult it becomes to reverse that and to put the genie back in the bottle.
Despite the demands and the prohibitions, they have continued to progress secretly in undeclared facilities, in violation of the U.N. Security Council resolutions and their [Nuclear Nonproliferation Treaty] obligations, to bolster their threat against international peace and security (see GSN, Feb. 1).
It’s most disturbing because it shows that they are completely flouting their obligations under the Security Council resolutions. They’re doing precisely what the Security Council says they should not be doing.
Q: How could the recent experts committee report affect the deliberations of the U.N. Security Council and its sanctions committee on new penalties against the North Korea regime? (see GSN, Feb. 24)
Comras: I think there will be certain countries that don’t believe that they [new penalties] will be conducive to realizing the objectives set by sanctions.
A number of members of the sanctions committee feel that we need to take the measures already in place and assure their more effective implementation. There is discussion of additional measures that can be taken to deal with North Korea, although there is some view [that] simply raising the stakes in terms of additional sanctions may end up being less than productive. So, I suspect there will be some very high-powered discussions on these issues, although I’m skeptical that anything new will come out of the Security Council at this time.
Q: How would you summarize the sanctions against North Korea?
Comras: The U.N. sanctions are directed at the activities themselves that are of concern: prohibiting the development of nuclear weapons and of their delivery system of ballistic missiles. They impose an obligation on all states to refrain from providing any assistance, materiel, equipment sales, or financing — across the board — that could foster or assist in any way the nuclear capabilities of North Korea or of ballistic missile delivery systems. That goes for other weapons of mass destruction as well.
The penal part is really that there is an across-the-board, total prohibition against [sales] by North Korea of any weapons or military equipment, military items. That has been meant to deprive the North Korean regime of what was an important source of revenue, which was then applied to their nuclear and ballistic missile and weapons programs.
In the terms of sanctions that are meant to bite, there is a prohibition on the provision of luxury goods and luxury items to the regime, Caviar, fancy cars, boats — those items would at least impose some cost on the regime itself without imposing a cost on or depriving the general population, which lives on very basic necessities. So, luxury goods were meant to be a punishment of the regime: the elite, ruling class of North Korea.
Q: Are the other sanctions pushed by the U.S.?
Comras: There are a number of other countries that have imposed much broader sanctions than the U.N. Security Council resolution calls for. The United States has an across-the-board trade and financial embargo with respect to North Korea. … American officials have alerted the international business community to the risks associated with doing business with North Korea. In my personal view, it has been one of the more effective measures that have been adopted and that are having an impact on North Korea.
Bankers are very well aware of what happened to Banco Delta Asia in Macau and how the designation for … the Patriot Act, Bank Secrecy Act, ended up putting them out of business. And other financial institutions are very wary of dealing with North Korea. North Korea has a clear reputation for engaging in a number of illicit transactions that violate international standards, as well as money-laundering activities related to drugs and other illicit activities. And one recalls also the issue of counterfeiting of U.S. currency. So, banks have to be very wary of any dealings that they undertake with North Korea
Q: What are in the U.N. sanctions against Iran?
Comras: Very similar in many respects to what’s in the sanctions against North Korea, except there’s no prohibition of luxury goods. But there is a prohibition on anything related to the nuclear area or the ballistic area. There’s a prohibition on weapons. And there is a significant list of designated individuals and entities, all their financial activities are supposed to be blocked
The critical element in the new resolution [from 2010] was the fact that they laid the foundation for an obligation to inspect and interdict cargoes, including on the high seas. And the language made the European Union comfortable that it could go ahead and take further measures beyond the measures adopted by the Security Council.
The Europeans, which are Iran’s most important trading partner, have imposed a set of sanctions that go well beyond the Security Council measures. But they only came into effect in October of 2010. And I think it’s too early to determine how effectively they are being applied and implemented. There are some indications that implementation is still less than satisfactory.
Q: What are the U.S. sanctions on Iran? Do American sanctions alone matter?
Comras: Since 1995, we’ve had very broad sanctions imposed on Iran. It’s clear that in and of themselves, the U.S. sanctions have been digested by the Iranians. And that has limited the leverage that those sanctions have.
But what has been very effective is the very activist policies and postures taken by [former official] Stuart Levey in the Treasury Department to make international financial institutions very well aware of the risks that arise (see GSN, Jan. 25).
The [2010 Comprehensive Iran Sanctions Act] has had a significant impact on companies dealing with Iran. It’s a U.S. sanction that has made foreign companies aware that they may be subjected to a set of penalties which limits their ability to access the U.S. market. [As a result] a great number of Western companies have withdrawn from the Iranian market.
Q: In order to hurt the Iranians in this case, don’t there need to be sanctions against oil?
Comras: Well, the problem with the oil is it’s a sword that cuts two ways. The international community faces a tight oil situation to begin with. And 10 percent of the world’s oil is produced by Iran. What is in place from the European Union is the fact that Iranian ships that carry these goods are not permitted to come into European ports.
Q: Are Security Council sanctions in the case of Iran and North Korea sometimes ignored?
Comras: I’m not sure if I would use the word “ignored.” Not effectively implemented. In some cases, because of a lack of political will. In some cases, because of a lack of technical capabilities or a lack of awareness and knowledge. North Korea and Iran are very proficient at masking transactions and seeking to circumvent the sanctions. That’s big business.
Q: And some countries just don’t believe in them?
Comras: Well, it’s very clear that China has the ability, along with certain other countries such as Japan and South Korea and Russia, to impose a very stringent sanctions regime on North Korea. China is a major transshipment point for North Korea and perhaps could do a much better job in identifying cargoes that are suspect and interdicting them.
Q: Are sanctions a useful tool in situations dealing with North Korean and Iranian nuclear ambitions?
Comras: Sanctions are a necessary tool in dealing with the situation in North Korea and posed by Iran. If they’re correctly designed and implemented effectively, they can have a major impact on these regimes to dissuade them from continuing these policies. They make it much more difficult for these regimes to acquire the material and the financing necessary to do these programs.
They impose a significant cost on these regimes and must certainly at some point, bring into review whether the costs are worth their continuing these policies. And it affects some of those policy-makers directly in terms of depriving or imposing costs on them for their nefarious behavior.
Q: Why haven’t these penalties stopped Iran and North Korea from continuing their nuclear programs?
Comras: In terms of Iran, the Security Council resolutions until the last round were quite weak. They did not cut at the heart of stopping Iran or imposing a significant cost on the regime for carrying out these activities. In fact, the Security Council resolutions until the last round were counterproductive. They probably convinced the Iranian leadership that there was no cost that was going to be imposed on them that they couldn’t afford.
There’s a lot more to be done. The Security Council sanctions on North Korea are somewhat limited. Their application and implementation still remains somewhat at issue. The Panel of Experts only became aware [in recent years] of a certain number of compliance issues or cases where items were interdicted.

But what we saw from the [cargo] interdictions that were successful gave us concern there were a lot of prohibited goods still moving in and out of North Korea that were not being stopped. And the fact that North Korea has advanced as far as it has with respect to its uranium enrichment capabilities demonstrates that the sanctions have not stopped their getting access to certain needed imports of equipment and technology.

Citing “insufficient accountability and insufficient consequences,” Victor Comras said more attention must be paid to monitoring forbidden WMD and arms trade around the world. “We often talk the talk, but what’s required is the application of appropriate resources and a political will to carry out these measures,” Comras told Global Security Newswire.
“North Korea continues to actively pursue a nuclear weapons program and a ballistic missile delivery system,” he added. The regime in Pyongyang is “completely flouting” the will of the U.N. Security Council.
Iran has also been undeterred by U.N. sanctions imposed over the nation’s nuclear defiance, Comras said.
“North Korea and Iran are very proficient at masking transactions and seeking to circumvent the sanctions,” he declared. “That’s big business.”
Comras was a longtime U.S. diplomat who worked on sanctions, terrorism and WMD issues. During his career, Comras also served on U.N. panels relating to sanctions and terrorism financing. Until late last year, he was Washington’s representative on the Panel of Experts that advised the U.N. Security Council on sanctions against North Korea related to the nation’s nuclear and proliferation activities.
In an extensive interview, Comras discussed the rising nuclear threat from North Korea, how the regime evades U.N. and international sanctions, efforts to curb Iran’s nuclear ambitions and the state of sanctions efforts on both countries. In the edited excerpts below, Comras also offered insight on other issues including the effectiveness of the U.N. experts panel he served on and the nuclear proliferation threat in the future.
Q: North Korea could have one or maybe more secret nuclear sites, according to the U.N. experts panel. What does that mean in terms of the threat from North Korea’s nuclear program?
Comras: It increases the danger of their capabilities in terms of military applications of nuclear weapons. The further they go down the line of developing a nuclear weapons capability, the more difficult it becomes to reverse that and to put the genie back in the bottle.
Despite the demands and the prohibitions, they have continued to progress secretly in undeclared facilities, in violation of the U.N. Security Council resolutions and their [Nuclear Nonproliferation Treaty] obligations, to bolster their threat against international peace and security (see GSN, Feb. 1).
It’s most disturbing because it shows that they are completely flouting their obligations under the Security Council resolutions. They’re doing precisely what the Security Council says they should not be doing.
Q: How could the recent experts committee report affect the deliberations of the U.N. Security Council and its sanctions committee on new penalties against the North Korea regime? (see GSN, Feb. 24)
Comras: I think there will be certain countries that don’t believe that they [new penalties] will be conducive to realizing the objectives set by sanctions.
A number of members of the sanctions committee feel that we need to take the measures already in place and assure their more effective implementation. There is discussion of additional measures that can be taken to deal with North Korea, although there is some view [that] simply raising the stakes in terms of additional sanctions may end up being less than productive. So, I suspect there will be some very high-powered discussions on these issues, although I’m skeptical that anything new will come out of the Security Council at this time.
Q: How would you summarize the sanctions against North Korea?
Comras: The U.N. sanctions are directed at the activities themselves that are of concern: prohibiting the development of nuclear weapons and of their delivery system of ballistic missiles. They impose an obligation on all states to refrain from providing any assistance, materiel, equipment sales, or financing — across the board — that could foster or assist in any way the nuclear capabilities of North Korea or of ballistic missile delivery systems. That goes for other weapons of mass destruction as well.
The penal part is really that there is an across-the-board, total prohibition against [sales] by North Korea of any weapons or military equipment, military items. That has been meant to deprive the North Korean regime of what was an important source of revenue, which was then applied to their nuclear and ballistic missile and weapons programs.
In the terms of sanctions that are meant to bite, there is a prohibition on the provision of luxury goods and luxury items to the regime, Caviar, fancy cars, boats — those items would at least impose some cost on the regime itself without imposing a cost on or depriving the general population, which lives on very basic necessities. So, luxury goods were meant to be a punishment of the regime: the elite, ruling class of North Korea.
Q: Are the other sanctions pushed by the U.S.?
Comras: There are a number of other countries that have imposed much broader sanctions than the U.N. Security Council resolution calls for. The United States has an across-the-board trade and financial embargo with respect to North Korea. … American officials have alerted the international business community to the risks associated with doing business with North Korea. In my personal view, it has been one of the more effective measures that have been adopted and that are having an impact on North Korea.
Bankers are very well aware of what happened to Banco Delta Asia in Macau and how the designation for … the Patriot Act, Bank Secrecy Act, ended up putting them out of business. And other financial institutions are very wary of dealing with North Korea. North Korea has a clear reputation for engaging in a number of illicit transactions that violate international standards, as well as money-laundering activities related to drugs and other illicit activities. And one recalls also the issue of counterfeiting of U.S. currency. So, banks have to be very wary of any dealings that they undertake with North Korea
Q: What are in the U.N. sanctions against Iran?
Comras: Very similar in many respects to what’s in the sanctions against North Korea, except there’s no prohibition of luxury goods. But there is a prohibition on anything related to the nuclear area or the ballistic area. There’s a prohibition on weapons. And there is a significant list of designated individuals and entities, all their financial activities are supposed to be blocked
The critical element in the new resolution [from 2010] was the fact that they laid the foundation for an obligation to inspect and interdict cargoes, including on the high seas. And the language made the European Union comfortable that it could go ahead and take further measures beyond the measures adopted by the Security Council.
The Europeans, which are Iran’s most important trading partner, have imposed a set of sanctions that go well beyond the Security Council measures. But they only came into effect in October of 2010. And I think it’s too early to determine how effectively they are being applied and implemented. There are some indications that implementation is still less than satisfactory.
Q: What are the U.S. sanctions on Iran? Do American sanctions alone matter?
Comras: Since 1995, we’ve had very broad sanctions imposed on Iran. It’s clear that in and of themselves, the U.S. sanctions have been digested by the Iranians. And that has limited the leverage that those sanctions have.
But what has been very effective is the very activist policies and postures taken by [former official] Stuart Levey in the Treasury Department to make international financial institutions very well aware of the risks that arise (see GSN, Jan. 25).
The [2010 Comprehensive Iran Sanctions Act] has had a significant impact on companies dealing with Iran. It’s a U.S. sanction that has made foreign companies aware that they may be subjected to a set of penalties which limits their ability to access the U.S. market. [As a result] a great number of Western companies have withdrawn from the Iranian market.
Q: In order to hurt the Iranians in this case, don’t there need to be sanctions against oil?
Comras: Well, the problem with the oil is it’s a sword that cuts two ways. The international community faces a tight oil situation to begin with. And 10 percent of the world’s oil is produced by Iran. What is in place from the European Union is the fact that Iranian ships that carry these goods are not permitted to come into European ports.
Q: Are Security Council sanctions in the case of Iran and North Korea sometimes ignored?
Comras: I’m not sure if I would use the word “ignored.” Not effectively implemented. In some cases, because of a lack of political will. In some cases, because of a lack of technical capabilities or a lack of awareness and knowledge. North Korea and Iran are very proficient at masking transactions and seeking to circumvent the sanctions. That’s big business.
Q: And some countries just don’t believe in them?
Comras: Well, it’s very clear that China has the ability, along with certain other countries such as Japan and South Korea and Russia, to impose a very stringent sanctions regime on North Korea. China is a major transshipment point for North Korea and perhaps could do a much better job in identifying cargoes that are suspect and interdicting them.
Q: Are sanctions a useful tool in situations dealing with North Korean and Iranian nuclear ambitions?
Comras: Sanctions are a necessary tool in dealing with the situation in North Korea and posed by Iran. If they’re correctly designed and implemented effectively, they can have a major impact on these regimes to dissuade them from continuing these policies. They make it much more difficult for these regimes to acquire the material and the financing necessary to do these programs.
They impose a significant cost on these regimes and must certainly at some point, bring into review whether the costs are worth their continuing these policies. And it affects some of those policy-makers directly in terms of depriving or imposing costs on them for their nefarious behavior.
Q: Why haven’t these penalties stopped Iran and North Korea from continuing their nuclear programs?
Comras: In terms of Iran, the Security Council resolutions until the last round were quite weak. They did not cut at the heart of stopping Iran or imposing a significant cost on the regime for carrying out these activities. In fact, the Security Council resolutions until the last round were counterproductive. They probably convinced the Iranian leadership that there was no cost that was going to be imposed on them that they couldn’t afford.

There’s a lot more to be done. The Security Council sanctions on North Korea are somewhat limited. Their application and implementation still remains somewhat at issue. The Panel of Experts only became aware [in recent years] of a certain number of compliance issues or cases where items were interdicted.

But what we saw from the [cargo] interdictions that were successful gave us concern there were a lot of prohibited goods still moving in and out of North Korea that were not being stopped. And the fact that North Korea has advanced as far as it has with respect to its uranium enrichment capabilities demonstrates that the sanctions have not stopped their getting access to certain needed imports of equipment and technology.