DRAWING LESSONS FOR NUCLEAR EXPORT CONTROLS AND SAFEGUARDS
FROM STUDYING SUPPLY CHAINS AND COVERT PROCUREMENTS OF MILITARY
DUAL-USE ITEMS USED IN THE UKRAINE WAR

The analysis of covert procurements of military equipment and dual-use items for the deployment of unmanned aerial vehicles (UAVs) against Ukraine reveals lessons relevant to export controls and safeguards. A key overlap between nuclear-related trade controls and safeguards is oversight over manufacturing and supply capabilities of nuclear and dual-use items, necessary to control exports of items listed on a control list, regulate non-listed items restricted or prohibited to certain end-uses, and report relevant activities and exports to the International Atomic Energy Agency (IAEA). However, large-scale deployment of combat and reconnaissance drones in the Ukraine war reveals that components for UAVs were successfully procured on the international market. This paper presents examples of foreign-made dual-use items identified as used in large-scale production and deployment of UAVs. The examples highlight the increasing difficulty of understanding global supply chains for sensitive products and capabilities and countries’ difficulties in overseeing domestic manufacturing and supply potential of dual-use items. In many cases, the items sought by procuring countries are readily available for purchase on the open market, demonstrating a stringent need for enhanced end-user verification and catch-all mechanisms. Secondary and resale markets pose an even more complicated challenge. The examples further highlight the rising difficulties of focusing on narrowly-defined items listed on a control list. They provide a stark warning that proliferating countries adapt and work to undermine control lists, and highlight the need to counter this activity to undermine proliferating countries’ abilities to conduct covert, undeclared nuclear activities in violation of safeguards obligations. The identified challenges not only reduce the effectiveness of national export control systems but also the effectiveness of IAEA member state reporting based on activities and items listed in the Model Additional Protocol Annexes. They further reduce countries’ abilities to identify and voluntarily share other relevant procurement data with the IAEA. Updating the AP Annexes periodically is one important step that can be taken to help address these challenges, but more are needed. If unaddressed, these challenges may reduce the IAEA’s ability to detect the development of undeclared activities and contribute to the undermining of global non-proliferation goals more broadly.