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Licensing Mass Destruction Page 15 of 25

termed these companies "Specially Designated Nationals," and said that "when you deal with them, you're dealing with Saddam."

Total approvals to Iraqi Airways: over $50 million, including:

1. Compasses, gyroscopes, and accelerometers (ECCN 1485)
valued at $13 million in seven cases.

- The Commerce Department approved these sales without
external review in four of the seven cases, despite the fact that
these were missile items and were approved after the missile list
came into effect. All items under category 1485 are controlled
as missile items.

2. Navigation, radar and airborne communication equipment
(ECCN 1501) valued at $5 million in five cases.

- Approved without external review in four of the five cases.
3. Computers (ECCN 1565) valued at $5 million.

4. Aircraft, helicopters, engines and equipment valued at
$23,000,000.

5. Aircraft parts, boats, diesel engines, underwater cameras, and
submersible systems valued at $28 million.

Many of the items approved for Iraqi Airways fell into
categories that are listed, by their commodity control numbers,
as useful in the development, testing, production and
deployment of missiles capable of delivering nuclear weapons.
Items such as compasses, gyroscopes, accelerometers,
computers, radars and navigational equipment all fall into this
category. It is possible that some of these items aided the Iraqi
SCUD program.

The procedures by which missile technology exports are
approved are not available to the public. It is widely assumed
that at least the Department of State reviews and approves these
sensitive exports. However, the Department of Commerce
approved at least six exports that appear to be on the missile
technology list with no external review. In one case (B373514),
the Commerce Department approved over a million dollars'
worth of compasses, gyroscopes, and accelerometers without
consulting either the State or Defense Departments. All items in
category 1485 are missile items and should have been referred
to the State Department.

Iraqi Air Force:

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• Total approvals: $57 million, including:

1. Navigational, radar, and air communication equipment
(ECCN 1501) valued at more than $200,000 in nine cases.

- No external review in five of the cases (A839273, A858162,
A866417, B200489, B222433).

- State Department approved three of the cases.

2. Compasses, gyroscopes, and accelerometers (ECCN 1485)
valued at $957,500.

- Commerce Department approved without external review in
March 1989, despite the fact that these are missile technology
items.

3. Oscilloscopes (ECCN 1584) valued at $12,391 (case
A826888).

- Approved by State Department in May 1985.
4. Computers (ECCN 1565) valued at $11,394 (case B236580).

- No referral to Energy Department, as required for items on the
Nuclear Referral List.

5. Aircraft and helicopters (ECCN 6460) valued at $45.8
million.

- Approved by the State and Energy Departments from April to
June, 1988.

Iraqi Atomic Energy Commission: Responsible for nuclear research in Iraq, including Iraqi work on nuclear weapons.

• Total approvals: over $3 million, including:
1. Computers (ECCN 1565) valued at $2.9 million.

- The largest computer export, valued at $2.8 million (case
B175217) was approved by the Energy Department without
referral to the SNEC, whereas a second computer, worth only
$24,390 (B108166) was referred to the SNEC, indicating that
the SNEC did not receive the most important cases.

- A third computer was approved without referral to the Energy
Department, which is required for a commodity on the Nuclear
Referral List being exported to a nuclear end user for a nuclear
end use. This violated export control procedures.

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2. Precision electronic and photographic equipment (ECCN
6599) valued at $87,000 (case D042767).

- No referral for external review.

• Ten of the items approved for this end user were on the Nuclear Referral List, but only three were submitted to SNEC for interagency review.

Ministry of Defense: In charge of Iraqi defense operations.
Responsible for the State Organization for Technical Industries
(SOTI) and the Sa'ad General Establishment (both described below).

• Total approvals: over $567 million, including:

1. Computers (ECCN 1565) in eighteen cases valued at $2.1
million.

- Commerce referred only two of the eighteen cases to the
Energy Department, as required for items on the Nuclear
Referral List. Of the two cases referred to Energy, only one was
referred to the SNEC.

2. Compasses, gyroscopes and accelerometers (ECCN 1485) in
three cases valued at over $1 million.

- These items are subject to missile technology controls.

- Commerce did not refer one case (B204774) valued at $60,136
for external review, although the approval was in May 1987
after the establishment of the missile control list in April 1987.

3. Navigation, radar, and airborne communication equipment
(ECCN 1501) valued at $291,000.

- These items may be subject to missile technology controls.

- The bulk of the value of this approval was for case B353226,
valued at $264,000, which Commerce did not refer for external
review, despite the fact that the approval was in September 1988
after the establishment of the missile control list in April 1987.

- Commerce licensed this sale of dual-use military equipment to
a military end user without external review by the Defense
Department.

State Organization for Technical Industries (SOTI): Subdivision of
the Ministry of Defense. Commissioned the building and equipping of
DOT, a solid rocket motor production plant built as part of the Condor
II project. Also procured, according to U.S. officials, equipment for

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the Al-Hillah and Al-Fallujah SCUD modification projects and the space launch facility at Karbala.

• Total approvals: $1.4 million, including:
1. Oscilloscopes (ECCN 1584) valued at $20,000.

- Commerce approved three applications, two without the
external review required for items on the Nuclear Referral List.

- One oscilloscope went to Mansour, a military site described
below.

2. Computers (ECCN 1565) valued at $380,000 in five cases.

- Only one of the five cases was reviewed by the Energy
Department, as required for items on the Nuclear Referral List.

3. Measuring, calibrating, and testing equipment (ECCN 1529)
valued at over $143,000 in three cases (B052572, B156528,
B311058).

- Commerce licensed the largest approval (B052572), valued at
over $132,000, without an end use statement.

- Commerce referred only one of the three cases to the Energy
Department, although all three were on the Nuclear Referral
List.

- Commerce made no referral to the State Department, despite
the fact that this item appears to be on the missile technology
control list, and one of the cases was approved in 1988 after the
list went into effect.

Sa'ad General Establishment: A division of SOTI. Self-described as "a state organization specialized in the planning and erection of large industrial complexes for the Government of Iraq," Sa'ad does not operate any of the contracted facilities itself./15 According to MidEast Markets, Sa'ad only does work on military projects. Contracted for the construction of Sa'ad 16 at Mosul.

• Total approvals: $1.1 million, including:
1. Computers (ECCN 1565) valued at more than $450,000 in
seven cases (B177669, B224682, B265627, B271629, B350736,
E000057, E002881).

- No referral to the Energy Department, as required for items on
the Nuclear Referral List.

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2. Precision electronic and photographic equipment (ECCN
6599) valued at $290,000.

Monsour Factory (or Al Mansour): Linked to SOTI and served as a procurement agent, according to U.S. officials, for the SCUD enhancement facilities at Al-Fallujah and Al-Hillah, and the space launch center at Al-Anbar. According to press reports, purchased a high-speed oscilloscope from Tektronix.

• Total approvals: $5.2 million, including:

1. Electronic manufacturing equipment (ECCN 1355) valued at
$4.2 million.

- No referral to the State or Energy Departments.

- This equipment enables domestic production of transistors and
diodes for use in computers and other electronics, including
military systems such as communications and radar.

2. Electronic measuring, calibrating and testing equipment
(ECCN 1529) valued at $644,000.

- No referral to the Energy Department, as required for items on
the Nuclear Referral List.

- No referral to the State Department, despite the fact that this
item appears to be on the missile technology list and was
approved in October 1989 after the list came into effect.

3. Computers (ECCN 1565) valued at $354,000 and $12,000.

- No referral to the Energy Department, as required for items on
the Nuclear Referral List.

4. Superconductive electromagnets (ECCN 1574) valued at
$8,280.

- No referral for outside review.

Ministry of Industry and Military Industrialization (MIMI), formerly Ministry of Industry and Minerals: Run by Saddam Hussein's son-in-law Hussein Kamil al-Majid, with overall responsibility for Iraq's nuclear, missile and chemical weapon programs. MIMI ordered furnaces, the sale of which was blocked by the White House in June 1990 because of Iraq's plan to divert the furnaces to nuclear weapon production.

• Total approvals: $8.5 million, including:

http://www.wisconsinproject.org/pubs/reports/1991/licensemd.html 11/19/2002

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