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Analytical Center for Nonproliferation Problems SSC of RF - A.I.Leypunsky Institute of Physics and Power Engineering A Concept Of The Second Line Of Defense Against WMD Proliferation Pilot Project Obninsk (RUSSIA) 2000 Preface Now in the Russian Federation, two all-important mechanisms aimed to provide control over nuclear and nuclear-related materials, as well as commodities and technologies having some military application, have been properly developed and strengthened, namely:
We decisively differentiate the well-known full-scope customs functions from those customs goals that related to detecting and deterring the illicit trafficking of nuclear materials and other WMD sensitive commodities and technologies, which are subjected to export control under the RF Export Control Low. The suggested conceptual project of the Second Line of Defense against WMD proliferation has been developed in Analytical Center for Nonproliferation Problems at SSC of RF - A.I.Leypunsky Institute of Physics and Power Engineering (Minatom, RUSSIA) by a group of experts dealing with nuclear export control and general non-proliferation aspects. The concept is aimed to formulate basic conceptual provisions about structure of this system, about its functions and tasks, and about (the most valuable!) necessary correlation of the SLD with the systems of the First Line of Defense. The given concept considers an available and most reasonable composition of the SLD as a comprehensive system. It marks out possible ways for subsequent system development, and analyzes a management of interactions with the First Line of Defense systems. The draft project is offered for consideration of governmental and non-governmental institutions opposing WMD proliferation threats. The concept is not intended to determine finally the essence and composition of the SLD in the Russian Federation. It rather propones relevance in developing and strengthening such line and offers the most reasonable ways for it. Our author team would like to express the hope that the given paper can be used in future as a conceptual and informational background at development of an official federal document prepared by agencies and organizations concerned.
CONTENT 1. Introduction. General conceptual provisions and terms. 2. Major goals and tasks of the SLD  2.1. Major mission and functions2.2. Mandatory conditions of main mission accomplishment2.3. SLD organization chart2.4. Main threat to be opposed3. Scenarios for possible attempts of illicit jumping the SLD 3.1. Falsification of documents3.2. Falsification of cargo or parts of it.3.3. Camouflaging a part of cargo.3.4. An exporter uses documents provided by the law3.5. Stake on SLD staff malpractice in attempts to overcome the SLD3.6. Techniques of influence over SLD staff aimed to overcome the SLD by any illicit way4. Resistance to illicit export: tools and techniques 4.1. Customs violation prevention arrangements4.2. Methodical and technical perfecting the customs control over export/import trafficking4.3. Investigation and prevention of infringements related to the sensitive export4.4. Internal review of all own measures; integration of departmental legislative proposals5. Technical tools, methods, and procedures of the SLD 5.1. Operative technical means and procedures of the customs control5.2. High-efficiency sealing technology5.3. Implementing intrusion indicators5.4. Technical means for commodity identification5.5. Technical procedures of nondestructive control5.6. Technical procedures for sampling and providing an express-analysis in situ5.7. Referral of commodity to technical examination in customs examination labs or specialized centers for commodity identification5.8. Development, logistics and implementation of technical (and computer-aided) means, methods, and procedures for control in the SLD5.8.1. Analysis of technical needs for the SLD5.8.2. Marketing the advanced technical tools and methods for analysis of commodities and substances5.8.3. Development of the necessary equipment and methods for control and communications5.8.4. Technical instrumentation and timely upgrade of the SLD5.8.5. Providing calibration, technical service, repair, and upgrade of the SLD equipment5.8.6. Exploration of new technical equipment and methods of controls5.8.7. Technical training for the staff on the regular background5.9. Tracking the transportation of the cargo registered en route "regional (local) customs - customs-house on the state border" with application of up-to-date technical means6. Development of an operation interface for the SLD, MC&A and EC systems 6.1. Development of an operation interface for first and second lines of defense6.2. Regular cooperation management7. International cooperation 7.1. International cooperation role and scope7.2. SLD International cooperation directions and methods8. Evaluation of the SLD structure and activity efficiency 1. INTRODUCTION. GENERAL CONCEPTUAL PROVISIONS AND TERMS. 1.1. Terms and definitions Sensitive commodities - nuclear materials, equipment and technologies, as well as dual-use commodities and technologies, that are dangerous in terms of risk of their diversion to military goals or use in an illegal nuclear fuel cycle. The export of similar commodities is controlled after the national law and in accordance with provisions of the international regimes of nonproliferation and export controls. Fissionable and radioactive materials are examples of sensitive commodities. The export (the export transaction) is a coming-out of commodities, technologies, and services from the state to sell them on the outer market. The export transaction is implemented on the background of a commercial contract on sell/purchase/delivery of the commodities (services) and in the definite customs regime. It is available for control beginning from the moment of the contract conclusion and up to the full contract performance. The control over an export transaction should be comprehended as a capability to restrict, to inhibit, or to suspend/stop the transaction at some stage of its implementation as an act of enforcement in pursuance of the actual law. 1.2. Introductory provisions An export transaction, at its document processing stage, is controlled in framework of the internal compliance program of the exporting entity. The MPC&A system controls nuclear materials subjected to export up to the moment of their shipment, till they are in its account zone. The export control (EC) system controls the export operation on the level of authorization (the draft contract review, the agency/interagency adjustment of an export application, licensing, export control at customs clearance). The MPC&A and EC systems are the main elements of "the First Line of Defense" against to possible diversion of nuclear materials onto military goals or their application in a fuel cycle not safeguarded by IAEA. Prerogatives of the First Line of Defense is related to that status of a sensitive commodity when it is transformed from a production unit into a commodity (contract closing, packing, prepares to transportation, document forming), but not leaves yet its balance area or the commercial area of its producer/owner. Control over an export transaction on the customs area, i.e. at stages of customs registration (including shipping, storage, protection at storage and transportation, transportation, customs control, customs examination, export clearance), is fulfilled by the state bodies from the Second Line of Defense (SLD). A deposit of SLD successful activity is the close interaction and coherence of all system components of state control over foreign trade activities, both at a federal level, and at a level of the basilar executive boards. The key element of SLD is the customs. The Internal Affairs bodies, prosecutor's office, FSS, transporting state companies, Gosatomnadzor, Sanepidnadzor (Sanitary Epidemiological Inspection) can participate in control procedures at shipment, transportation, and also, if necessary, in enforcement. The customs control over the licensed commodity export/import occurs on the three interacting levels:
2. MAJOR GOALS AND TASKS OF THE SLD 2.1. Major mission and functions The main mission of the SLD is to block any illicit trafficking through state border of the nuclear and dual use commodities at attempts to accomplish export-import trade transactions with violation of the Customs code or the export control legislation. The basic SLD functions in terms of combating WMD proliferation are as follows:
For successful accomplishment of the main SLD mission, there are indispensable:
The key element of SLD is the customs-house. On various stages of customs registrations, cargo shipping and transportations, some other state control bodies, as Internal Affairs bodies, prosecutor's office, FSS, transporting state companies, Gosatomnadzor, and Sanepidnadzor can be involved in control procedures and also, if necessary, in the enforcement. So, the SLD efficiency will be ensured, firstly, by the customs control efficiency, secondly, by the productive collaboration of all the SLD elements, and thirdly, by capability of the SLD to development and updating. In light of this approach, the given SLD concept should consider:
To date the Russian customs includes seven Regional Customs Authorities servicing the corresponding new seven Federal Regional Districts. The integrated configuration of the Russian customs system is contributed by the following basic elements:
The fundamental threat to be combated by the SLD in interaction with the First Line of Defense systems is the WMD proliferation and/or development of a nuclear fuel cycle not covered by IAEA safeguards, using illicit commodity trafficking, and violating requirements of the international nonproliferation regimes. The given concept recognizes that the basic threat could be performed by a potential proliferator (a participant of WMD proliferation) through attempts of illicit overcoming the SLD, which are considered by the legislation as the VCR attracting the administrative/criminal law responsibility. In terms of methodology, an analysis of possible scenarios of the thread realization demands to consider of possible scenarios of illicit overcoming the SLD by proliferator. 3. SCENARIOS FOR POSSIBLE ATTEMPTS OF ILLICIT JUMPING THE SLD The following techniques and methods used to smuggle nuclear commodities and technologies are mainly observed in practice of the nuclear export control:
3.1. Falsifying documents The threat of document falsification should be considered as for documents reflecting (1) item title (Commodity Nomenclature of Foreign Economic Activity, CNFEA codes), (2) amounts, (3) owner/exporter, (4) purchaser/importer/end-user, and so on, and/or for regulatory compliance export/import documents. It is possible when item declare documents could be falsified after the authorizing documents have been issued (a challenge of hardening the document forms from a fabrication; a challenge of finding the fabrication). 3.1.1. There is a possibility of initial entering by the exporter of falsified entries in the documents on any by one or on a number of items:
Falsifying the consignment or its parts can be attempted by an exporter-proliferator with the purpose of illicit export. The supervisor of the custom-house should know the possible scenarios of similar falsifying. The greatest objection for falsifying the consignment is its reliable identification with consequent laying technical control means onto its packing. In cases, when the sensitive commodities are falsified as insensitive, an objection for falsifying can be only identification of the commodities. The customs control officers should have in their inventory the techniques, means and databases of "know-how" type, unknown to the contrabandists and persons, which are intentionally violating customs rules. These techniques and tools should be capable to expertise the commodities, which are not declared or declared by false name, quality, trademark, country of origin, etc. The similar databases could be developed in collaboration with producers of sensitive commodities, with technical experts, and customs specialists. The great danger is from falsifying complicated equipment and materials of complicated chemical composition. 3.3. Camouflaging a part of cargo The finding of a hidden part of the consignment is related to the professional qualification of the customs inspector. At the same time, to raise the efficiency of customs controls it is necessary to create and to manage the databases on techniques of masking a part of sensitive consignment. 3.4. An exporter uses documents not provided by the law It is necessary to consider a scenario of illicit export, when an exporter uses extralegal licensing documents. It can be documents issued by a state organ, commission, etc, not authorized to that, or documents of any arbitrary form signed by any high-ranking chiefs. Similar "documents" can have character of an application, an assurance, or a type of order. It can testify about exclusiveness of the case, yet not foreseen by law, etc. The final stake in this case can be made on father-figure of some state bodies (chiefs), and on availability of any chance that their power can substitute the regular proceedings. 3.5. Stake on SLD staff malpractice in attempts to overcome the SLD Any mechanism of violation of export control rules can be comprehended after the answer to a question on what sensitive commodities and in what volumes can be contrabanded by criminals. For this reason, knowing the control lists established by international export control regimes play the primary role in the skill of the customs officer. On the other hand, the sensitive commodities can be exported in different forms (export of products, tutoring, open publication, acquiring of patents, visits, donation etc.). All these forms have the specificity concerning possible techniques of falsifying, and therefore specific preventive measures should be developed and applied in the export control activity. The customs staff must have and know the new information about those world regions where illicit end use of nuclear and dual-use commodities and technologies is possible. The main attention should be paid to the threshold and near-threshold countries. The statistics testifies, that proliferators prefer to use definite countries for illicit trafficking, and through such countries most often the illicit consignments are transported. In particular, the USA services noted that Germany, Switzerland, the Great Britain, Canada, Hong Kong, the Netherlands, Mexico, Singapore, Belgium, Austria are those countries, through which one most often transit the illicit consignments. In such cases, the speech always goes about amicable countries as the most friend path. To particular features of modern international criminal activity threatening national concerns refer:
3.6. Techniques of influence over SLD staff aimed to overcome the SLD by any illicit way When a proliferator makes a stake on illicit overcoming the SLD, then proliferator's attempts are possible to affect the SLD staff by threats, bribery, blackmail etc. The arsenal of similar techniques aimed to manipulate some enforcement staff is known. The success of combating such attempts is determined by moral and strong-will qualities and psychological resistibility of the staff. Open/secret monitoring executed by enforcement structures for providing internal safety should not be excluded. The cases of any attempts to effect on staff should be registered and reviewed; in evidential cases, the actions should be entered against the violators/criminals. The enforcement staff should be acquainted with the possible scenarios of criminal effects and be ready for the proper countermeasures. 4. RESISTANCE TO ILLICIT EXPORT: TOOLS AND TECHNIQUES The SLD counterstand to the illicit export is performed on following areas of the SLD activity:
Into this line of activity on prevention of violations of customs rules enter: 4.1.1. informing exporters about procedures (registration) of export in compliance to the law. For resolving the task, the major significance would have the establishment of routine communications with internal compliance structures of the enterprises located in the area of regional customs house activity, as well as a regular information support for internal compliance program structures about existing standards both rules of customs registration and controls, and particularly - about their renewals. 4.1.2. the steady enforcement at any VCR case and regular informing the public about the VCRs will advantage the combat against similar VCR. The threat of acquiring a "contrabandist" image and losing the foreign business relations after publications about found and proved VCRs can give more effect on the exporter (commodity producer) than penal sanctions for the VCRs. 4.1.3. participation of the SLD experts in activity of existing systems aimed to educate exporters about the rules of customs registration and on the legislation and regulation in the sphere of export/import. This problem is considered in details below. 4.1.4. developing public relations. 4.2. Methodical and technical perfecting the customs control over export/import trafficking Processing export-import traffics through the SLD can be accelerated by introduction the following modern computer and means into practice both export control and customs control:
For investigation and prophylaxis of violations in the sphere of sensitive export, there are used all components of investigation (investigation technique, examination, signals, methods, information, study of the plan, check of data, analysis of sources, accumulation of evidence, availability of informers, support of departments, proving a crime, accusation, confiscation, arrest). The customs investigations can be executed in the pre-trial actions, in operations of customs registration and control, during review and adjudication of the VCR, criminal cases about contraband, as well as in judicial and arbitral procedures, and also in out-of-court action at law. The customs houses conduct investigation under the initiative or after a signal from the outside. The check of the licensing documents is executed in various interdepartmental commissions on FRM traffic surveillance, in state license body, or in the department of the exporter's subordination. The inquiry should contain the following data:
One should review as the licensing documents, as the customs documents (bill of lading, preliminary invoices and dock receipts, manifests of cargo, licenses, or other transport documents, cargo delivery instructions, consular fee invoices, commercial invoices, letters of credit, price lists, orders, delivery orders, insurance certificates, covering letters, bank records and related documents). Following component is the mastering and usage of modern monitoring instrumentation, which are capable to identify quickly nuclear materials and other delivered consignments, and to control transport vehicles and packing. Among methods involved in global practice for investigation of violations, for example, under the nuclear bargains, there are following techniques:
The annual review of own activity is conducted at all SLD levels with the purpose of revealing problematic clusters. The specific cases of export operations refer to problematic clusters, when there were occurred the challenges related with some gaps in the legislation, and in regulating or methodical base. Revealing and analyzing problematic clusters, and submitting legislative initiatives (the proposals on review of the control lists and decrees regulating the sensitive export), and submission of proposals on perfecting of technique and control procedures - are implemented according to the order accepted in the given SLD agency. 5. TECHNICAL TOOLS, METHODS, AND PROCEDURES OF THE SLD Customs-implemented control over sensitive commodities are featured by the fact, that these commodities usually are high-tech and high-end products, therefore SLD activity field becomes synthetic one, i.e. SLD involves legislative as well as engineering expertise. Then this provision on technical and methodological logistics will demonstrate exclusive importance and should be treated in the Concept under more dedicated and close scrutiny. Several up-to-date commodities and materials are featured by such controlled parameters, which could not be identified without implementing the devices and procedures specially developed. Besides, technical control means are purposed to improve routine customs control over consignment and covering documents; technical control means demonstrate some benefits as compared with control without technical assistance:
5.1. Operative technical means and procedures of the customs control 5.1.1. Operative technical diagnostics (OTD) of the customs documents: 5.1.1.1. Primary OTD; 5.1.1.2. Comprehensive OTD; 5.1.1.3. Technical review of the customs documents. 5.1.2. Operative technical inspection of the customs control issues: 5.1.2.1. Endoscopy; 5.1.2.2. Remote search of specific items whose presence within a consignment is a customs violation; 5.1.2.3. Remote volume or quantity control of specific sensitive commodities; 5.1.2.4. Remote diagnostics of the package innage. 5.1.2.5. Radiation control of fissile and radioactive materials. 5.1.3. Operative technical examination of the customs control issues:
5.1.5. Operative technical paperwork on the content of issues subjected to customs control:
5.2. High-efficiency sealing technology High-efficiency sealing technology of access control (seals, stamps, access indicators, identity tags) of consignment, package, containers, vehicle (car, tanker, container) is implemented to prevent unauthorized access to a consignment purposed to subtract, replace or add some items after control at an exporter site. High-efficiency seals under integrity state confirm that customs consignment status remains integer at transportation span "shipment yard - border post" or "regional customs post - border post". High-efficiency seals should be implemented for the well-identified consignment only, and directly at a producer site, shipment site, or regional customs storage. 5.3. Implementing intrusion indicators Intrusion indicators testify to the occurrence of a consignment access event (events) during transportation within line "shipment post - border post". Intrusion indicators do not limit a consignment access and testify only a consignment access during transportation stage. If intrusion indications are absent, the indicators confirm that the consignment retained its status identified at shipment moment. If intrusion indications are present, the consignment could be considered as unidentified one. The consignment, a loss of which could damage a safety issue, could be equipped by high-efficiency intrusion indicators, which could record access location and time and then transmit the data. All sensitive commodities should be categorized after their protection needed for transportation: implementing the indicator seal, force seal, high-efficiency intrusion indicators etc. 5.4. Technical means for commodity identification The commodities identification is a major extant problem of both export and customs control. Technical means contribution is a major issue of this area. 5.4.1. Detectors, analytical physical and chemical equipment, indicators, control points Regular technical control of identifying commodities, their quality and features need in establishment of technical control posts immediately at customs border posts. If sensitive commodities flow is rather significant for the customs check point, then border control attributes should be provided by physical and chemical equipment, detectors and indicators providing routine commodities analysis (especially - materials analysis) and including express analysis methods. Standardized technical control equipment layout should be implemented including site-specific control of local commodity flows. The technical means mounted for operative, additional, and comprehensive controls of fissile/radioactive materials (FRM) at major FRM traffic locations are an option of dedicated technical equipment. 5.4.2. Means for subject-oriented presentation of sensitive commodities A rather operative procedure of commodity analysis and identification at customs check point consists in comparison of its appearance and declared parameters against specifications typical for the commodity type. Commodity visualization should be developed. A customs post should possess related reference books on controlled commodities providing their appearance, major parameters and package type for commodities presenting most sensitivity as related with WMD proliferation limited by national control lists. An example is presented by Nuclear Suppliers Group's "Reference Book on Dual-Use Commodity List", developed by ORNL and LANL and translated into Russian by Russian State Center KURCHATOV INSTITUTE (1998). The data describes US-manufactured commodities only but some part of the book demonstrates international validity, e.g., description of typical peaceful use and possible diversion paths are independent from production place. The reference book russification and development of similar domestic commodity reference books for other national control lists are some examples of virtual urgent measures. The problem solution need in coordination effort of Customs, Export Control Authorities, MINATOM and other federal agencies, because of related information could be confidential. The reference books development provides only partial solution of sensitive commodities control and identification problem as related with customs posts. Seven control lists are valid in the Russian Federation now (disregarding military cooperation lists):
5.4.3. Reviewing by computerized analysis The reference data acquired for sensitive commodities could be transformed into computerized database (DB) accessible at a customs post. The DB could cover rather detailed information as compared with hard-copy reference books. Context and attribute search at the DBs provides an accelerated identification of a suspicious commodity. Besides, up-to-date electronic equipment and graphic software provide a development and visualization of 2-D images and their axonometric demonstration. Recent digital camera ensures copying and displaying of an item under motion. High-power hardware and related software for complex images recognition are should be located in review centers of SLD (special customs review labs and dedicated scientific identification centers (MINATOM, Russian Space Agency etc.). The centers and customs authorities are able to develop a database and unique knowledge base acquiring data on non-conventional events, occurring at controlling sensitive export. Implementing the systems opportunities provides qualitative identification of an item as related with control lists and elucidates if the commodity export validation needs in related licensing. The systems and nuclear materials' C&AS could comply with SLD problems as related with exclusion of unauthorized transfer of the sensitive commodities. These high-power smart data systems does not provide timely a complete review and identification of the sensitive commodities. Institutionalization of interlocked federal and intra-agency data networks is needed to offer on-line communication with managerial and review SLD centers and timeliness of an efficient review statement for involved state control bodies. 5.4.4. Communication LAN with technical reviewer for on-line advising E-mail is a routine tool now to get data exchange with remote addressees in several hours. Global Internet network provides more enhanced opportunities. Any Internet user can implement addresses and passwords to access public data of an addressee. A lot of Internet addresses and related legislative and engineering data useful for controlling the sensitive export should be used to develop catalogs and reference books supporting on-line search of a specific data. Very e-mail provides an opportunity in on-line communicating between customs posts and review centers or authorities. But this communication mode is an occasional link between participating e-mailers. Hierarchical networks should be created to provide efficient review and data support for all contributing SLD components:
The facts demonstrate the activity field coordination should involve all state bodies contributing to a structure of first and second line of defense (SCC, Department of trade and economic development, Minatom, Department of Defense and other departments). Decision-making and mutual approval should be made at top level and supplemented by establishment of interagency work groups for approval of conceptual and engineering aspects. 5.5. Technical procedures of nondestructive control Technical procedures of nondestructive control should identify a commodity (a material), its properties, and parameters without damaging package, opening container, and sampling. The requirement usually is due to fact the control should not violate ware integrity or package (container) integrity/tightness because of reasons as follows:
Other remote control methods implement virtual proper commodity (material) radiation (radioactive radiation, infrared thermal radiation) for its identification. 5.6. Technical procedures for sampling and providing express-analysis in situ In-situ sampling and express-analysis at border or regional customs post is feasible for acquiring the primary identification data for simple and regular cases (solution acidity, oil viscosity, alcohol liquids proof etc.). The analyses should be specified and well standardized after their scope, procedure, and hardware logistics. All other commodities and their properties should be identified by dedicated laboratories, the list and authority of which should be specified as well. 5.7. Referral of commodity to technical examination in customs examination labs or specialized centers for commodity identification Customs examination could be ordered in any field case. Major feature of the examination is in the fact, that the subjects of the examination are commodities proposed for transfer, under transfer, or transferred across a border, and the objects of the examination are properties, links, and relations which present these commodities in light of customs laws. But the examination is a high-tech and expensive constituent of customs business therefore it should be involved in efficient way. The goal could be achieved by proper customs regulations which provides clear categorization of whole examination and reviewer fields, of commodities to be identified in customs labs and of those to be examined by dedicated identification centers certified for operations of identification studies. Dedicated identification centers should be involved in cases, which assume special conditions, facilities, and laboratory methods unfeasible in customs laboratories. Federal regulations should state the procedures related with certifying identification centers and with implementation and management of identification review. Dedicated identification centers' cooperation with customs officers and reviewer should be operative one without any undue obstacles for trade operations. A lot of opportunities exist for improving the communication hardware (images transfer, advising by communication channels etc.) 5.8. Development, logistics and implementation of technical (and computer-aided) means, methods, and procedures for control in the SLD 5.8.1. Analysis of technical needs for the SLD Periodical review of technical needs for the SLD should be implemented. The needs could emerge in customs activity fields as follows:
Technical needs analysis is a basis for logistics, up-dates etc. 5.8.2. Marketing the advanced technical tools and methods for analysis of commodities and substances Marketing the advanced technical tools and methods for logistics of tasks mentioned above in item 5.1 should be carried out. The marketing findings are implemented for making decision what technical means type and where should be purchased and which technical means should be developed and produced by specific contractors. Major priority is involving domestic manufacturers providing more fast and low-cost update and replacement of excessive outdated equipment. Customs bodies could order new high-efficient means after tender mode. 5.8.3. Development of the necessary equipment and methods for control and communications Development of the necessary equipment and methods for customs control occurs when available off-the-shelf means does not comply to a demand as related with price, quality, or technical performance. Domestic development is of more benefit. 5.8.4. Technical instrumentation and timely upgrade of the SLD Technical instrumentation for customs control at regional and border sites should meet to recent technical performance. Otherwise threat of relaxing the export control of sensitive commodities emerges. Identification centers should be equipped after their major scientific profile and related task scope, technical logistics of customs posts and customs review laboratory should be established as dedicated bodies for controlling export of sensitive commodities. 5.8.5. Providing calibration, technical service, repair, and upgrade of the SLD equipment Technical updates of the SLD tools should be completed by maintenance of this instrumentation after manufacturer's specification. Related logistics should be mandatory implemented, otherwise all updates stages (development, purchase, installation, personnel training) will be wasted because of equipment will loss its operation condition and become obsolescent one. 5.8.6. Exploration of new technical equipment and methods of controls Exploration of new technical equipment and methods of controls for the SLD personnel will be carried out in training and refreshment system of the SCC. Personnel could be trained at other dedicated education bodies especially at companies and premises manufacturing the equipment. Regular refreshment courses should cover sensitive commodities data that constitute another important knowledge for customs officers. Hereto dedicated premises and institutions possess beneficial opportunities to provide training. 5.8.7. Technical training for the staff on the regular background Personnel qualification within all SLD system is of great importance for implementing the efficient export control of sensitive commodities. Involved export control personnel should know all valid legislation and regulation documents establishing the export control of sensitive commodities and especially the control lists. Export control specialists should accurately qualify the products to be exported (their pertinence to specific control list, commodity sensitivity as related with WMD proliferation and need in licensing procedures. Customs personnel should know as well if the commodity is itemized in a control list, what a matter is this commodity, and to operate available technical control means. Personnel training under regular mode is obvious means to establish valid skill, to maintain and refresh it. Now established customs personnel training system is under operation. A training system is under operation for personnel of internal compliance programs of Minatom and other agencies involved in sensitive export. Nevertheless, the systems are yet operated under independent mode derating their efficiency. Several regional education and training sites are necessary to train and refresh skill of the SLD personnel. The training sites for controlling the nuclear type commodities could be established in different Russian regions at several Minatom's enterprises, e.g., in Central Russia at RF SSC IPPE site (Obninsk), in Ural region at RF NC VNIITF site (Snezhinsk), in East Siberia (Krasnoyarsk or Irkutsk). These educational-training technical centers could meet all Russia demands and neighboring CIS countries as well. Minatom's enterprises possess some features beneficial for establishing the training centers. Minatom's enterprises produce and export most sensitive products (nuclear materials, equipment and technology). Therefore the enterprises could compile a set of most sensitive commodities covered by nuclear control list and major part of dual-use list. Then involved agencies could submit their request for refreshment or enlargement of the exhibition of commodities used for developing the missile weapons and other WMD. Minatom's enterprises possess up-to-date instrumentation and analysis harware for identifying nuclear and radioactive materials, for nondestructive analysis and express-analysis of chemicals. Minatom's enterprises are manned by skilled scientific and technical personnel pretty well to secure SLD personnel training and drill. Minatom's enterprises are well guarded and equipped by a physical protection, which restrict a proliferator's access to sensitive aids. Besides, conversion of Minatom persons to educational-training activity meets to conversion policy implemented in Russia. It should be noted, that similar approach has been used by USA where a nuclear site Hanford was implemented for regular training of US customs within framework of INTERDICT/RADACAD Program. Establishing the Russian training-drill centers could be started by a stage, at which US specialists will learn a team of future managers and trainers for Russian training-drill centers under establishment. US team knowledge and expertise could be acquired by a Russian team which could initiate Russia-USA agencies cooperation addressed to deployment of these training-drill centers and learning of SLD personnel. The group training could be started in USA (e.g., at Hanford or similar site), then completed at a Minatom's host premise (e.g., in RF SSC IPPE, Obninsk). RF SSC IPPE is an operator of two Minatom's agency centers - Russian Methodological and Training Center on Nuclear Materials Control and Accounting and Branch Expert-Methodological Laboratory on Export Control - which have specific expertise in managing and implementing education and advisory activities related with NMC&A and export controls. RF SSC IPPE provides all involved capabilities for accommodation and service of rather large trainees groups. The approach has been implemented when creating cooperation between Minatom's enterprises and national laboratories of the US Department of Energy in topics of export controls. Training activity for the SLD personnel could be supplemented by an exhibition of new commodities to be exported and of advanced domestic and foreign technical means for material analysis and commodities control. 5.9. Tracking the transportation of the cargo registered along the route "regional (local) customs - customs-house on the state border" with application of up-to-date technical means Transportation of the export cargo registered along the route "shipment yard - state border" has a number of risks:
Apparently it is a great need in a Categorization of commodities, export of which is controlled under nonproliferation regimes. The Categorization should include commodity groups requiring different levels of its protection at export transportation. 6. DEVELOPMENT OF AN OPERATION INTERFACE FOR THE SLD, MC&A AND EC SYSTEMS First and second lines of defense contribute to practical tools of the Nuclear Non-Proliferation Treaty (NPT) providing a legislative mechanism of deterring the nuclear proliferation and nuclear terrorism. The systems operation is rather independent; therefore their deep and advanced interaction is a most urgent need. The most benefit interaction could be started when dealing with information issues. 6.1. Development of an operation interface for first and second lines of defense The SLD, MC&A and EC operation interface development should ensure: 6.1.1. solving the cooperative tasks which could not be implemented by any single system; 6.1.2. common dataware support; 6.1.3. consulting and review support; 6.1.4. attending of one system personnel at training courses operated by an other adjacent system:
Regular interaction of first and second lines of defense need in a specific object-oriented conception development because of it involves complex inter-agency document approval and coordination issues. The systems interaction should evolve in the directions as follows: 6.2.1. Instituting the inter-agency coordination/advisory body (board) under regular operation (2-3 times a year) by related workgroups; 6.2.2. Common decision making at top level; 6.2.3. Implementing the common projects; 6.2.4. Establishment of on-line data communication; 6.2.5. Data sharing by agency information materials, bulletins etc. 7. INTERNATIONAL COOPERATION 7.1. International cooperation role and scope Nuclear nonproliferation issues do not present a national task only. Any isolated national approach could result in pronounced international impact. Therefore establishment and development of a permanent international cooperation system is an urgent need. Besides, national export control operation involves considerable amount of different resources (finance, computational efforts, skilled personnel, interagency activity). Establishment of national export control as a multilateral control constituent provides an enhanced efficiency and validity of the decision making, as well as reduce in total efforts spent by national export control authorities. The similar approach allows to state out that export control regime for nuclear engineering and commodities is a global target in searching nuclear nonproliferation contributing to the high-priority international cooperation. Russian Federation participates in all international actions aimed to nuclear nonproliferation, and therefore considerable acquired expertise could be implemented in adjacent CIS countries by technical assistance, specialist exchange, and consulting activity. Nonproliferation efforts of the Russian Federation in the world arena promote our national security. SLD constituents play an active role in implementing the international cooperation program. 7.2. SLD international cooperation directions and methods 7.2.1. Implementation of the international cooperation follows in two directions:
8. EVALUATION OF THE SLD STRUCTURE AND ACTIVITY EFFICIENCY Evaluation the proper structure and activity efficiency is a mandatory constituent of any system structure. The evaluation will provide a base for the system improvement. It should be carried out after all major activity directions in regular mode. As SLD is contributed by several elements under multi-agency authority, the proper activity review should search any element after a consistent procedure. The evaluation findings will be submitted to an inter-agency SLD board. The efficiency evaluation results for a stated period will be implemented to improve managerial, procedural and methodological issues targeted to efficiency enhancement. The recommendations consideration will result in intra-agency regulations or legislative proposals ensuring sustainable development of the SLD system. Development of a technique aimed to provide SLD performance tests could be also envisaged in framework of the activity. |
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