Source: Getty
commentary

Brazil, Argentina, and the Politics of Global Nonproliferation and Nuclear Safeguards

As possessors of advanced nuclear technology, Brazil and Argentina bear special responsibility for helping the international community and neighbors in their region feel confident that their nuclear programs are peaceful, secure, and safe.

published by
Editora UFSM, Federal University of Santa Maria.
 on November 29, 2016

Source: Editora UFSM, Federal University of Santa Maria.

Brazil and Argentina influence and are influenced by the global trends in nuclear nonproliferation and nuclear safeguards. This article describes the evolving trends in the global nonproliferation regime, reflects on international nuclear safeguards, and explains how these trends relate to unique challenges and opportunities facing Brazil, Argentina, and ABACC. As possessors of advanced nuclear technology, Brazil and Argentina bear special responsibility for helping the international community and neighbors in their region feel confident that their nuclear programs are peaceful, secure, and safe. Over the past 25 years, ABACC has played an indispensable role in strengthening such confidence by implementing nuclear safeguards in the two countries.

Politics of Nuclear Nonproliferation

Differences in Assessing the Threat

Historically, nuclear proliferation has been the preoccupation of advanced nuclear countries. Several concerns feed the fear of the spread of sensitive technology. In a strategic sense, acquisition of nuclear weapons technologies by new countries can disrupt the established nuclear order and the balance of power. The dual-use nature of nuclear technology calls for caution—the spread of nuclear technology for peaceful purposes comes with increased risk that some of that technology and associated material might be diverted for military use by states. Non-state actors can also represent a risk, as well-funded and well-organized groups might obtain nuclear or radioactive material and use it in their attacks. The threat of nuclear terrorism, like nuclear proliferation, has remained predominantly a concern of Western countries.

On the opposite side of the spectrum, the majority of non-Western, developing countries do not view nuclear proliferation as a fundamental threat to their security for a number of reasons. Due to the absence of strategic conflicts and existential threats, the use of nuclear weapons remains unlikely in many parts of the world. More apparent security threats that these countries face usually emerge from other sources—drug and arms smuggling, crime, economic and political instability, public health issues, and others. The risk of nuclear proliferation and its potential consequences (new nuclear-armed states or acquisition of nuclear material or weapons by non-state actors) remain abstract when compared with the more immediate risks facing these nations. Furthermore, the majority of non-Western developing countries believe that nuclear terrorism does not present an immediate or probable threat to their security. Western cities are still perceived as primary targets for global terrorism, despite the more recent history of terror attacks in non-Western countries.

Countries in South America belong to the latter group. For the last several decades the region has enjoyed peace. No major inter-state wars or deep ideological conflicts have occurred. Unlike the animosity between India and Pakistan that drives the nuclear arms race in South Asia, the regional competition between Brazil and Argentina never grew into an arms race. Moreover, the two countries have cooperated in the nuclear field for decades. Drivers for any country in South America to seek military nuclear programs are close to non-existent.

Many South American countries present the lack of progress on disarmament by nuclear-weapon states as one of the main qualms and sources of hesitation by non-nuclear-weapon states to embracing additional nonproliferation commitments. Since the United States leads the efforts to promote nuclear nonproliferation, countries such as Brazil pay special attention to what the United States does or does not do on the nuclear disarmament front.

Yet, at closer examination, lack of progress on the disarmament front does not appear to serve as the primary concern for either Brazil or Argentina. Instead both countries appear to be more concerned that developing countries’ access to nuclear technology might become hostage to the nonproliferation goals of developed countries.1 Past experience feeds these concerns. Particularly in the 1970s-1980s, the United States exerted pressure on suppliers of nuclear technology to limit cooperation with other countries in order to curb potential proliferation.

Arguments about fairness and justice in the global nuclear order also feature prominently in the discourse. Concerns about double standards in the global nuclear order are not new. The Nuclear Nonproliferation Treaty (NPT), which provides the foundation for the nuclear order, has long been considered to promote the division of countries into nuclear “haves” and nuclear “have nots.”

In recent years, however, voices expressing inherent unfairness codified in the NPT resounded more widely for two reasons. First, the Humanitarian Initiative, a coalition of states and civil society actors, which focuses on the humanitarian impact of nuclear weapons, gained impressive momentum. The 2010 NPT Review Conference final document included the language on the catastrophic consequences of use of nuclear weapons.  At the 2015 NPT Review Conference more than 150 countries supported the most recent statement by the Humanitarian Initiative. The Humanitarian Initiative, and the widespread support it received, amplified the voices of non-nuclear weapon states within the NPT forum.

Second, several emerging powers, by virtue of their growing standing in the international system and possession of advanced nuclear programs, became stronger participants in the discourse on global nuclear issues. These states include Brazil and Argentina, which have nuclear power infrastructure, are important players in the Nuclear Suppliers Group and in the IAEA, and hold leverage in the NPT forum.

A favorable security environment, concerns about access to nuclear technology for development and economic needs, and a sense of injustice about the existing global nuclear order all explain why Brazil and Argentina are less concerned about nuclear proliferation threats than major Western powers.

However, the regional context should serve as an impetus for Brazil and Argentina to adhere to high nonproliferation standards. It is in the interest of both nations that their neighbors in the region do not have any serious concerns about their advanced nuclear programs. Such concerns might include questions about power projection (such as in the case of Brazil’s nuclear-powered submarine program), nuclear material security, and nuclear safety (in relation to nuclear power plants in Brazil and Argentina).

Confidence in the peaceful nature of Brazil’s and Argentina’s nuclear programs remains by far the most critical component for regional confidence-building and stability. Existing arrangements, such as the nuclear safeguards regime implemented by ABACC, serve a very important role in that sense. But the existing arrangements have limitations, as will be discussed below, and the two countries might want to consider strengthening them.

Furthermore, the regional context calls for Brazil and Argentina to pay greater attention to nuclear security. Two parallel trends developing in South America demonstrate that nuclear security threats are not as abstract as they may have seemed in the past. First, there have been several cases of lost or stolen radioactive material in the region.2 Second, the region is not immune to terrorist threats. There have been concerns about the presence of terrorist groups such as Hezbollah and Hamas at the Triple Border area (Brazil, Argentina, and Paraguay).3 In the most recent example, Brazilian authorities arrested 12 individuals allegedly planning to carry out a terrorist attack.4 Taken together, these developments demonstrate that should criminals capable of procuring radioactive or nuclear material connect with potential terrorist groups, the end result might be a terrorist group in possession of nuclear material.

It should be noted that Argentina joined the Global Initiative to Combat Nuclear Terrorism, approved the International Convention for the Suppression of Acts of Nuclear Terrorism, and ratified the 2005 Amendment to the Convention on the Physical Protection of Nuclear Material (an amendment that significantly broadened the original scope of the Convention beyond nuclear material in international transport). Brazil has also signed the Convention and the country’s National Congress is considering ratification of the 2005 Amendment.

Nuclear Nonproliferation Regime: An Era of Exceptionalism and Precedents?

Two developments of the last decade—the embrace of a nuclear India and adoption of the Iran Deal—raise the question of whether the nuclear nonproliferation regime has entered an era of exceptionalism and precedence. It would prove useful to reflect on how these developments might influence the future of the regime.

Embrace of Nuclear India

Since 2005, U.S. policy has aimed to bring India, a state with nuclear weapons which remains outside of the NPT, into the nuclear mainstream. The U.S. government signed a nuclear cooperation agreement with India and proved instrumental in persuading members of the NSG to pass an exemption in 2008 for nuclear trade with India.

In 2009, the IAEA approved an Additional Protocol to India’s safeguards agreement. India’s Additional Protocol, however, does not include a number of critical components contained in the Model Additional Protocol that serves as a template for similar arrangements. India did not agree to provide the IAEA with information on fuel cycle R&D, nuclear imports, and uranium production, limiting agreed information-sharing to nuclear exports only. India also did not agree to provide the IAEA with complementary access. As a result, the IAEA has no authority to safeguard undeclared nuclear activities.5 Furthermore, a significant number of nuclear facilities in India remain outside of the IAEA’s safeguards purview, raising questions about the separation of military and civilian nuclear programs.

The question of potential Indian membership in the Nuclear Suppliers Group, a multilateral export control group, came to the forefront in 2016. While the U.S. government has offered full support for India’s membership, many nonproliferation experts and numerous NSG-participating governments have raised questions and concerns about admitting India into the NSG without preconditions. All members of the NSG are parties to the NPT. As a non-party to the NPT, India has not taken on important legally binding obligations associated with the NPT.

India might be admitted to NSG membership on the basis of certain conditions or NPT benchmarks. These might include India signing the CTBT, formally taking on commitments similar to the NPT’s main articles, and ceasing production of unsafeguarded fissile material. Should India accept these conditions, New Delhi would demonstrate its willingness to join all NPT participants in making nonproliferation commitments in exchange for the benefits of nuclear trade. However, accepting India into the NSG without any conditions would send a message that global nonproliferation objectives are subject to strategic and geopolitical interests, and that it is possible to benefit from access to nuclear trade while being outside of the formal nonproliferation regime. This will weaken the regime and strengthen cynicism about the nuclear order.

Iran Deal

The adoption of the Joint Comprehensive Plan of Action, commonly known as the Iran Deal, by the United States, United Kingdom, France, China, Russia, Germany, the European Union, and Iran remains one of the most consequential events for the nuclear nonproliferation regime of the last decade. In 2015, the Iran Deal parties agreed that in return for sanctions relief, Iran, which has violated its nuclear safeguards in the past, will accept caps on its nuclear program and greater scrutiny of its nuclear activities.

The Iran Deal contains provisions that allow Iran to benefit from the nuclear fuel cycle while offering greater confidence to the international community that its nuclear program is peaceful. For example, one of the main ideas underpinning the Iran Deal is that Iran’s production of nuclear material is commensurate with its civilian needs. The Iran Deal dictates that Iran cannot enrich uranium beyond 3.67%, a level sufficient for producing nuclear fuel for nuclear power plants but not for weapons. The Iran Deal imposes caps on the amount of enriched uranium and bans reprocessing for fifteen years. Another important component of the Iran Deal deals with verification. Under the agreed provisions of the Iran Deal, the IAEA has greater verification authority on uranium enrichment, centrifuge production, and the removal and storage of materials and equipment. In addition, Iran also accepted an obligation to implement an Additional Protocol.6

Some nonproliferation policy analysts encourage the international community to engage in a discussion on whether and how some components of the Iran Deal might be universalized.7 The Iran Deal offers practical ideas of how to distinguish between military and civilian nuclear programs, which can be a grey area. Several countries, including Russia, raised concerns about any attempts to universalize components of the Iran Deal. The text of the Iran Deal specifically states that its provisions and measures “should not be considered as setting precedents for any other state or for fundamental principles of international law and the rights and obligations under the NPT and other relevant instruments.”8

Regardless of whether the idea of universalizing some of the Iran Deal’s components gains any traction, the Iran Deal strengthens the norm of commensuration of nuclear activities and material with peaceful purposes and promotes higher nonproliferation standards, specifically regarding nuclear safeguards. This development is significant for Brazil and Argentina, given that they both have advanced peaceful nuclear programs.

Trends in Nuclear Safeguards

Evolving trends in the field of international safeguards hold relevance to Brazil and Argentina in multiple ways.

NSG Guidelines for Sensitive Trade

Until 2011, the NSG called for restraint with transfers of sensitive fuel technology – uranium enrichment and reprocessing (ENR). In 2011, the NSG adopted more specific guidelines, urging NSG members to limit transfer of ENR technology only to countries who signed Additional Protocols with the IAEA.

Brazil and Argentina insisted that ABACC safeguards arrangements be recognized as sufficient when considering ENR transfers. As a result, the language of the NSG guidance includes a notable acknowledgement of ABACC. According to adopted guidance, ENR technology can be transferred to countries with IAEA Additional Protocols in place and those “implementing appropriate safeguards agreements in cooperation with the IAEA, including a regional accounting and control arrangement for nuclear materials, as approved by the IAEA Board of Governors.”9

Different perceptions have emerged, however, regarding what the language on regional safeguards arrangements implies. It appears that Brazil and Argentina did not see it as a requirement to eventually conclude Additional Protocols. The Brazilian ministry of external affairs, for example, stated that the NSG started recognizing ABACC’s safeguards as “an alternative criterion to the Additional Protocol.”10

But the exact wording of the relevant passage on ENR transfer criteria includes an important caveat: it recognizes regional safeguards arrangements pending adoption of an Additional Protocol. Nonproliferation analysts suggest that this implies an expectation that Brazil and Argentina should sign Additional Protocols.

Experts closely familiar with the matter commented:

“The use of the phrase ‘pending this’ in the NSG decision links the concepts of the Model Additional Protocol and ABACC as an expression of hope that comfort with the ABACC arrangement will be bolstered in due course by the conclusion of additional protocols by both countries or at least the adoption of the key elements of the protocol that provide the highest level of confidence.”11 

Then NSG chair Piet de Klerk described it the following way: “we have formulated that the Additional Protocol is the norm when it comes to the export of sensitive facilities and equipment and technology.”12

The IAEA and the Future of Safeguards

Among developments within the IAEA, two stand out as relevant to Brazil and Argentina. The first concerns the future of safeguards as it relates to the State-Level Concept (SLC). While the State-Level Concept is not new, in 2012 the discussion about it grew into a heated debate involving the IAEA and the member states. The concept promotes the idea that any given country should be evaluated as a whole on the basis of all available information instead of on the basis of disparate information about individual facilities. The rationale driving this concept was a desire to utilize the IAEA’s resources more efficiently by tailoring safeguards to each state.

Several countries raised serious concerns about the concept, including but not limited to issues such as use of intelligence, potential subjective judgments about countries, and lack of clear information on how implementation of the State-Level Concept will affect them in practice.13

Brazil and Argentina were among the countries that raised concerns about the State-Level Concept both in terms of the substance of the concept and the way the IAEA Secretariat initially communicated with the states.

In 2013 after the IAEA Director General reported to IAEA member states on State-Level Concept (The Conceptualization and Development of Safeguards Implementation at the State Level (GOV/2013/38)), Brazil then voiced concerns on the substantive issues related to SLC and lack of clarity on what it entailed. Fundamentally, Brazil called for clearer answers on how the IAEA would draw safeguards conclusions about states. For example, Brazil sought answers on how member states could be assured that SLC would be in strict adherence to the different categories of safeguards arrangements that countries have with the IAEA (countries with Comprehensive Safeguards Arrangements (CSA), countries with CSA and Additional Protocol, countries with voluntary offer agreements, and countries under INFCIRC 66 provisions). Brazil voiced concerns about subjectivity of some factors that would feed into safeguards conclusions, such as “level of cooperation with the Agency.” Brazil noted that the GOV/2013/38 did not elaborate on what “safeguard-related information” entailed and on how open-source and third-party information would be used.14

Similarly, Argentina had concerns with the lack of clarity of how SLC was presented and the contradictions in terms of its contents and objectives.

Brazil and Argentina played an instrumental role in encouraging the IAEA Secretariat and the IAEA Director General to provide more information and to engage with member states in a productive dialogue.

The consultations that ensured and further information provided by the IAEA Secretariat, including in the Supplementary Document to the Report on the Conceptualization and Development of Safeguards Implementation at the State Level (GOV/2013/38) and its Corrigenda on State-Level Concept (GOV/2014/41 and GOV/2014/41/Corr1), alleviated Brazil’s main concerns.15 Of critical importance to Brazil was the affirmation from the IAEA Secretariat that SLC would not place additional rights or obligations on the states and would not substitute the Additional Protocol, and that acquisition path analysis would be focused exclusively on the acquisition of nuclear material in a nuclear weapon or nuclear device and would rely on technical methods and not on judgements about intentions.16 Brazil’s diplomats described as unprecedented the consultations and technical meetings between the Secretariat and member states and acknowledged that “for Brazil, this process introduced a new and encouraging dynamic in how safeguards issues should be dealt with within the IAEA.”17 Yet the country continues to monitor the process to verify it remains in conformity with the states’ respective safeguards agreements and does not shy away from pointing out remaining issues surrounding SLC that require clarification.18

In an interview with the author, a representative of Argentina acknowledged that the commitment of the IAEA Secretariat to consult fully and openly with countries provides a good basis for bilateral discussions and may help clarify issues. He noted an improvement in the IAEA Secretariat’s communication with states but added that more can be done in terms of its engagement.19

The second on-going issue within the IAEA that draws attention is the IAEA budget and funding. With a steady increase in the amount of nuclear activities around the world, the safeguards burden on the IAEA continues to increase because of the growing number of nuclear facilities and activities it must verify. According to a U.S. National Nuclear Security Administration report from 2008, the number of facilities under safeguards more than tripled over a 25 year period.20 In addition, the Iran Deal placed a considerable new burden on the IAEA to verify Iran’s nuclear activities. IAEA Director General Yukiya Amano stated that monitoring implementation of Iran will cost the IAEA $10 million per year.21

The implementation of strengthened safeguards since 1991 has increased the Agency’s costs. To meet the requirements of the State-Level Concept, the IAEA will also need to invest in its infrastructure, facilities, and expertise.22

Zero real growth in its budget means that the IAEA depends on voluntary and extra-budgetary funding. Although the IAEA’s regular budget includes expenses to carry out nuclear safeguards, even safeguards work depends on voluntary funding due to a limited budget.23 Brazil believes that all safeguards activities foreseen in the safeguards agreements between the states and the IAEA should be covered from the IAEA’s regular budget. In the case of the Iran Deal implementation, Brazil’s position is that the activities under the safeguards agreement and the Additional Protocol signed by Iran must be covered from the regular budget and the confidence-building measures beyond the comprehensive safeguards agreement and the Additional Protocol must be paid by extra-budgetary voluntary contributions.

Argentina similarly believes that, in principle, verification should not be subject to voluntary contributions and as a rule statutory activities should be covered from the IAEA regular funds.24

Late payments by member states of their contributions to regular budget further complicate the IAEA’s funding problems. Brazil and Argentina find themselves in the company of the United States and several other countries, who owe significant contributions to the IAEA regular budget. According to the IAEA financial documents, as of September 2015, Brazil owed 16 million Euros and 2 million US dollars and Argentina owed 2.2 million Euros.25 At the beginning of 2016, Brazil paid a small part of its contribution to the 2014 regular budget and, according to officials, aims to pay off its remaining debt as soon as possible. As of August 2016, Argentina has cleared most of its arrears.26

Currently Brazil and Argentina belong to a category of developing states “shielded” from paying their full share of the IAEA’s safeguards costs. Starting in 2017 they will no longer remain in this category and will have to pay the full share.27

ABACC at 25: Challenges and Opportunities

At twenty-five, ABACC’s main challenge is deciding whether and how the organization should evolve. Responding to this challenge creates opportunities for ABACC to strengthen its standing and make an even greater contribution to international and regional security.

The global trend towards higher standards in nuclear safeguards implies that sooner or later Brazil and Argentina might feel compelled to reconsider their positions on the Additional Protocol.

The arrival of the new administration in Buenos Aires in late 2015 rekindled a conversation in Argentina on the question of an Additional Protocol. Key advisors of President Mauricio Macri believe that signing an Additional Protocol will serve Argentina’s interests.28 In fact, Argentina might have more compelling reasons than Brazil to eventually sign an Additional Protocol. Given Argentina’s more export-oriented nuclear industry, signing an Additional Protocol might deliver political benefits and greater international confidence in its nuclear program.

Without a doubt, Argentina would prefer to make a joint decision with Brazil on whether both countries should sign an Additional Protocol. It remains in the interests of both Brazil and Argentina to move in tandem on this issue since the existing safeguards arrangements rely on bilateral cooperation within the ABACC framework. However, a scenario of Argentina moving first cannot be excluded.

Strong concerns remain in Brazil and Argentina among some stakeholders that signing an Additional Protocol would undermine the existing bilateral system of nuclear safeguards. In Argentina, in what appears to be a response to a renewed discussion on an Additional Protocol within the government, Grupo Convergencia, a group of prominent academics and specialists in international relations, defense, and security, released a statement asserting strong opposition to the possibility that Argentina might sign the Additional Protocol. In the document entitled “An Inconvenient Initiative in Nuclear Politics” the authors state the following:

“To advance unilaterally in that direction would imply putting an end to a system of guarantees and safeguards constructed 25 years ago by Argentina and Brazil that has made it possible that the use of nuclear energy in both countries could be carried out with exclusively peaceful ends.”29

Yet what is seen as a challenge can be turned into an opportunity. A decision by Brazil and Argentina to sign an Additional Protocol or move in a direction aligning more closely with its provisions could allow ABACC to evolve beyond its original mandate. One potential area of growth might involve granting ABACC authority to verify the absence of undeclared nuclear activities and undeclared nuclear material.

Another long-term challenge for ABACC will be safeguarding Brazil’s nuclear-powered submarine program. No precedent exists for safeguarding such a program in a non-nuclear-weapon state, and developing safeguards for naval fuel might be interpreted as a good policy and technical challenge for Brazil, Argentina, and ABACC. The uncertainty surrounding the future of the nuclear submarine program, however, may push this particular challenge into the future. The on-going large-scale anti-corruption investigation (Lavo Jato) that implicated several major contractors will likely delay construction.

Looking forward, a growing safeguards burden for the IAEA may open a window of opportunity for ABACC. ABACC could eventually take on more safeguards responsibilities, perhaps with the possibility that its mandate currently limited to implementing safeguards in Brazil and Argentina could evolve into a regional one. If that goal is pursued, important questions relating to the legal foundation, procedures, budget, recruitment of inspectors beyond Brazil and Argentina, and others will need to be addressed.

Nuclear safeguards, and the nonproliferation regime as a whole, are not static. By thinking ahead and responding to global trends, ABACC can become a more influential and consequential actor in this regime. 

The author gratefully acknowledges invaluable research assistance provided by Scoville Fellow Chelsea Green and Junior Fellow William Ossoff, both at the Carnegie Endowment for International Peace. A visiting fellowship from the Center of International Relations of FGV (FGV CPDOC) offered the author an opportunity to spend two months in Brazil in 2015 and to learn about the evolution of Brazil’s nuclear policy. The author thanks Laercio Antonio Vinhas, Ambassador, Permanent Mission of Brazil to the IAEA and CTBTO and Rafael Grossi, Ambassador and Permanent Representative of the Argentine Republic to International Organizations in Vienna for answering questions related to their countries’ policies and Mark Hibbs of the Carnegie Endowment for International Peace for comments on an earlier draft. The contents of this paper are the sole responsibility of the author. 

This piece originally appeared in Odilon Antonio Marcuzzo do Canto, ed., O Modelo ABACC: Um Marco no Desenvolvimento das Relações Entre Brasil e Argentina (The ABACC Model: A Milestone in the Development of the Relationship Between Brazil and Argentina), Federal University of Santa Maria, Editora UFSM, Brazil, 2016.

Notes

1 For relevant discussion on the importance of access to technology see the essays on Brazil and Argentina in Toby Dalton, Togzhan Kassenova, Lauryn Williams, eds., Perspectives on the Evolving Nuclear Order (Washington, D.C.: Carnegie Endowment for International Peace, 2016), http://carnegieendowment.org/2016/06/06/perspectives-on-evolving-nuclear-order-pub-6371.

2 Nuclear Threat Initiative, “CNS Global Incidents and Trafficking Database,” March 23, 2016, http://www.nti.org/analysis/reports/cns-global-incidents-and-trafficking-database/.

3 Andrea Machain, “Frontier in Terror Spotlight,” BBC News, September 10, 2002, http://news.bbc.co.uk/2/hi/americas/2248487.stm.

4 Holly Yan, Julia Jones, and Shasta Darlington, “Brazilian Police Arrest 12 Suspected of Planning Terrorist Acts During Olympics,” CNN, July 25, 2016, http://www.cnn.com/2016/07/21/americas/brazil-olympics-terror-arrests/.

5 Peter Crail, “IAEA Approves India Additional Protocol,” Arms Control Today, March 31, 2009.

6 Joint Comprehensive Plan of Action, July 14, 2015, U.S. State Department, http://www.state.gov/documents/organization/245317.pdf.

7 George Perkovich, “Iran Deal’s Building Blocks of Better Nuclear Order,” Carnegie Endowment for International Peace, June 9, 2016, http://carnegieendowment.org/2016/06/09/iran-deal-s-building-blocks-of-better-nuclear-order-pub-63780.

8 Joint Comprehensive Plan of Action, July 14, 2015, U.S. State Department, http://www.state.gov/documents/organization/245317.pdf.

9 Mark Hibbs, “New Global Rules for Sensitive Nuclear Trade,” Nuclear Energy Brief, Carnegie Endowment for International Peace, July 28, 2011, http://www.carnegieendowment.org/2011/07/28/new-global-rules-for-sensitive-nuclear-trade/4avp.

10 “Nuclear Suppliers Group (NSG) Recognizes the Quadripartite Agreement as an Alternative Criterion to the Additional Protocol,” ABACC, June 28, 2011, http://abacc.org.br/?p=3846&lang=en.

11 David S. Jonas, John Carlson, and Richard S. Goorevich, “The NSG Decision on Sensitive Nuclear Transfers: ABACC and the Additional Protocol,” Arms Control Today, November 5, 2012.

12 “The NSG in a Time of Change: An Interview with NSG Chairman Piet de Klerk,” Arms Control Today, September 20, 2011.

13 Laura Rockwood, “The IAEA’s State-Level Concept and the Law of Unintended Consequences,” Arms Control Today, August 28, 2014; Mark Hibbs, “Intel Inside,” Foreign Policy, December 10, 2012; “IAEA Safeguards Development and Russia’s National Interest,” 2014 Moscow Nonproliferation Conference, November 22, 2014.

14 Brazil’s Statement at the IAEA Board of Governors on Agenda Item 6 (B) The Conceptualization and Development of Safeguards Implementation at the State Level, delivered by H.E. Ambassador Laercio Antonio Vinhas, September 2013; Brazil’s Statement at the IAEA Board of Governors on Agenda Item (7b) Safeguards Implementation Report, delivered by Ambassador Laercio Vinhas, June 2013. 

15 Supplementary Document to the Report on the Conceptualization and Development of Safeguards Implementation at the State Level (GOV/2013/38), GOV/2014/41, report by the Director General, https://armscontrollaw.files.wordpress.com/2014/09/iaea-state-level-safeguards-document-august-2014.pdf.

16 Brazil’s Statement on the State-Level Approach at the IAEA Board of Governors, delivered by H.E. Ambassador Laercio Antonio Vinhas, September 2014.

17 Statement by H.E. Antonio de Aguiar Patriota Ambassador, Permanent Representative of Brazil to the United Nations, 2015 Review Conference of the Parties to the Treaty on the Non-Proliferation of Nuclear Weapons, New York, April 28, 2015, http://www.un.org/en/conf/npt/2015/statements/pdf/BR_en.pdf.

18 Brazil’s Statement on the State-Level Approach at the IAEA Board of Governors, delivered by H.E. Ambassador Laercio Antonio Vinhas, September 2014.

19 Author’s interview with Rafael Grossi, Ambassador of the Argentine Republic and Permanent Representative to International Organizations in Vienna, August 19, 2016.

20 “International Safeguards: Challenges and Opportunities for the 21st Century,” NNSA, https://nnsa.energy.gov/sites/default/files/nnsa/inlinefiles/NGSI_Report.pdf.

21 Laura Smith-Spark and Marilia Brocchetto, “U.N. Watchdog: We Need Money to Monitor Iran Nuclear Deal,” CNN, August 25, 2015, http://www.cnn.com/2015/08/25/world/iaea-iran-nuclear-deal/.

22 Trevor Findlay, What Price Nuclear Governance? Funding the International Atomic Energy Agency, Belfer Center, Harvard University, March 2016, pp. 19-20.

23 Trevor Findlay, What Price Nuclear Governance? Funding the International Atomic Energy Agency, Belfer Center, Harvard University, March 2016, p. 30.

24 Author’s interview with Rafael Grossi, Ambassador of the Argentine Republic and Permanent Representative to International Organizations in Vienna, August 19, 2016.

25 Statement of Financial Contributions to the IAEA: Report by the Director General, GC(59)/INF/6, Vienna, September 11, 2015 quoted in Trevor Findlay, What Price Nuclear Governance? Funding the International Atomic Energy Agency, Belfer Center, Harvard University, March 2016, p. 39.

26 Author’s interview with Rafael Grossi, Ambassador of the Argentine Republic and Permanent Representative to International Organizations in Vienna, August 19, 2016.

27 Trevor Findlay, What Price Nuclear Governance? Funding the International Atomic Energy Agency, Belfer Center, Harvard University, March 2016, p. 37.

28 Eduardo Diez, “National Development and Argentina’s Nuclear Policy,” in Toby Dalton, Togzhan Kassenova, and Lauryn Williams, eds., Perspectives on the Evolving Nuclear Order (Washington, D.C.: Carnegie Endowment for International Peace, 2016), http://carnegieendowment.org/2016/06/06/perspectives-on-evolving-nuclear-order-pub-6371.

29 Grupo Convergencia, “Una Iniciative Inconveniente en Política Nuclear,” in Spanish, translation by author, March 28, 2016, https://grupoconvergenciablog.wordpress.com/.