The State  Department coordinates the United States’ financial and policy  relationship with IAEA. Safeguards activities include on-site inspections, environmental sampling,  and remote monitoring. IAEA Has Been Asked to Verify and Monitor Iran’s Implementation of a Range of Nuclear-Related Commitments under the JCPOA

The JCPOA commitments IAEA has been asked to verify include limits on  Iran’s nuclear program, including those on numbers of centrifuges (for example, no more than 5,060 of specified  centrifuges at Natanz for 10 years); uranium enrichment levels (no more than 3.67 percent for 15 years);  stocks of enriched uranium (no more than 300 kilograms for 15  years); heavy water inventories; and  centrifuge manufacturing. IAEA Is Using Its Safeguards Authorities and Conducting Additional Activities to Verify and Monitor Iran’s Commitments

According to officials in IAEA’s Office of Legal Affairs, the agency draws  on its safeguards authorities to verify and monitor Iran’s implementation  of its nuclear-related commitments. Under the JCPOA, Iran agreed to provisionally apply, and seek  ratification of the Additional Protocol, which gives the agency’s  inspectors access to an expanded range of locations, including those  where the agency seeks assurance regarding the absence of undeclared  nuclear materials and activities. Under the JCPOA, IAEA is also conducting certain additional verification  and monitoring activities agreed to by Iran, such as containment and  surveillance measures for monitoring Iran’s uranium mines and mills,  according to IAEA officials. The JCPOA includes a  mechanism in which its participants commit to resolve access issues with  the agency regarding an undeclared location within 24 days after the  request is made. IAEA Has Identified the Financial, Human, and Technical Resources Necessary to Verify and Monitor Iran’s Nuclear- Related Commitments in the JCPOA

IAEA has estimated the financial, human, and technical resources  necessary to verify and monitor Iran’s implementation of its nuclear- related commitments in the JCPOA. Financial Needs

IAEA has estimated that it needs approximately $10 million per year for  15 years in additional funding above its current safeguards budget to fund  additional inspections, among other things, under the JCPOA. IAEA officials said that consistent with its Statute, the Director General  intends to propose to the Board of Governors that the approximately $5.7  million in costs associated with Additional Protocol activities and inspector  and other direct staff costs attributable to the JCPOA be funded through  IAEA’s regular budget after 2016. Consequently, according to a 2015 IAEA report, all of  IAEA’s JCPOA work through 2016 will be funded through extra-budgetary  contributions. According to State Department  officials, the balance of JCPOA-related costs not covered by IAEA’s 2017  regular budget will require extra-budgetary contributions from member  states. These potential challenges include (1) detecting undeclared nuclear  materials and activities, (2) accessing sites in Iran, and (3) managing  safeguards budgetary, human, and technical resources. According  to current U.S. and IAEA officials, some former U.S. officials, some  former IAEA officials, and officials from several expert organizations,  IAEA faces inherent challenges and limitations in identifying indicators of  undeclared activity. Efforts to Mitigate Challenges in Detecting Undeclared Nuclear Material and Activities

Current IAEA and U.S. officials as well as a former IAEA official said that  IAEA has taken steps to improve its ability to detect undeclared nuclear  activities and materials and told us that there are other mitigating factors  to the challenges IAEA faces in this area. For example, according to U.S. officials, IAEA has  adapted its inspector training program to focus on potential indicators of  undeclared activity beyond the agency’s traditional safeguards focus on  nuclear materials accountancy. Officials and expert organizations we interviewed  discussed two potential challenges regarding the mechanism. Specifically, IAEA’s strategy of transferring inspectors to its Office of  Safeguards Verification in Iran from other safeguards divisions may pose  a challenge to IAEA and its safeguards work in other countries because  of the extensive time it takes IAEA to hire and train new inspectors for  those divisions. Agency Comments

We are not making any recommendations in this report. Appendix I: Objectives, Scope, and Methodology

This report examines (1) the Joint Comprehensive Plan of Action  (JCPOA) commitments that the International Atomic Energy Agency  (IAEA) has been asked to verify and monitor and its authorities to do so,  (2) the resources IAEA has identified as necessary to verify and monitor  Iran’s nuclear-related commitments under the JCPOA, and (3) potential  challenges and mitigating actions, if any, IAEA and others have identified  with regard to verifying Iran’s nuclear-related commitments under the  JCPOA. We also analyzed  IAEA documentation concerning the safeguards legal framework,  including the Statute of the IAEA, which authorizes the agency to apply  safeguards, at the request of parties, to any bilateral or multilateral  arrangement; “The Structure and Content of Agreements Between the  Agency and States Required in Connection with the Treaty on the Non- Proliferation of Nuclear Weapons” (information circular (INFCIRC)/153),  which provides the basis for the comprehensive safeguards agreement  that most countries have concluded with IAEA and that covers all of the  countries’ nuclear material in peaceful activities; Iran’s Comprehensive  Safeguards Agreement (INFCIRC/214); the Model Additional Protocol  (INFCIRC/540), which provides the basis for an Additional Protocol that  most countries with a CSA have concluded with IAEA to provide  additional information about countries’ nuclear and nuclear-related  activities; and the November 2011 IAEA Safeguards Report, which  details items concerning “possible military dimensions” of Iran’s nuclear  program; IAEA’s report on its investigation of the possible military  dimensions; and the related Board of Governors’ resolution.
Why GAO Did This Study

In July 2015, multilateral talks with Iran culminated in an agreement called the JCPOA, through which Iran committed to limits on its nuclear program in exchange for relief from sanctions put in place by the United States and other nations. IAEA, an independent international organization that administers safeguards designed to detect and deter the diversion of nuclear material for nonpeaceful purposes, was requested to verify and monitor Iran's implementation of these commitments. The U.S. Department of State coordinates the United States' financial and policy relationship with IAEA.
GAO was asked to review the authorities and resources IAEA has to carry out its activities regarding the JCPOA. This report, which updates the preliminary findings from an interim report released in February 2016 (GAO-16-417), examines (1) the JCPOA commitments that IAEA has been asked to verify and monitor and its authorities to do so, (2) the resources IAEA has identified as necessary to verify and monitor those JCPOA commitments, and (3) potential challenges and mitigating actions IAEA and others have identified with regard to verifying and monitoring the JCPOA. GAO analyzed the JCPOA and key IAEA documents and interviewed current and former IAEA officials, U.S. government officials, national laboratory representatives, and experts from research institutions.

What GAO Found

As outlined in the Joint Comprehensive Plan of Action (JCPOA), the International Atomic Energy Agency (IAEA) was asked to verify and monitor Iran's implementation of a range of nuclear-related commitments. IAEA is using its safeguards authorities and conducting additional activities agreed to by Iran under the JCPOA to do so. Iran's commitments include limits on uranium enrichment levels and on enriched uranium inventories. IAEA is verifying and monitoring Iran's implementation of these commitments through a range of activities conducted by its Safeguards Department, such as inspecting Iran's nuclear facilities, analyzing environmental samples, and monitoring Iran's uranium mines and mills. Under the JCPOA, Iran agreed to provisionally apply the Additional Protocol, an agreement that will give IAEA's inspectors access to an expanded range of locations, including where the agency seeks assurance regarding the absence of undeclared nuclear material and activities. The JCPOA also includes a mechanism in which participants to the agreement commit to resolve an access request from the agency within 24 days after the request is made.
IAEA has identified the financial, human, and technical resources necessary to verify and monitor Iran's nuclear-related commitments in the JCPOA. IAEA has estimated that it needs approximately $10 million per year for 15 years in additional funding above its current safeguards budget for JCPOA verification. According to IAEA documents, this $10 million will be entirely funded through extra-budgetary contributions through 2016. IAEA officials said that the agency intends to propose that of the $10 million approximately $5.7 million for all Additional Protocol activities and inspector costs attributable to the JCPOA be funded through IAEA's regular budget after 2016; approximately $4.4 million will be supported through extra-budgetary contributions from member states, such as the United States. IAEA also plans to transfer 18 experienced inspectors to its Office of Safeguards Verification in Iran from other safeguards divisions and to hire and train additional inspectors. According to IAEA officials, existing safeguards technical resources are sufficient to implement the JCPOA.
IAEA may face potential challenges in verifying and monitoring Iran's implementation of certain nuclear-related commitments in the JCPOA. According to current and former IAEA and U.S. officials and expert organizations, these potential challenges include (1) integrating JCPOA-related funding into IAEA's regular budget and managing human resources in the safeguards program, (2) access challenges depending on Iran's cooperation and the untested JCPOA mechanism to resolve access issues, and (3) the inherent challenge of detecting undeclared nuclear materials and activities. IAEA has identified mitigating actions, such as utilizing remote monitoring and cost-free experts to address potential understaffing of IAEA safeguards activities in other countries as additional experienced inspectors are transferred to work on Iran-related safeguards. In addition, according to IAEA and U.S. officials as well as a former IAEA official GAO interviewed, IAEA has improved its capabilities in detecting undeclared activity. For example, according to U.S. officials, IAEA has adapted its inspector training program to focus on potential indicators of undeclared activities.

What GAO Recommends

GAO is not making any recommendations.