North America 1540 Reporting

October 17, 2017

Region Overview

The North American region is comprised of the United States, Canada, and Mexico, all of which play an active role in 1540 implementation both domestically and globally. Longstanding nuclear suppliers and advocates of nonproliferation, the United States and Canada possess robust export control systems. Both have partnered with other states and regional organizations in an effort to achieve 1540 objectives. The rapid growth of Mexico’s advanced manufacturing sector has propelled recent efforts to construct a modern export control system. Mexico has made significant progress in this area and has begun to act as a 1540 assistance provider abroad. All three countries in North America have submitted their national action plans.

As major suppliers of proliferation sensitive dual-use goods, North America’s states all face ongoing challenges controlling their extensive land and sea borders and adapting their export control and 1540-related programs to evolving threats from non-state actors. Canada, Mexico, and the United States have increasingly demonstrated solidarity in their efforts to combat terrorism and other illicit activities. In February 2011, U.S. President Obama and Canadian Prime Minister Harper announced the joint declaration, Beyond the Border: A Shared Vision for Perimeter Security and Economic Competitiveness, articulating “a shared approach to security in which both countries work together to address threats within, at, and away from our borders, while expediting lawful trade and travel.” [1] As part of this collaborative effort, the United States and Canada released the Joint Border and Threat Risk Assessment in March 2011, which recognized the continuing interest of terrorists in acquiring Chemical, Biological, Radiological and Nuclear (CBRN) materials as a high priority threat for both governments. [2] In response to this threat and others, the United States and Canada have developed a number of cooperative mechanisms to disrupt such illicit activity, including Integrated Border Enforcement Teams (IBETs) and Currency Seizure Memorandum of Understanding “to assist in money-laundering and terrorist-financing interdictions, investigations, and prosecutions.” [3]

The growth of Mexican drug cartels since the mid-1990s represents an immediate internal security threat for Mexico as well as the United States. In 2008, the United States and Mexico established the Mérida Initiative as a $1.6 billion foreign assistance program to strengthen Mexico’s institutional capacity to counter organized criminal networks. [4] The advance of Mexican drug cartels has also raised the specter of narco-terrorism and the potential for terrorists to use the U.S.-Mexico border to enter the United States. As a result, the United States and Mexico have begun negotiating methods to detect nuclear and radioactive material if shipped, prevent terrorists from utilizing Mexican seaports to ship illegal materials, and intercept harmful material before it can be used against the United States or U.S. allies. [5]

For more detailed information on this region’s NBC and delivery system capabilities, see the relevant country profiles.

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WMD-Related Illicit Trafficking

The U.S.-Canada border is the longest land border between any two states, and the U.S.-Mexico border is the most frequently crossed border in the world. The sheer geographical scope and volume of activity across these borders makes combating illicit trafficking an enormous challenge. Indeed, the U.S. Department of Homeland Security “reported achieving an acceptable level of border control across less than half of the southwest border and less than 2 percent of the northern border during fiscal year 2010.” [6]

The drug trade is a pervasive form of illicit trafficking in North America, facilitated in large part by Mexican drug cartels. According to U.S. officials, approximately 90 percent of the cocaine and 96 percent of the opiates entering the country cross the U.S.-Mexico border. [7] Some other drugs, principally Ecstasy, flow southward from Canada into the United States. [8] Trafficking in firearms is also widespread. Upwards of twenty thousand weapons are smuggled annually from the United States to Mexico via the southwest border. [9]

All three countries have significant high-tech industries, and their commodities are often sought out by trafficking networks. The US and Canadian governments in particular have significant outreach efforts with their business community to help companies better implement compliance programs and avoid being caught up in illicit procurement efforts.

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1540 Implementation

All three North American states have diligently participated in the 1540 reporting process, submitting initial reports by the original deadline and providing follow-on clarifications and updates. Both the United States and Canada have developed 1540 national action plans as encouraged by Resolution 1977, which extended the 1540 Committee’s mandate in April 2011. Mexico has made steady progress towards building its own comprehensive export control system. While its implementation and enforcement experience remains underdeveloped, Mexico appears to be committed to the long-term project of improving its capacity in this field.

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Export Controls and Related Measures

The modern U.S. export control system is both comprehensive in scope and complex in implementation. A broad array of laws and executive orders, including some in place since the Cold War’s early years, comprise the legal authority for U.S. export controls. Governing the export of dual-use goods and technology, the International Economic Emergency Powers Act (IEEPA), combined with Executive Order 13222, have kept active the provisions of the now-expired Export Administration Act. [10] Based on this authority, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) implements the corresponding Export Administration Regulations (EAR). [11] The EAR includes the Commerce Control List (CCL), which supports U.S. regime commitments by outlining export licensing requirements for those dual-use goods controlled by the Nuclear Suppliers Group (NSG), the Australia Group (AG), the Missile Technology Control Regime (MTCR), and the Wassenaar Arrangement. The CCL also includes items controlled unilaterally by the United States for national security and foreign policy reasons.

While the EAR controls dual-use items listed in Part 2 of the NSG Guidelines, the export of nuclear material and “Trigger List” equipment are subject to a separate set of regulations, 10 CFR Part 110. [12] The Nuclear Regulatory Commission (NRC) administers export and import licensing requirements associated with Part 110-controlled items, which correspond to Part 1 of the NSG Guidelines. [13] The Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974 provide the legal authority for these regulations, as well as 10 CFR Part 810, which controls the export of nuclear technology specifically, and is administered by the U.S. Department of Energy (DOE). [14]

The United States was among the early adopters and promoters of WMD nonproliferation “catch-all” export controls. [15] According to catch-all rules, exporting any item, regardless of its level of technology, is prohibited without a license if the exporter knows or has reason-to-know that the item will support WMD proliferation. The United States vigorously enforces its export control system. For example, in FY2012 the Department of Homeland Security (DHS)’s Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI) Counter-Proliferation Investigations Program, “initiated more than 1,800 counter-proliferation investigations, made 517 arrests, indicted 568 individuals, obtained 399 convictions, and seized millions of dollars’ worth of military weaponry and other highly sensitive commodities.” [16] The FBI, ICE, and DHS’ Customs and Border Protection (CBP) all have export enforcement authority, as does the law enforcement body solely dedicated to enforcement of dual-use export controls, the BIS Office of Export Enforcement (OEE). ICE and CBP also have border security-related responsibilities under DHS.

The other half of the United States’ export control regime is the International Traffic in Arms Regulation (ITAR). [17] The ITAR governs the export of defense articles enumerated in the US Munitions List (USML). Applications for the export of goods contained in the USML go through the Directorate of Defense Trade Controls (DDTC) within the US Department of State. Recent developments in US export control reform have seen numerous items from the USML and DDTC jurisdiction transferred to the CCL and BIS jurisdiction.

Finally, a small subset of items, specifically those enumerated in Part I of the NSG Guidelines, are controlled by the Nuclear Regulatory Commission (NRC). The NRC grants general or specific licenses for the export of items falling under their jurisdiction. [18]

Additionally, the United States has relied heavily on sanctions to slow down or even deter North Korea’s nuclear program development. Starting in 2006, the sanctions have become increasingly stringent following each North Korean WMD-related action.

Canada had already taken extensive steps to prevent the spread of dual-use materials and technologies prior to the adoption of UNSCR 1540. The primary legislation governing Canada’s export control system is the Export and Import Control Permits Act (EIPA), which “authorizes the establishment, maintenance, and enforcement of national control lists.” The Export Control and Technical Barriers Bureau (TCTBB), located within the Department of Foreign Affairs and International Trade, is responsible for implementing the EIPA, and thus administers both the Export Control List (ECL) and the Export Permit Regulations (EPR). [19] The ECL is regularly updated to reflect Canada’s obligations to the multilateral export control regimes of which it is member, including the Nuclear Suppliers Group (NSG), the Australia Group (AG), and the Missile Technology Control Regime (MTCR). Nuclear and dual-use goods are subject to additional controls administered by the Canadian Nuclear Safety Commission (CNSC) pursuant to the Nuclear Safety Control Act (NSCA) and the Nuclear Non-Proliferation Import and Export Regulations (NNPIECR). Within the NNPIECR, the CNSC maintains its own control lists of nuclear substances, equipment, and information, which require a license issued by the Commission for import or export. According to the OECD Nuclear Energy Agency, “Administrative arrangements ensure that terms and conditions described in the export permit issued under the [EIPA] do not duplicate conditions imposed on the license issued by the Commission.” [20]

Canada also maintains a robust border control and law enforcement system to counter the proliferation of NBC weapons and their delivery systems. Located within the Canada Border Services Agency, the Strategic Export Control Unit is responsible for “all related counter proliferation concerns as well as enforcement of export controls related to military and other strategic goods.” [21] Violations of Canadian strategic trade control laws can result in criminal penalties of up to ten years imprisonment and/or fines. Canada is also an active participant in a host of multilateral counter-proliferation initiatives complementary to 1540 objectives, including the Proliferation Security Initiative (PSI), the Container Security Initiative (CSI), the Financial Action Task Force (FATF), and the Global Initiative to Combat Nuclear Terrorism (GICNT).

Mexico has made significant efforts to improve its export control system. Progress appears most evident with respect to implementation of chemical and nuclear nonproliferation and security measures as opposed to biological measures. Pursuant to the Act on Nuclear Activities and General Radiological Safety Regulations, the import and export of nuclear and radiological materials is prohibited without a license issued by the National Nuclear Safety and Safeguards Commission. [22] Mexico successfully implemented its export control obligations pursuant to the CWC with the passage of the Federal Law for the Control of Dual Use Chemical Substances in 2008. [23] Given Mexico’s ambition to join the various multilateral export control regimes, efforts to bring Mexico’s regulatory and licensing efforts into closer alignment with international best practices began in 201, with a decision made by the Mexican National Security Council. [24] Following this decision, the Ministry of the Economy published an Accord in the Official Diary of the Federation creating a national export control regime, which entered into force on 20 October 2011. [25] The Accord established the Committee for the Control of Dual-Use Goods, Software and Technologies to implement the regime. [26] Mexico modeled its control lists on those of the Multilateral Export Control Regimes (MECRs), with items on the Nuclear Suppliers Group’s list being controlled by the Ministry of Energy, those on the Australia Group’s list being controlled by the Ministry of the Environment and Natural Resources, and those on the Wassenaar Arrangement’s list being controlled by the Ministry of National Defense. [27] The Ministry of Economy is responsible for a subset of items from all three lists. Indicative of progress in this area, Mexico was formally admitted to the Wassenaar Arrangement in January 2012 and the Nuclear Suppliers Group in November 2012. [28] Most recently, Mexico was admitted to the Australia Group in 2013. [29]

Reflective of progress in this area, Mexico was formally admitted to the Wassenaar Arrangement in January 2012 and the Nuclear Suppliers Group in November 2012. [25]

While Mexico has been working on legislation to improve its export controls, its border controls remain a significant problem. Narcotics smuggling as well as human trafficking are only two of the challenges that confront U.S.-Mexico border security. Furthermore, since 2006 violence along the U.S.-Mexico border has escalated immensely. Mexico and the United States have collaborated to prevent smuggling and violence along Mexico’s northern and southern borders. The United States is also assisting Mexico with border security by providing training programs on non-intrusive equipment inspection, detection of weapons of mass destruction, and identification of fraudulent documents.

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Regional Cooperation and Outreach

Canada, Mexico and the United States are all members of the {{glossary-term:”g-8-global-partnership-against-spread-weapons-mass-des”:”G8 Global Partnership Against the Spread of Weapons and Materials of Mass Destruction (GP)”}}, which began in 2002 as a 10-year, $20 billion multilateral initiative, “for financial commitments to implement and coordinate [CBRN] threat reduction activities on a global scale.” [30] The GP has focused on a number of 1540-related priority areas including destruction of chemical weapons; disposition of fissile materials; dismantlement of nuclear submarines; employment redirection of former Weapons of Mass Destruction (WMD) scientists; and biological, nuclear, and radiological security. Moreover, at the time of the GP’s renewal beyond 2012 at the 2011 G8 Summit, leaders agreed to include the facilitation of implementation of UNSCR 1540 among priority focus areas. [31] U.S. financial commitments accounted for half of the $20 billion initially pledged by all GP participants, and the United States plans to provide another $10 billion in continued funding from 2012 to 2022, pending Congressional appropriations. Canada pledged CA$1 billion over the Partnership’s first ten years of operation, and announced at the 2012 Nuclear Security Summit its renewed commitment of CA$367 million between 2013 and 2018. Mexico joined the GP in December 2012 as its 25th member, and the initiative’s first Latin American partner state.

In addition to assistance provided through Canada’s Global Partnership Program, Canada also provides 1540-relevant support through its Counter-Terrorism Capacity Building (CTCB) Program, established in 2004. This Program “supports training courses, workshops, equipment, and technical and legal assistance to states to enable them to prevent and respond to terrorist activity.” [32] According to Canada’s latest 1540 report, the CTCB Program has supported more than 20 capacity-building projects which “have increased the ability of states in Asia, South America, the Caribbean, Central America, Africa, and the Middle East to respond to chemical, biological, radiological, nuclear and explosive issues.” [33]

Until a few years ago, Mexico was primarily a recipient of 1540 assistance, but has recently indicated its willingness to become an assistance provider. Mexico has worked with the International Atomic Energy Agency (IAEA) to improve nuclear security within its borders. Beginning in 2007, the IAEA established a regional nuclear security assistance program to increase the awareness and capacity of countries in Latin America for prevention, detection, and response to malicious acts involving nuclear and other radioactive materials or facilities. Mexico, along with twenty-one other states in Latin America and the Caribbean, participates in the program. [34] As a part of the program, in 2009 the IAEA undertook a technical cooperation project to build human resource capacity for developing a sustainable nuclear security infrastructure. Training in this area included prevention and response for illicit trafficking and nuclear threats; safety and security of radiation sources; security of nuclear and radioactive materials; and physical protection of nuclear facilities. [35] Mexico has identified “technical assistance on matters relating to extradition” as well as “first response to chemical, biological and radioactive weapons incidents” as two areas where it holds expertise that may be of value to other states seeking assistance. [36] As Mexico’s 1540-related capabilities increase, its ability to offer additional types of assistance will likely grow as well.

A number of U.S. programs also offer legislative assistance to improve states’ counterterrorism and national export control laws and regulations, as well as their capacities to implement these measures and prosecute relevant violations. The State Department’s EXBS program is the flagship program in this area. EXBS actively provides assistance to 50 countries, using a budget of nearly $61 million to help “build effective national strategic trade control systems in countries that possess, produce, or supply strategic items as well as in countries through which such items are likely to transit.” [37] Toward this end, EXBS provides assistance via workshops and exchanges in five core areas: drafting and implementing new export control laws and regulations; establishing and strengthening export control licensing mechanisms; bolstering enforcement capabilities; government-industry cooperation; and interagency cooperation and coordination.

A March 2012 GAO report identified five nonproliferation training programs focused on law enforcement and four programs involved in providing nuclear and radiological detection equipment. [38] Training-oriented programs identified in the GAO report include the NNSA’s Second Line of Defense (SLD) program, the International Nonproliferation Export Control (INECP) Program, the State Department’s EXBS Program, the Defense Department’s WMD-Proliferation Prevention Program (WMD-PPP), and the International Counterproliferation Program (ICP). In addition to offering training, the SLD program, EXBS program, WMD-PPP, and ICP also provide equipment to enhance states’ capacity to detect nuclear trafficking.

While the GAO identified a potential for fragmentation and overlap among these programs, the various administrative agencies point out that the programs have geographical distinctions and tend to focus on specialized areas of expertise. [39] In addition, many of these programs complement each other’s objectives. For example, the Container Security Initiative (CSI), initiated in 2002 by DHS, deploys multidisciplinary teams to work with their foreign counterparts to target and prescreen all containers bound for the United States that pose a potential risk for terrorist use in delivering a weapon. CSI works in close cooperation with the NNSA’s SLD program and Megaports Initiative, which partner with countries to equip major international seaports with radiation detection equipment and have committed to providing a detection capability at all CSI ports. Today CSI operates in 58 ports worldwide, and reportedly screens over eighty percent of all U.S.-bound maritime containerized cargo. [40]

Recognizing the positive role regional organizations (ROs) can play in facilitating 1540 implementation, Canada and the United States have increasingly engaged ROs from around the world as conduits through which to provide 1540 assistance. Mexico has also engaged ROs on 1540 implementation, primarily to organizations within Central and South America.

The Organization of American States (OAS) plays an important role in the implementation of UNSCR 1540 in the Western Hemisphere, and is the only RO to which all three North American states belong. Since 2005, the OAS has adopted resolutions in support of Resolution 1540 and been actively involved in outreach events to promote 1540 implementation. The United States, Canada, and Mexico have either hosted, funded, organized, or participated in these events. [41] The United States and Canada have also supported the Caribbean Community’s (CARICOM) UNSCR Implementation Program, which provides a number of services, including the training and resources necessary to detect, identify, and prevent transfers that violate export control laws and regulations. [42] Based on CARICOM’s successful experience, another RO, the Central American Integration System (SICA), requested assistance in establishing its own 1540 Coordinator. In June 2011, Canada announced that it would fund the effort to establish the position. [43]

Canada and the United States have also engaged ROs that operate outside the Americas. For example, both have actively promoted and facilitated 1540 implementation through their participation in the Organization for Security and Cooperation in Europe (OSCE). Drawing on the vast experience in strategic trade controls of some of its members, the OSCE produced a Best Practices Guide on UNSCR 1540 in 2009, providing a comprehensive blueprint for the development or enhancement of a national export control system. [43] Subsequently, a Ministerial Council Decision made in 2009 mandated that member states “facilitate regional implementation of UNSCR 1540, providing assistance to those states that require it.” [45]

In February 2007, the United States, along with Canada and Singapore, co-funded and co-chaired an ASEAN Regional Forum (ARF) workshop in San Francisco, the primary purpose of which was to raise awareness about the resolution. Subsequently, in 2008 the ARF established the Inter-Sessional Meeting on Nonproliferation and Disarmament (ISM/NPD), the first and fourth meetings of which placed central emphasis on 1540 implementation. The United States co-organized, along with China and Singapore, the first ISM/NPD held in Beijing in July 2009, which provided states with an opportunity to make assistance requests and explore how the ARF could contribute to 1540 implementation. [41] The United States and Canada attended the fourth ISM/NPD in March 2012 held in Sydney, which focused on sharing implementation experiences and provided the opportunity for states to offer assistance. [47] 

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1540 Implementation Challenges

Canada, Mexico, and the United States continue to demonstrate a strong commitment to addressing the threat posed by the nexus of non-state actors, illicit trafficking, and WMD proliferation through the implementation of resolution 1540. This is especially encouraging given the fact that the presence of advanced nuclear, biological, and chemical industries in the United States and Canada, and increasingly in Mexico, makes these states prime targets for non-state actors interested in acquiring WMD materials. It is also encouraging that these states, given their extensive experience in developing WMD security and export control systems, have prioritized 1540-related outreach to states and regional organizations abroad.

While significant progress has been achieved, all three states face ongoing challenges with respect to the achievement of 1540 objectives. On a national level, even in the United States and Canada, gaps remain with respect to the security of WMD-related materials at vulnerable civilian and military locations. In addition, national export control systems require constant adaptation to reflect updates to multilateral export control regimes and to remain effective against the dynamic threat of non-state actor proliferation. Yet the bureaucratic structures erected for this purpose remain highly complex and inefficient. Efforts to streamline the U.S. export control system are underway, but the Obama Administration’s vision of a single licensing authority remains unrealized to-date.

On a regional level, achieving adequate border security in North America remains a colossal challenge. The sheer geographical scope and volume of bilateral flows of goods and people across the U.S.-Mexico and U.S.-Canada borders complicates this effort greatly. On a global level, the United States and Canada, and to a lesser extent Mexico, have endeavored to encourage the achievement of 1540 objectives. With numerous states engaged in a variety of 1540-related outreach activities, coordination within and between states’ assistance programs is vital to ensuring an efficient and prioritized allocation of resources. Facilitating 1540 implementation to the priority focus areas of the G8 Global Partnership is a positive step in this direction. In the United States in particular, the massive interagency effort to provide 1540-related assistance abroad could benefit from more centralized direction to avoid potential programmatic overlap and inefficiency.

These challenges demonstrate how the expansive scope and ambitious nature of resolution 1540 makes it difficult for even the most capable and committed states to fulfill all of their 1540-related obligations. This should serve not to detract from the immense progress that has been realized in North America, but to recognize that the achievement of 1540 objectives is a long-term goal requiring sustained attention and commensurate action.

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Sources:
[1] “Beyond the Border: A Shared Vision for Perimeter Security and Economic Competitiveness,” Department of Homeland Security, 4 February 2011, www.dhs.gov.
[2] “United States-Canada Joint Border Threat and Risk Assessment,” U.S. Customs and Border Protection, Canada Border Services Agency, and the Royal Canadian Mounted Police, July 2010, www.dhs.gov.
[3] “Northern Border Strategy,” Department of Homeland Security, June 2012, p. 10-11, www.dhs.gov; “Canada-U.S. Borders: Putting the Threat into Perspective,” Embassy of Canada, www.canadainternational.gc.ca.
[4] Bureau of International Narcotics and Law Enforcement Affairs, “Merida Initiative,” Department of State, www.state.gov.
[5] “DHS, ICE and Mexico honor graduates of Mexican Customs Investigator Training Program,” ICE website, 22 October 2010, www.ice.gov.
[6] Richard M. Stana, “DHS Progress and Challenges in Securing the U.S. Southwest and Northern Borders,” Testimony before the Senate Committee on Homeland Security and Government Affairs, 30 March 2011, p. 2, www.gao.gov.
[7] “The Globalization of Crime: A Transnational Organized Crime Threat Assessment,” UN Office of Drugs and Crime, 2010, p. 87, www.unodc.org; United States-Canada Joint Border Threat and Risk Assessment,” U.S. Customs and Border Protection, Canada Border Services Agency, and the Royal Canadian Mounted Police, July 2010, p. 9, www.dhs.gov.
[8] United States-Canada Joint Border Threat and Risk Assessment,” U.S. Customs and Border Protection, Canada Border Services Agency, and the Royal Canadian Mounted Police, July 2010, p. 7-8, www.dhs.gov.
[9] “The Globalization of Crime: A Transnational Organized Crime Threat Assessment,” UN Office of Drugs and Crime, 2010, p. 133, www.unodc.org.
[10] Legal Authority, Export Administration Regulations (as of 23 January 2013), prepared by The Office of the Chief Counsel for Industry and Security, Bureau of Industry and Security, U.S. Department of Commerce, 23 January 2010, www.bis.doc.gov.
[11] “Export Administration Regulations,” Bureau of Industry and Security, U.S. Department of Commerce, www.bis.doc.gov.
[12] The “Trigger List” refers to the original list of nuclear items controlled for export by the Nuclear Suppliers Group as per Annex A to Part 1 of the NSG Guidelines. A second list, controlling dual-use items, was later added to the NSG Guidelines as Part 2. See www.nuclearsuppliersgroup.org; CFR refers to Code of Federal Regulations.
[13] “Export/Import,” U.S. Nuclear Regulatory Commission, www.nrc.gov.
[14] Dennis J. Burnett, “United States of America,” in Export Control Law and Regulations Handbook: A Practical Guide for Military and Dual-Use Goods, Trade Regulations and Compliance, eds. Yann Aubin and Arnaud Idiart (The Netherlands: Kluwer Law International BV, 2007), 341.
[15] “Catch-All Controls,” A Resource on Strategic Trade Management and Export Controls, U.S. Department of State, www.state.gov.
[16] “Fact Sheet: Counter-Proliferation Investigations,” 29 March 2013, Department of Homeland Security, Immigration and Customs Enforcement, www.ice.gov; Note: As defined by HSI, “counter-proliferation” encompasses not only the countering of WMD proliferation, but also the proliferation of advanced conventional military capabilities.
[17] “Overview of U.S. Export Control System,” U.S. Department of State, accessed 12 October 2017, www.state.gov.
[18] “Export-Import,” United States Nuclear Regulatory Commission – Protecting People and the Environment, accessed 12 October 2017, www.nrc.gov.
[19] Permanent Mission of Canada to the UN, “Note verbale dated 31 December 2004 from the Permanent Mission of Canada to the United Nations addressed to the Chairman of the Committee,” Security Council Committee established Pursuant to Resolution 1540 (2004), S/AC.44/2004/(02)/98, 6 February 2005, p. 13; “Export and Import Permits Act (1985),” distributed by the Canadian Minister of Justice, 1 April 2013, www.laws-lois.justice.gc.ca.
[20] OECD Nuclear Energy Agency, “Canada,” Nuclear Legislation in OECD Countries: Regulatory and Institutional Framework for Nuclear Activities, 2009, p. 13, www.oecd-nea.org.
[21] Permanent Representative of Canada to the UN, “Letter dated 19 January 2006 from the Permanent Representative of Canada to the United Nations addressed to the Committee,” Security Council Committee Established Pursuant to Resolution 1540 (2004), S/AC.44/(02)/98/Add.1, 23 February 2006, p. 21.
[22] OECD Nuclear Energy Agency, “Mexico,” Nuclear Legislation in OECD Countries: Regulatory and Institutional Framework for Nuclear Activities, 2009, p. 8-9, www.oecd-nea.org.
[23] U.S. Department of State, “EXBS Post in Focus: Mexico City,” EXBS Newsletter, Vol. II, Issue 3, p. 6, www.state.gov.
[24] U.S. Department of State, “EXBS Post in Focus: Mexico City,” EXBS Newsletter, Vol. II, Issue 3, p. 6, www.state.gov.
[25] “Dirección de Control de Exportaciones,” Dirección de Control de Exportaciones, accessed 12 October 2017, www.siicex.gob.mx.
[26] Vázquez, Adrián B , Horacio López-Portillo, and Eduardo Zepeda Grimaldo, “New export control regime for weapons and dual-use goods,” International Law Office, 11 November 2011, www.internationallawoffice.com.
[27] “Mexico’s Experiences in Establishing an Export Control System,” General Directorate of Foreign Trade, Ministry of Economy, June 2016.
[28] “Mexico Formally Enters the Nuclear Suppliers Group,” Foreign Ministry of Mexico Press Release, 2012, www.sre.gob.mx.
[29] “Participants,” The Australia Group – Participants, accessed 12 October 2017, www.australiagroup.net.
[30] Ambassador Bonnie D. Jenkins, “The Future Role of the G-8 Global Partnership: Combating Weapons of Mass Destruction,” The Stanley Foundation Policy Analysis Brief, June 2010, p. 1, www.stanleyfoundation.org.
[31] Ambassador Bonnie D. Jenkins, “Assistance and Partnering Opportunities to Implement Resolution 1540,” Department of State, 13 July 2012, www.state.gov; “Report on the G8 Global Partnership against Weapons and Materials of Mass Destruction,” G8 Information Centre, 27 May 2011, www.g8.utoronto.ca.
[32] Permanent Mission of Canada to the UN, “Letter dated 31 January 2008 of the Permanent Mission of Canada to the UN addressed to the Chair of the Committee,” Security Council Committee Established Pursuant to Resolution 1540 (2004), S/AC.44/2007/14, 28 July 2010, p. 15.
[33] Permanent Mission of Canada to the UN, “Letter dated 31 January 2008 of the Permanent Mission of Canada to the UN addressed to the Chair of the Committee,” Security Council Committee Established Pursuant to Resolution 1540 (2004), S/AC.44/2007/14, 28 July 2010, p. 15.
[34] “Awareness raising and Training for Nuclear Security: TC Number RLA/9/059,” IAEA, www-tc.iaea.org.
[35] “Developing Human Resources in Nuclear Security: TC Project Number RLA/9/063,” IAEA, www-tc.iaea.org.
[36] “Mexico Direct Assistance,” 1540 Committee, www.un.org.
[37] “The EXBS Program,” Department of State, www.state.gov.
[38] Government Accountability Office, “Further Actions Needed by U.S. Agencies to Secure Vulnerable Nuclear and Radiological Materials,” Testimony before the Senate Committee on Homeland Security and Government Affairs, 14 March 2012, www.gao.gov, p. 12-13.
[39] Government Accountability Office, “Action Needed to Address NNSA’s Program Management and Coordination Challenges,” Report to the House Subcommittee on Energy and Water Development, December 2011, www.gao.gov, p. 44-45.
[40] “CSI in Brief,” U.S. Customs and Border Protection, 7 October 2011, www.cbp.gov.
[41] “Event List and Related Documents: 2006-2012,” 1540 Committee, www.un.org.
[42] “Support for the implementation at the Hemispheric Level of United Nations Security Council Resolution 1540” (2004), OAS, 14 February 2010, www.scm.oas.org.
[43] “Canada Contributes to Improving Security in the Americas,” Ministry of Foreign Affairs and International Trade Canada Press Release, 22 June 2011, www.international.gc.ca.
[44] “Best Practice Guide on UN Security Council Resolution 1540 Export Controls and Transshipment,” OSCE, 16 September 2009, www.osce.org.
[45] Anton Martyniuk, Valclovas Semaskevicius, and Adriana Volenikova, “UNSCR 1540 and the Organization for Security and Co-operation in Europe,” Center for International Trade and Security.
[46] “Event List and Related Documents: 2006-2012,” 1540 Committee, www.un.org.
[47] “Co-Chairs’ Summary Report of the Fourth Regional Forum Inter-Sessional Meeting on Nonproliferation and Disarmament,” ASEAN Regional Forum, 9 March 2012, p. 5-6, www.aseanregionalforum.asean.org; “Event List and Related Documents: 2006-2012,” 1540 Committee, www.un.org.

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