"But a 2007 government study found that 61 percent of the office's investigations since 2000 had been aimed at just one target: Cuba," Bardach reports. "Between 2000 and 2005, OFAC penalties for violations of the Cuban embargo represented more than 70 percent of all the penalties the office imposed."

"At the hearing, OFAC acknowledged that it had just four employees searching for the funds of Osama bin Laden and Saddam Hussein, as opposed to more than 20 full-time investigators charged with hunting down suspected violators of the embargo."

"Iranian banks illegally shifted billions of dollars through American financial institutions in recent years, and authorities suspect some of the money may have been used to finance Iran's nuclear and missile programs."

"It 'stripped' information that would have identified the transfers in order to deceive American financial institutions, which are barred from doing business with Iranian banks ..."

"This is the pipeline at its best. One simply has to shift addresses, at least on paper, the companies go again, and the pipeline is unclogged and continues to carry its vital products. The flexibility of the pipeline and its ability to adapt and reroute itself in a very short period of time is one of its greatest strengths." 

It had to happen someday:  A Middle Eastern oil exporter glimpsing the bottom of the barrels.

The booming United Arab Emirates, facing declining oil reserves, will be issuing a call for bids early next year for the construction of "several" nuclear power plants, the Paris-based Intelligence Online (IO) newsletter is reporting.
 
Westinghouse (now a U.S.-Japanese company) and France's Areva "are geared up to bid for the huge contract," it said.

The Bush administration has favored the deal, arguing that it's an object lesson on U.S. support for peaceful nuclear power development in the region.    

"This is a real counter-example to what Iran is doing," a senior US official was quoted as saying in the Wall Street Journal over the weekend. "We're seeking commitments from nations within the Middle East."

The clock's running out for the Bushies, however. As my CQ colleague Matt Korade pointed out Dec. 9:

"Under Section 123 of the Atomic Energy Act of 1954 (PL 83-703), Congress must be given 90 days to approve this kind of nuclear trade deal. Because there is not enough time left in the current session, the Bush administration has indicated it probably will not submit the agreement for approval before the next Congress takes office, a congressional aide said."

There are other hurdles.

Last week Rep. Ileana Ros-Lehtinen of Florida, the top Republican on the House Foreign Affairs Committee, introduced a resolution (HR 7316)  "that would bar any agreement or the issuing of licenses to export nuclear technology unless the president certifies to Congress that the UAE has met certain requirements," as Korade described it.

They include "taking effective action to prohibit the transfer of sensitive technology to Iran for a one-year period and enforcing U.S. sanctions and non-proliferation law."

But an earlier effort isn't working very well, Intelligence Online says.

Under pressure from the Commerce Department's Bureau of Industry and Security, the UAE last year adopted a law on export controls designed to prevent the transfer of classified American technology to Iran.

But the law "has failed by far to put a halt to trade between Dubai and Tehran," despite U.N. sanctions, IO reported.

As for the Obama team, it's not commenting on the issue.

But it's interesting to note that the French company in the running for the UAE's business, Areva, is represented by Covington & Burling, the Washington superlawyer firm where Obama's attorney general-designate, Eric Holder, worked until recently.

On the other hand, Areva is competing for major contracts here, IO reported, and can't afford to alienate members of Congress

Victor Comras, a longtime State Department diplomat and trade expert, argues that plunging oil prices and chaos in the international finance system could force Iran back to the bargaining table over its nuclear program.

Economic sanctions have also begun to show results, Comras said, as reports surfaced that the Bush administration was forcing Israel to stand down from plans to attack the Islamic republic.

"Iran's economy is already in shambles," Comras wrote for the widely read Counterterrorism Blog Tuesday.

"The downturn in the price of oil has left Iran's government with serious budget shortfalls and significantly reduced its ability to support and subsidize its extensive ongoing energy sector and other infrastructure projects," he said.

"It has also significantly reduced the profit incentives that previously enticed foreign businesses and banks to compete for Iran's business, even when that meant irritating their American relationships.

"Iran's cost of doing business is soaring, and the stepped up measures adopted by the U.S. Treasury Department, and the US campaign to dissuade financial dealings with Iran, are now actually having a significant impact! More and more Western banks are reducing their Iran exposure and pulling out of the Iran marketplace. Even non Western banks in Dubai are beginning to view triangular transactions with Iran more cautiously. These factors may serve to enhance the chances of engaging Iran in a more constructive dialogue on its nuclear program than previously."

Read the rest here.

A bipartisan study commission headed by two former U.S. senators is recommending that the United States tell Iran in no uncertain terms that it will suffer a nuclear attack if it launches a nuclear attack on anybody else.

"A nuclear deterrent strategy would require moving to a declared U.S. stance threatening the potential use of nuclear weapons should Iran ever use a nuclear weapon or allow its proxies to do so," said the report from The Bipartisan Policy Center, which is co-chaired by former senators Charles Robb, D-Va., and Dan Coats, R-Ind.

When Hoskinson listened to the interview, broadcast only in Arabic, he was startled to discover that ElBaradei had suddenly sliced years off his previous estimates of how long it would take Iran, if left alone, to build a bomb.

Nobody seemed to notice that ElBaradei said Saturday Iran would need only six months to a year to produce a nuclear weapon if it broke off talks and expelled IAEA inspectors. 

This seems like a huge shift: ElBaradei has consistently said that it could take Iran from three to eight years to make a weapon. Or sometimes, demurring on personal estimates but seeking to knock down the more inflammatory statements by some Bush administration figures, ElBaradei took refuge in the softer estimates on Iran by U.S. intelligence chief Mike McConnell and Deputy Secretary of State John D. Negroponte. In October, for example, he told CNN's Wolf Blitzer that Iran was "a few years" away from a bomb.   

Of course, last fall's controversial National Intelligence Estimate. also gave ElBaradei cover to throw cold water on the hawks' itching for an attack on Iran.   

But now it looks like ElBaradei's gone off the reservation. By the sound of last Saturday's interview, he's pulled much closer to what Israel is saying about the immediacy of the Iranian threat. 

Here's what he said on Al-Arabiya, the Saudi-owned station based in Dubai:

ELBaradei: "If Iran wants to turn to the production of nuclear weapons, it must leave the NPT [Nuclear Proliferation Treaty], expel the IAEA inspectors, and then it would need at least -- "

Interviewer: "How much time would it need?"

ElBaradei: "It would need at least six months to one year. Therefore, Iran will not be able to reach the point where we would wake up onemorning to an Iran with a nuclear weapon."

Six months is a lot better than a week, or overnight. But what happened to the eight-years estimated lag?

The interviewer seemed shocked by the sudden evaporation of seven years in ElBaradei's thinking, too. 

Interviewer: "Excuse me, I would like to clarify this for our viewers. If Iran decides today to expel the IAEA from the country, it will need six months..."

ElBaradei: "Or one year, at least --"

Interviewer: "-- to produce [nuclear] weapons?"

ElBaradei: "It would need this period to produce a weapon, and to obtain highly-enriched uranium in sufficient quantities for a single nuclear weapon." [...]

What's going on here?

My guess is that the IAEA chief may well be sick of recent Iranian behavior and wanted to send a message to Tehran (while cautioning Washington that Iran has the wherewithal to respond with fire).  

But the English-language media missed the first part.

In retrospect, ElBaradei's toughening -- if that's what it is -- should not come as such a surprise: Last month's IAEA report, after all, was tougher than previous ones, with a complaint that Iran was holding back on the inspectors.

ElBaradei, the most patient of diplomats, may be running out of patience with Iran.