FY26 All CTR Non-Proliferation Programing NOFO - 260206.docx

Notice of Funding Opportunity (NOFO)

CTR Non-Proliferation Programing BUREAU ARMS OF CONTROL AND NONPROLIFERATION, OFFICE OF COOPERATIVE THREAT REDUCTION, DEPARTMENT OF STATE Opportunity number: DFOP0017675 Application deadline: 6 March 2026

Contents

U.S Department of State

INTERNATIONAL SECURITY AND NONPROLIFERATION OFFICE OF

COOPERATIVE THREAT REDUCTION

Notice of Funding Opportunity

A. Basic Information

1. Overview

Funding Instrument Types: Grant, cooperative agreement, Inter-Agency Agreement. Cooperative agreements - ACN/CTR will have significant involvement in implementation.

Project Performance Period: ACN/CTR would prefer most projects be completed within 15 months from kick off to final report. Please budget for 12 months of program work, with three months of room if events are postponed. Projects with extremely strong justification may be given 24 months if sufficient need and funding is available.

This notice is subject to availability of funding.

2. Executive Summary Priority of Regions:

1. Western Hemisphere (WHA)

2. East Asia and the Pacific (EAP)

3. South and Central Asian (SCA)

4. Europe and Eurasia (EUR)

5. Middle East and North Africa (NEA)

6. Africa (AF)

Executive Summary The Office of Cooperative Threat Reduction (CTR) is a key component of the Department’s and ACN’s efforts to advance the Administration’s top national security and foreign policy objectives in a cost-effective and impactful manner. CTR uses programming and training with foreign partners to advance President Trump’s America First Investment Policy (NSPM-3) and America’s AI Action plan by disrupting the Chinese Communist Party’s (CCP) exploitation of critical U.S. intellectual property (IP) and dual-use technologies, including AI, biotechnologies, quantum, semiconductor, and space technologies, through research security, cybersecurity and IP protection training. As the programmatic lead for the Foundational Infrastructure for the Responsible Use of Small Modular Reactor [SMR] Technology (FIRST) program, CTR implements Section 8(e) of EO 14299 on Deploying Advanced Nuclear Reactor Technologies for National Security by helping U.S. vendors deploy secure, safe U.S. SMRs to strategic regions, including Latin America, the Indo-Pacific, and the Middle East, to outcompete strategic competitors for decades-long partnerships, generating multi-billion dollar deals for U.S. companies and creating thousands of American jobs. CTR implements maximum pressure on Iran (NSPM-2), by training foreign partner countries to implement U.S. sanctions on Iran’s nuclear weapons and ballistic missile programs, and disrupts proliferation networks tied to the CCP, DPRK, and Russia that undermine U.S. interests. CTR also advances EO 14292 by preventing U.S. adversaries from advancing biological weapons capabilities through targeted biosecurity, physical security, and cybersecurity trainings and disrupts Iran’s and other U.S. adversary chemical weapons programs through assisting supply chain security of precursor chemicals and equipment. Finally, CTR advances EO 14285 Unleashing America’s Offshore Critical Minerals, by training critical mineral holders to derisk from reliance on Chinese and Russian Private Military Companies in favor of U.S. security firms.

Please see further eligibility requirements in the eligibility section of the NOFO below.

B. Eligibility

1. Eligible Applicants The following organizations are eligible to apply: U.S. for-profit organizations or businesses; U.S.-based non-profit/non-governmental organizations with or without 501(c) (3) status of the U.S. tax code; U.S.-based private, public, or state institutions of higher education; foreign-based non-profit organizations/non-government organizations (NGO); Federally Funded Research and Development Centers (FFRDCs); Public International Organizations (PIO); Foreign Public Entities (FPE); and foreign-based institutions of higher education.

2. Cost Sharing or Matching Providing cost sharing, matching, or cost participation is an eligibility factor or requirement for this NOFO and providing cost share will result in a more favorable competitive ranking. Per 2 CFR §200.306, items that are proposed for cost share must be allowable per 2 CFR §200, Subpart E—Costs Principles.

Voluntary cost-share: Should the applicant choose to contribute voluntary cost-share but does not meet the minimum amount of the voluntary cost-sharing stipulated in the applicant’s budget, DOS’ contribution may be reduced in proportion to the applicant’s contribution.

3. Other Eligibility Requirements All organizations must have a Unique Entity Identifier (UEI) issued via SAM.gov as well as a valid registration in SAM.gov. Please see Section D.3 for more information.

Note: The process of obtaining or renewing a SAM.gov registration may take anywhere from 4-8 weeks. Please begin your registration as early as possible.

Applicants can submit one application in response to the NOFO. If more than one application is submitted by an organization, only the final application received, and time stamped by grants.gov will be reviewed for eligibility. Each application can include multiple projects that will be evaluated independently.

C. Program Descriptions

1. Goals and Objectives

Proposals do not need to address all objectives and sub-objectives. Proposal that effectively address multiple objectives or fully address a single objective are more likely to receive a higher evaluation.

Line of Effort 1: Countering Russian Chemical and Biological Threats

Specific Aim 1: Understand Russian Procurement Modes, Networks, and Patterns

Background:

Russia has repeatedly used chemical and radiological weapons in assassination attempts and, on the battlefield, including high-profile incidents in the UK and Russia, as well as the use of chloropicrin in Ukraine in 2024. In response, the U.S. government has imposed sanctions and trade restrictions on 25 entities since 2020 for their roles in supporting Russian weapons of mass destruction programs, particularly chemical and biological weapons. CTR aims to help scientific equipment, biological, chemical, and pharmaceutical industries identify and mitigate risks of direct or indirect transactions with prohibited entities, thereby strengthening and securing their supply chains.

Objective: Conduct open-source research to provide CTR with transaction data, including stratified by geography, sector, and trends over time, in order to allow CTR to understand how to better: 1. target and engage manufacturers of scientific equipment, pharmaceuticals, chemicals (including relevant precursors), and related biological materials to help strengthen their compliance standards; and 2. to better target and engage distributors, financiers, insurers, logistics providers, intermediaries, subsidiaries, and other transshipment facilitators of those sectors to strengthen due diligence.

Countries: Global: Particularly EUR, SCA, and EAP.

Specific Aim 2: Disrupt Russian WMD Supply Chains Via Targeting Procurement Modes, Networks, and Patterns by Focusing on Manufacturers

Background:

CTR seeks innovative engagement strategies to help biological, biotechnology, chemical, and pharmaceutical (BBCP) manufacturers identify and mitigate risks of trading with prohibited WMD-linked Russian entities and strengthen their supply chains. CTR is also looking for implementers with expertise in BBCP technical fields, compliance, legal, financial, and sales to train manufacturers in supply chain security.

Objective: Leverage commercial trade data and other open-source tools to develop engagement strategies that help manufacturers identify and understand links to prohibited Russian entities and take proper de-risking actions.

Objective: Provide sector, country, company, and product specific data to manufacturers including stratified by geography, sector, and trends over time in order to demonstrate how to better target exactly what scientific equipment, pharmaceuticals, chemicals (including relevant precursors), and related biological materials Russia is trying to procure to help strengthen their compliance standards.

Objective: Educate BBCP sector manufacturers—regardless of company size or resources—on the latest U.S., EU, and partner country sanctions and trade restrictions, as well as Russia’s circumvention tactics (such as transshipment hubs, shell companies, and other diversion methods), and provide practical tools to help them recognize, detect, and avoid these efforts, thereby strengthening their internal compliance standards.

Objective: Provide tailored support to BBCP manufacturers of all sizes to strengthen controls against Russian sanctions evasion: for large multinationals with sanctions screening software, offer consultations to identify and address products still reaching Russia through direct, subsidiary, or third-country channels; for small and medium-sized companies without such resources, deliver in-depth trainings and individualized guidance on detecting and preventing circumvention tactics.

Countries: EUR, SCA, and EAP.

Specific Aim 3: Disrupt Russian BBCP Supply Chains via Targeting Procurement Modes, Networks, and Patterns by Focusing on Distributors

Background:

CTR seeks innovative strategies and qualified implementers with expertise in distribution, logistics, compliance, and BBCP/ and chemical and biological technical fields to train distributors on the risks and consequences of transporting materials to prohibited Russian entities. These efforts aim to help distributors recognize their exposure to sanctions evasion and strengthen their ability to prevent unwitting involvement in chemical and biological weapons (CBW) proliferation.

Objective: Educate BBCP distributors on the importance of the BBCP materials and equipment they are transporting, and serious consequences if these make their ways to prohibited Russian entities for purposes of CBW proliferation.

Objective: Educate BBCP sectors and regardless of company size and resources, manufactures on the latest U.S., EU, and other partner country sanctions and trade restrictions, as well as circumvention efforts Russia is employing (e.g., using transshipment hubs, shell companies, and other diversion tactics) to provide a comprehensive and broad view of needing to tighten their internal compliance standards.

Objective: Leverage commercial trade data and other open-source tools to develop engagement strategies that help distributors identify and understand links to prohibited entities and take proper de-risking actions.

Objective: Provide distributors with sector, country, company, and product specific data to distributors, including stratified by geography, sector, and trends over time, in order to demonstrate how to better vet and conduct due diligence on those procuring scientific equipment, pharmaceuticals, chemicals (including relevant precursors), and related biological materials Russia is trying to procure in order to help strengthen their compliance standards.

Objective: Provide tools for BBCP sector distributors, whether specialist services or those that work across multiple (and non BBCP) sectors, to allow companies to recognize, detect, and avoid circumvention efforts Russia is employing (e.g., using transshipment hubs, shell companies, and other diversion tactics) to provide a comprehensive and broad view in order to allow distributors to tighten their internal compliance standards.

Countries: EUR, SCA, and EAP.

Line of Effort 2: Countering Biological Weapons Threats, Protecting Biotechnologies, and Strengthening Implementation of the Biological Weapons Convention

Background: The goal of CTR’s Biosecurity Engagement Program (BEP) is to prevent U.S. adversaries from developing or advancing biological weapons (BW) programs that pose a direct threat to Americans at home and overseas, protect U.S. and allies’ biotechnologies and intellectual property from theft, diversion, and/or misuse by America’s adversaries, and promote U.S. industry abroad to solidify U.S. leadership in global biotechnology and life science sectors. BEP advances America First policy priorities, including President Trump’s Executive Order on Improving the Safety and Security of Biological Research (E.O. 14292), NSPM-2 “Imposing Maximum Pressure on Iran”, and NSPM-3 “America First Investment Policy.” Additionally, BEP aims to strengthen implementation and compliance of the Biological Weapons Convention. BEP seeks to achieve these goals through support for activities that support the following Specific Aims:

Specific Aim 1: Prevent U.S. adversaries from illicit access to and misuse of biological data, equipment, and scientific expertise for biological weapons development and deployment against Americans at home and abroad.

Objective: Train partners to screen and detect predatory biological research collaborations and agreements, including Know-Your-Collaborator/Investor, personnel reliability, research security, intellectual property (IP) protection, and data security topics and tools.

Objective: Protect sensitive biological data from exploitation and/or theft by providing trainings and targeted upgrades for cybersecurity.

Specific Aim 2: Protect U.S. and allies’ biotechnologies and biological supply chains from theft, diversion, and/or misuse by adversarial actors.

Objective: Provide training on Know-Your-Investor/Customer, research security, IP protection, and data security topics and tools.

Objective: Protect sensitive biological data from exploitation and/or theft by providing trainings and targeted upgrades for cybersecurity.

Objective: Train on due diligence measures to counter potential proliferation of BW-applicable materials from development and production to manufacturing within biological supply chains.

Specific Aim 3: Strengthen BWC implementation, enhance transparency and confidence of BWC compliance, and support the UN Secretary General’s Mechanism (UNSGM) activities.

Objective: Train partners on the technical capacity to identify, attribute, and response to the alleged use of a biological weapons attack, including support for participation in UNSGM exercises.

Objective: Support for development of novel tools, including AI, to strengthen implementation and compliance with the BWC.

Specific Aim 4: Demonstrate U.S. biotechnology leadership by establishing U.S. industry networks and promoting U.S. standards and best practices.

Objective: Leverage U.S. industry experts to lead dialogues with partner industry and Government representatives to promote U.S. standards and regulations.

Objective: Forge U.S. industry-partner relationships to promote U.S. companies as the partner of choice.

Objective: Train foreign private industry on Know-Your-Investor/Customer, IP protection, and data security topics.

BEP projects are threat-driven and prioritize trainings, security upgrades, and private sector engagements based on the presence of active threats from adversarial actors, the presence of potentially weaponizable sensitive data, including genomic data, and dual-use equipment and materials, and significant security vulnerabilities. BEP directs its support towards priority countries or institutions based on these factors, leveraging burden-sharing contributions from partner countries, when possible, to maximize its programmatic impact and strengthen U.S. national security. BEP is interested in promoting U.S. private industry in engagements with partner countries’ governments, private industry, and academic sectors to promote U.S. economic prosperity. Priority regions are WHA and EAP, followed by EUR and SCA, although priority countries may be found in other regions, Audiences for these activities may include, but are not limited to:

· Government Representatives: BEP seeks to engage Government officials that have decision-making roles in research oversight, cybersecurity, and data security frameworks and policy, such as BWC or nonproliferation and disarmament affairs.

· Biological Facility Managers, Directors, and Technical Staff: BEP seeks to engage biological facility managers, directors, and technical staff spanning government and academic labs to implement programs that promote U.S.-backed standards and establish security (cybersecurity, research security, cybersecurity) measures to prevent adversarial exploitation of sensitive data, dual-use materials and equipment, IP, and scientific expertise.

· University Leadership: BEP seeks to engage leadership of academic institutions engaged in life sciences research that could be exploited by adversarial actors, including academic institutions with collaborations with private industry partners. These audiences should have roles in university decision making, including implementation of policies and frameworks for IP protection, data sharing, institutional oversight, and personnel vetting.

· Private Industry Professionals: BEP seeks to engage private industry in dialogues with U.S. industry experts and Government representatives to promote U.S. leadership in biotechnology and life sciences sectors as well as promote U.S.-backed standards and regulations.

Line of Effort 3: Countering Chemical Weapons Threats

Specific Aim 1: Identify and disrupt the transfer of chemical precursors, laboratory research and chemical production equipment, and expertise to proliferator state chemical weapons (CW) programs.

Background: The Chemical Security Program’s Anticipated Countries of Impact for the following objectives are EAP, EUR, NEA, and SCA.

Objective: Intensifying open-source research about ongoing or potential state-specific CW proliferation pathways including land, air, and maritime routes for CW materials and related equipment as well exploitation of unwitting research partners to support diplomatic engagement, partner government investigations, and private industry compliance efforts.

Objective: Disrupting procurement networks for precursors of highly potent pharmaceuticals, including but not limited to central nervous system-acting (CNS-acting) chemicals.

Objective: Training producers, manufacturers, distributors, resellers, shipping agents, or others along the supply chain of CW-relevant goods, materials, and production equipment to adopt employee vetting and know-your-customer (KYC) programs to ensure chemicals and equipment are not diverted to malicious state actors or front companies operating on their behalf.

Objective: Training government and private industry on implementing CW-related sanctions.

Objective: Enhancing government oversight of proliferation-sensitive supply chains by advancing cross-sector collaboration and information sharing between government agencies, law enforcement, industry, and academic stakeholders.

Objective: Disrupting proliferator states from acquiring materials to conduct research on advanced CW capabilities.

Objective: Training partner government law enforcement to investigate and disrupt CW-related procurement activities in their jurisdiction.

Objective: Raising awareness among chemical scientists, technicians, and engineers in partner countries of the dual-use dangers associated with research collaborations with proliferator states.

Specific Aim 2: Enhance global efforts to deter CW use through response and attribution

Background: The Chemical Security Program’s Anticipated Countries of Impact for the following objectives are EAP, EUR, NEA, and SCA.

Objective: Improving partner states’ defensive countermeasures to identify and characterize early indicators of CW attacks and make recommendations to decision-makers for diagnosis, decontamination, protection, and medical treatment.

Objective: Improving information sharing among first responders, law enforcement, and government stakeholders.

Objective: Build capability to support international analysis and verification efforts by facilitating discussions on existing laboratory capabilities, identifying strengths in national laboratory networks, and building capacity to participate in the Chemical Weapons Convention Chemical Analysis Competency Test (CCACT).

Objective: Strengthening the ability of law enforcement agencies to investigate chemical attacks, manage crime scenes that are contaminated with chemical materials, and attribute the chemicals involved to their sources or intermediate handling.

Objective: Developing trainings, field exercises, lectures, tabletop exercises (TTXs), and hands-on field training that tackle chemical threat scenarios and utilize technologies to respond to and attribute chemical attacks.

Specific Aim 3: Reinforce global norms against CW research, production, stockpiling, and use and promoting Chemical Weapons Convention (CWC) implementation.

Background: The Chemical Security Program’s Anticipated Countries of Impact for the following objectives are AF, EAP, NEA, SCA, and WHA.

Objective: Building partner governments’ capacities to comply with OPCW Executive Council and Conference of States Parties decisions, including decisions related to aerosolized use of CNS-acting chemicals in conjunction with law enforcement purposes.

Objective: Providing tailored assistance to support more effective government and industry risk mitigation to address new chemical security threats (e.g., new or modified chemical agents not included in CWC schedules or new technologies or equipment to facilitate production or use of CW) and empower governments, NGOs, and individuals to advocate for the CWC and its decisions without placing undue burdens on trade and business.

Specific Aim 4: Prevent non-state actor CW attacks targeting the United States and its partners and allies.

Background: The Chemical Security Program’s Anticipated Countries of Impact for the following objectives are NEA and SCA.

Objective: In addition to the objectives described above, engaging partner governments’ ability to identify vulnerable chemicals of concern in their jurisdictions and support relevant stakeholders in securing them in accordance with international best practices.

Line of Effort 4: Countering Chinese and Russian Proliferation of Advanced Conventional Weapons

Specific Aim 1: Countering Chinese and Russian Proliferator Procurement Networks

Background: CTR programming seeks to engage private sector technology manufacturers, suppliers, distributors, freight forwarders, shipping companies and wholesalers, public sector free trade zone authorities, financial intelligence units, and enforcement agencies to counter these illicit networks to help prevent the proliferation of ACW systems and technology from China and to Russia.

Objective: Use commercially-available and open-source data to develop and disseminate research reports that help partners to identify dual- and military- use components, front and shell companies, jurisdictional patterns and behavioral indicators, and illicit procurement pathways for military-related items in order to de-risk and disrupt those activities. Conduct engagements that enhance partners’ ability to develop, analyze and utilize open-source data to identify high-risk transactions, suspicious corporate activities, trade anomalies and procurement networks of military applicable components to proliferator states.

Objective: Build and/or improve capacity of private sector technology manufacturers, suppliers, distributors, and wholesalers to conduct enhanced due diligence for procurement practices, Know Your Customer and Customer’s Customer (KYC/C) protocols and procedures, and equip them with practical tools and resources to strengthen their investigative capabilities for identifying, assessing, and mitigating illicit procurement and proliferation risks related to specific commodities, such as microprocessors, integrated and printed circuit boards, Surface Mount Technology equipment, etc.), with military applications.

Objective: Engage major machine tool, microelectronic, semiconductor, and other high-end dual-use manufacturers to raise awareness on the risk of illicit entities seeking to invest or engage in joint ventures with primary or sub-tier supply chain companies involved in the design, production, or sale of these technologies.

Objective: Improve public-private partnership, data sharing, and other types of collaboration.

Objective: Equip technology manufacturers and other target audiences with the knowledge to effectively institutionalize internal compliance programs to ensure adherence to compliance practices, strengthen risk-based due diligence and prevent illicit diversion within global supply chains.

Objective: Develop and disseminate commercially available, open-source information to identify high-risk defense networks and exports to include: the methods, vessels, and aircraft facilitating these transactions, and the trade restrictions and sanction risks associated with transacting with these entities.

Specific Aim 2: Countering Chinese and Russian Proliferation of ACW

Background: Proliferator states, such as Russia and China, increasingly use the sale of their ACW systems as a means to obtain financial resources, exert political or economic influence, and create strategic defense dependencies. By analyzing and exposing global proliferator state-linked defense networks, public and private sector stakeholders can avoid predatory business venture risks, identify potential high-risk transactions, and help to ensure compliance with international sanctions. In addition, proliferator states use the development and sale of ACW systems as part of its strategy of self-reliance to access and help produce high-end technologies that enable its own military modernization efforts.

Objective: Equip public and private sector stakeholders with an understanding of how defense entities linked to proliferator states exploit commercial partnerships and joint ventures to illicitly market and sell defense articles and ACW. Provide commercially available information on these networks—including deceptive business practices, misuse of transportation assets, and transactional red flags—while outlining the trade restrictions, and compliance risks associated with engaging such entities

Objective: Support key business consultation firms to provide peer-to-peer engagements with foreign private sector partners to limit corporate risks and exposure to sanctioned, prohibited, or otherwise high-risk defense firms linked to proliferator states.

Specific Aim 3: Countering Unaccountable Private Military and Security Companies (PMSC):

Background: Private military and security companies supported by Russia and China contribute to the unaccountable proliferation of advanced conventional weapons and create economic and political influence that are counter to U.S. national security priorities, especially in WHA where they are a competitor to American interests.

Objective: Assist key defense, security, law enforcement, and private sector entities in partner countries to professionalize and standardize international best practices during the solicitation, procurement, and oversight processes when obtaining PMSC services. Simultaneously, focus in-person training content on promoting reliable American alternatives to the use of known unaccountable mercenary groups.

Objective: Implement tailored in-person engagements that provide the target audience with case studies, open-source training tools, and research methodologies to identify PMSCs involved in extralegal acts. This would include open-source data and information on PMSC deployments, modes of transport, financing, subsidiary, and logistics networks facilitating PMSC deployments to public and private sector partner enforcement officials

Objective: Demonstrate the strategic, economic, and governance risks associated with Chinese and Russian companies securing and exploiting critical natural resources, including critical minerals, and highlight their links to PMSCs, in order to raise awareness among policymakers, industry stakeholders, and regulators about the potential consequences for national security, supply chain integrity, and responsible resource management.

Specific Aim 4: Disrupting Weapons-Enabling Critical Minerals Supply Chains

Background: Critical minerals form the backbone of many ACW systems. Proliferator states, such as China and Russia, have aggressively sought to establish control over critical mineral supply chains, which they use to source irreplaceable materials for their advanced conventional weapons programs. Proliferator states also use these supply chains to exert economic and political influence on host countries and restrict U.S. access to these materials and their derivate products.

Objective: Raise Sector Awareness: Increase mining, infrastructure, financial, and other relevant sector awareness of the linkages between proliferator state critical mineral supply chains and their advanced conventional weapons industries. Develop research products using commercially and publicly available information that highlights these risks.

Objective: Support due diligence and risk management by engaging key private sector compliance managers and executives through workshops and private one-on-one consultations, providing guidance on large-transaction due diligence and best practices to effectively evaluate and mitigate reputational and compliance risks. Provide examples of proliferator weapons industry linkages that could lead to increased scrutiny, reputational harm, and sanctions risk. Provide and demonstrate free and low-cost open-source tools that assist in identifying risks.

Priority Regions: WHA, EAP, and SCA.

Line of Effort 5: Countering Iran and DPRK’s WMD, Nuclear, Ballistic Missile, and Drone Proliferation

Specific Aim 1: Disrupt and deny Iranian procurement efforts in support of their nuclear, ballistic missile, and drone programs.

Background: CTR’s Counterproliferation and Sanctions Enforcement (CASE) program directly supports President Trump’s Maximum Pressure Campaign on Iran by impeding Iran’s ability to develop and export ballistic missiles and UAS, slowing its nuclear enrichment pursuits, and constraining its military support to Iranian-back proxies and terrorists. To carry out this campaign, CASE-funded projects should enhance partner government and private sector capacity to identify and disrupt Iran’s efforts to procure components and other materials for its ballistic missile (BM) and unmanned aircraft system (UAS) programs and comply with U.S. and other international financial sanctions targeting Iran’s BM and UAS programs.

Objective: Deny the transfer of ballistic missile, nuclear, and drone-related technology and materials to and from Iran and its proxies by:

· Promoting and supporting robust global implementation of U.S. and UN sanctions on Iran, including the UN sanctions recently reinstated through the “snap back” mechanism within UNSCR 2231;

· Engaging relevant technology manufacturers, distributors, and developers on public-private sector cooperation, information sharing, KYC best practices, suspicious transaction reporting, and characteristics of sanctions evasion techniques that Iran uses to procure components, materials, and equipment to advance its UAS, nuclear fuel, and ballistic missile production capabilities;

· Assisting partner country governments in raising awareness among the private sector of U.S. and international sanctions concerning Iranian procurements of ballistic missile, nuclear, and UAS technologies and components; and

· Assisting partner county government in ensuring entities in their jurisdiction are not supplying prohibited items, technology, and knowledge to Iran’s nuclear enrichment program.

Objective: Support UN Member State autonomous sanctions and disruption actions by providing open-source information pertaining to sanctions evasion activities such as:

· Identifying and providing in-depth insight into these activities, as well as providing quick-turn, actionable, unclassified data for security assistance-related purposes in response to CTR requests;

· Investigating Iranian procurement and import trends, particularly on products that violate U.S. and UN sanctions and that support Iran’s nuclear advancements; and

· Identifying and mapping ownership networks, structures, and personnel involved with known or suspected front companies and procurement activities for the Iranian Revolutionary Guard Corps (IRGC). CTR is especially interested in activities and networks involving or impacting entities within the jurisdiction of U.S. foreign partners.

Specific Aim 2: Deny DPRK sanctions evasion and revenue generation in support of their WMD and missile programs.

Background: CASE counters DPRK’s WMD and missile programs by disrupting DPRK illicit revenue generation activities, exposing its sanctions violations, and limiting the flow of proliferation-sensitive components and materials to the DPRK. To achieve this, CASE-funded projects should enhance partner government and private sector capabilities to curtail DPRK WMD and ballistic missile proliferation by constraining DPRK revenue generation, procurements of certain resources and commodities, and other activities prohibited by UNSCRs, U.S., and other international sanctions.

Objective: Disrupt DPRK Cyber-Enabled Theft and Laundering of Virtual Assets

· Train technical and non-technical staff at virtual asset service providers (VASPs), financial institutions (FIs), and other likely targets of DPRK cyber activity to prevent DPRK cyber-revenue generation by identifying common social engineering techniques such as phishing attacks, and adopting enhanced cybersecurity measures including basic cyber hygiene practices;

· Train government officials to promote effective cybersecurity practices at VASPs and FIs to counter DPRK-linked exploitation, including public-private information sharing on cyber threat intelligence and designing effective cyber incident response plans;

· Train law enforcement officials to investigate malware and other malicious cyber activity for links to the DPRK;

· Educate and encourage VASPs to utilize blockchain transaction monitoring software to detect and block DPRK-linked funds before a transaction is executed, promoting U.S. software and business interests;

· Provide relevant law enforcement officials with the knowledge and tools to successfully trace, freeze, and seize stolen virtual assets in their jurisdictions, and utilize these capabilities in cooperation with international law enforcement efforts to disrupt DPRK-linked virtual asset laundering; and

· Support international adoption of novel efforts to address DPRK virtual asset enabled revenue generation.

Objective: Disrupt DPRK Information Technology (IT) Workers and Laborers from Generating revenue for DPRK sanctioned WMD and missile programs.

· Drawing from the U.S. Government IT workers advisory published in 2022 and updated in 2023 and the Multilateral Sanctions Monitoring (MSTM) reports published in 2025, Train the global tech industry to detect DPRK IT worker tactics to secure jobs (e.g. interview techniques and application red flags) to prevent DPRK WMD revenue generation and promote the hiring of U.S. experts and employees instead;

· Convene officials from ministries of labor, health, immigration, and foreign affairs, and law enforcement officials to improve inter-agency collaboration to identify and expel DPRK nationals working abroad on behalf of the DPRK regime, including those whose nationality has been obscured or falsified, or whose visa types have been fraudulently changed to evade deportation;

· Heighten awareness and expertise among partner government and media leaders about risks associated with employing DPRK laborers;

· Work with prosecutors to develop new approaches to disrupting DPRK laborers working abroad on behalf of the DPRK regime where national immigration or related authorities for expulsion are not in place; and

· Train immigration and customs personnel in database analysis and relevant open-source research techniques to identify DPRK nationals working abroad on behalf of the DPRK regime in partner countries’ territories.

Objective: Prevent the DPRK from exploiting the global maritime industry to evade UN sanctions on maritime commerce and to generate revenue for WMD development.

· Train publicly and privately-operated ship registries to conduct proper due diligence to identify, deregister, and report Iran and DPRK-linked vessels already on, or applying to, their respective registries;

· Convene bilateral and multilateral engagements to standardize rigorous compliance practices, and find creative opportunities to reach registries exploited by Iran and DPRK, which ACN/CTR has not yet engaged;

· Assist countries to conduct audits of their ship registries and deregister Iran and DPRK-linked vessels, and training maritime administration staff to conduct their own audits;

· Help countries to develop stronger registry oversight measures, including requirements for beneficial ownership information and best practices to identify whether ships have been physically altered to avoid sanctions evasion detection or have undertaken suspicious activities at sea such as turning off automatic identification systems (AIS) and loitering in known ship-to-ship transfer zones;

· Encourage and train ship registry personnel, when deregistering or denying DPRK-linked applications, to comply with information-sharing and reporting agreements with other ship registries, the United Nations, the United States, and the wider maritime community;

· Engage the International Maritime Organization (IMO) secretariat and/or IMO member states to improve sanctions compliance and facilitate information sharing about DPRK and Iran sanctions evasion activities through multilateral information sharing mechanisms databases;

· Advise countries that outsource ship registry management to a private entity on how best to design their ship registry management contract, conduct oversight of the private entity, and ensure sanctions compliance; and

· Engage with government authorities, ship registries, and port authorities to detect and disrupt the use of fraudulent flags, fraudulent registries, and other emerging tactics by threat actors such as DPRK and Iran to evade sanctions.

Objective: Support UN Member State sanctions and disruption actions by providing open-source information pertaining to sanctions evasion activities such as:

· Identify and provide in-depth insight into DPRK proliferation activities to target and develop security assistance trainings; and

· Provide quick-turn, actionable, unclassified data for security assistance purposes in response to CTR requests.

Line of Effort 6: Countering U.S. Adversary WMD and Drone Threats in Iraq

Specific Aim 1: Enhance Iraqi Ability to Counter State and Non-State UAS Threats

Background: In support of the Maximum Pressure Campaign on Iran (NSPM-2) and to protect U.S. troops and allies in the region, the Iraq Program enhances Iraq’s ability to counter state and non-state unmanned aerial systems (UAS)/unmanned aerial vehicle (UAV) threats, especially by Iranian-proxy groups operating in the region. Audiences for these engagements may include, but are not limited to, Government of Iraq (GOI), the Kurdistan Regional Government (KRG), and forensic investigators. All projects should aim to further Iraq’s establishment of a self-sustaining, proliferation-resistant security culture that reduces the threat posed by terrorist organizations or proliferator states seeking the means by which to obtain WMD and delivery systems for the purposes of threatening the United States and related interests.

Objective: Increase Iraqi national security institutions’ awareness of UAS threats and defensive measures.

Objective: Support Iraqi-led implementation of national strategies and action plans that regulate UAS usage in Iraqi airspace.

Objective: Enhance regional collaboration between the GOI and the KRG on countering UAS threats.

Specific Aim 2: Bolster Chemical, Biological, and Radiological (CBR) Response Capabilities of Security Forces, Forensic Investigators, First Responders, and Medical Staff.

Background: The goal of the CTR Iraq Program is to protect U.S. personnel, including U.S. forces based in the region, from attacks by securing chemical, biological, and radiological materials, dual-use equipment, technologies, expertise, and infrastructure to prevent their misuse by state and non-state actors such as Iran and its proxies. Given its borders with both Iran and Syria, CTR also plans to ensure Iraq is ready to deal with any CBR threats that could emanate from both Syria and Iran. Audiences for these engagements may include, but are not limited to, Government of Iraq (GOI), the Kurdistan Regional Government (KRG), first responders, forensic investigators, and private sector enterprises. All projects should aim to further Iraq’s establishment of a self-sustaining, proliferation-resistant security culture that reduces the threat posed by terrorist organizations or proliferator states seeking the means by which to obtain WMD and delivery systems for the purposes of threatening the United States and related interests.

Objective: Strengthen preparedness to identify, disrupt, and respond to an incident or attack involving pharmaceutical-based agents, toxins, or other chemical irritants by state and non-state actors.

Objective: Develop best practices for sample chain-of-custody between the field sampling and confirmation laboratories, particularly in conflict prone environments, and increase forensic investigators’ identification and attribution capacity during WMD incidents.

Objective: Enhance public, private, and regional collaborations.

· Strengthen government, chemical industry, and academic institution partnerships to mitigate and respond to potential sabotage at high-risk chemical facilities.

· Develop agency-specific plans to mitigate chemical and biological threats related to toxic industrial chemicals, and pesticides, at mass gatherings, or potential insider threats.

· In support of NSPM-2, CTR’s Iraq program seeks to maximize pressure on Iran’s weapons program by securing supply chains and weaponizable materials within Iraq.

Line of Effort 7: Denying U.S. Adversaries Access to Sensitive Nuclear, Missile, and Advanced Technical Expertise for Weapons of Mass Destruction Programs that Threaten America

ACN/CTR no longer expects to have sufficient resourcing to fund projects under this LOE, please do not submit any projects to this LOE.

Line of Effort 8: Enforcing Sanctions on China and Russia

Specific Aim 1: Targeted Financial Sector Engagements on Sanctions Compliance China and Russia rely on continued access to the U.S.-led global financial system to acquire proliferation-sensitive goods and technologies and to facilitate onward proliferation through illicit trade networks. Financial sector entities must move beyond basic list-based screening to understand evolving evasion strategies and to identify ultimate beneficial owners (UBOs) to maintain effective sanctions compliance. Strengthening the ability of foreign governments and financial institutions to detect complex networks of front and shell companies, as well as to identify transactions involving restricted or dual-use goods, is essential for maintaining good standing with U.S. regulators and correspondent banks. These programs will engage foreign financial regulators and private sector financial institutions, providing technical training, practical tools, and individualized guidance to strengthen internal compliance programs, effectively implement U.S. sanctions, and disrupt proliferation activities.

Objective: Partner with local business associations, chambers of commerce or trade groups to identify and engage small and medium sized financial institutions—including commercial and cooperative banks, microfinance institutions, and electronic payment providers—with limited compliance capacity, through technical full- or half-day trainings for 20-50 participants each or private one-on-one consultations to strengthen their understanding of U.S., E.U. U.K. and other aligned sanctions regimes, improve risk management practices, and enhance their ability to prevent illicit transactions.

Objective: Develop and deliver targeted training programs for financial stakeholders operating in digital currencies and decentralized payment networks, including banks, fintech companies, cryptocurrency exchanges, payment processors, and relevant public sector agencies. Begin by identifying and surveying these stakeholders to assess their current understanding and the specific compliance challenges they face. The training should address the unique risks and complexities of sanctions compliance in the crypto sector, emphasizing effective due diligence processes and the critical role of regulatory oversight in implementing and enforcing sanctions.

Objective: Strengthen public-private partnerships in the financial sector by providing targeted trainings designed to enhance coordination, information sharing, and collaboration between government regulators and private sector actors. Through these tailored sessions, participants will develop practical skills to improve suspicious transaction and activity reporting and response mechanisms, jointly identify, assess, respond to and mitigate financial risks, including those related to sanctions, illicit finance, and trade-based proliferation, thereby improving overall sector-wide resilience and compliance.

Objective: Integrate jurisdiction-specific case studies into sanctions compliance trainings, tailored to each audience, to illustrate local sanction evasion exposure risks and practical mitigation strategies. These case studies will form the basis of interactive exercises, enabling participants to actively apply knowledge and enhance their ability to detect and address sanction evasion risks within their specific operational context, thereby disrupting potential sanction evasion activities by China and Russia.

Objective: Leverage commercially available and open-source data to develop and disseminate reports that assist partners in identifying beneficial ownership structures, subsidiaries, lenders, financiers, and other connections to sanctioned or prohibited entities. These reports will enable partners to better understand complex ownership networks, OFAC’s 50% rule and use this information to take appropriate action, such as derisking or avoiding high-risk transactions.

Objective: Advanced Trainings on New Regulatory Development and Emerging Risk: Experts should update materials to reflect new regulations, guidance, and discuss their implications.

Objective: Train financial institutions to institutionalize and/or strengthen internal compliance programs, ensuring streamlined risk assessment and compliance mechanisms, commitments from senior leadership, and consistent policies and controls across the organization; empower improvements of mechanisms risk committees use to identify, assess, and mitigate financial, operational, and reputational risks. These improvements will enable institutions to enhance regulatory compliance, prevent illicit activities, and foster a culture of accountability and risk awareness.

Specific Aim 2: Counter Private Sector Sanctions Evasion Chinese and Russian actors exploit dual-use advanced technology and manufacturing sectors to strengthen their military capabilities and advanced weapons programs. CTR’s security assistance programming aim to engage key private sector stakeholders and relevant public sector regulators to counter these activities within advanced technology manufacturing, distribution, and logistics sectors. Targeted stakeholders include startups and businesses developing advanced materials, software, machine tools, and microelectronics; distributors of these goods; air, ground, and maritime logistics companies involved in international procurement; and public sector entities such as ministries of trade, industry, and commerce with regulatory oversight.

Objective: Enable macro level data-driven analysis and reporting: Offer access to open-source tools and expert support for analyzing large datasets that reveal how global trade and financial networks are manipulated to evade nonproliferation norms. Produce actionable reports for non-technical audiences, detailing violations and risks associated with illicit procurement networks that are leveraged in trainings and targeted engagements.

Objective: Investigate entities and networks involved in evasion: Provide resources and expertise to analyze entities, individuals, companies, and specific transport involved in sanctions evasion. Develop clear reports for internal and external audiences, identifying violations, networks of enablers, and risk typologies, that can then be used for taking enforcement action or de-risking.

Specific Aim 3: Counter Maritime and Related Sanctions Evasion Russia’s continued export of oil and gas provides its largest source of revenue that fund…