Extending Counterproliferation into the Civil-Economic Domain: The Role of Civil Affairs in Disrupting Illicit Trade Networks

Nathan Emery and Yevgeny Gershman

Abstract

Counterproliferation is often conceptualized as a highly technical mission domain, dominated by the U.S. Intelligence Community, Special Operations Forces, and federal agencies. Proliferators such as Russia, China, Iran, and North Korea leverage illicit procurement networks alongside the legitimate mechanisms of global trade and finance.  This article argues that Civil Affairs (CA) officers with Commerce and Trade specialties represent an underutilized capability for the Department of Defense’s counterproliferation mission. Through their expertise in trade, customs, finance, and governance, CA officers are uniquely positioned to disrupt illicit networks by mapping supply chains, strengthening partner institutions, and bridging military operations with interagency enforcement.  Although U.S. agencies such as the Departments of Commerce, Justice, State, and Homeland Security enforce federal laws and regulate the export of sensitive goods, efforts to curb illicit transfers to authoritarian regimes and hostile states are hindered by limited oversight and the slow, cumbersome nature of enforcement.  Drawing on doctrinal review, interagency practice, and case studies of Russia’s oil “shadow fleet,” Chinese money laundering organizations, and North Korea’s sanctions evasion network, this article explores how CA officers can extend counterproliferation into the civil-economic domain. The article concludes that integrating CA officers into joint and interagency counterproliferation frameworks would significantly enhance the United States’ ability to contest proliferation in the global commons.

Introduction

The proliferation of weapons of mass destruction (WMD), dual-use technologies, and illicit trade networks is not only a technical challenge; it is fundamentally an economic and governance problem. According to JP 3-40, counterproliferation entails efforts to dissuade, prevent, or roll back WMD programs.[i] Still, in practice, proliferators leverage legitimate global pathways such as shipping lanes and international finance to evade these measures.  Russia, China, Iran, and North Korea routinely demonstrate the ability to manipulate trade flows, employ front companies, make use of relationships in transit nations, and exploit weak customs regimes, as well as banking regulations, which have become as decisive as covert procurement itself.

Traditionally, counterproliferation has been the purview of intelligence agencies, special operations forces, and federal agencies such as Homeland Security Investigations (HSI), the Federal Bureau of Investigation (FBI), and the Department of Commerce – Bureau of Industry and Security (BIS). While essential, these actors are not always present where proliferators operate.  This absence is highlighted within the diplomatic constraints placed on limiting the number of U.S. personnel assigned to foreign posts.  Further, proliferators often operate in denied/semi-permissible areas, cut off from the reach from U.S. law enforcement.  This has led to complications in obtaining evidence and sources of information with firsthand knowledge of illicit acts.  The U.S. Attorney’s Office maintains prosecutorial authority in this domain, and because of these operational hurdles, only a small fraction of export control violations result in criminal charges.  Between February 2023 and September 2024, for example, the Department of Justice-led Disruptive Technology Strikeforce brought just 24 public cases against 34 defendants.[ii]  In contrast, CA officers are routinely deployed in those contested spaces, engaging host-nation governments, ministries, and commercial sectors. Within CA, the Commerce and Trade specialty provides officers with advanced civilian expertise in economics, trade, and finance. These officers are uniquely equipped to bridge the gap between the civil-economic terrain and military counterproliferation operations.  Moreover, they can augment prosecutorial efforts by contributing to joint task force initiatives and sharing relevant analytical data.

This article addresses the research question: How can CA officers support counterproliferation by leveraging trade and economic expertise? Methodologically, it combines a review of doctrine (JP 3-40, ATP 3-57.80, FM 3-57), analysis of interagency practices, and illustrative case studies. It advances three key arguments: (1) a doctrinal gap: counterproliferation doctrine highlights civil/economic systems but does not operationalize them; (2) operational value: CA officers contribute directly via economic reconnaissance, export control advising, and capacity-building; (3) strategic necessity, that is integrating CA officers into interagency and multinational counterproliferation frameworks enhances U.S. ability to contest proliferation in the global commons.

Counterproliferation in Doctrine and Scholarship: The Civil-Economic Seam

The role of CA officers in counterproliferation remains significantly underexplored in both doctrine and scholarship. While research on counterproliferation, sanctions enforcement, and economic statecraft has expanded, few studies consider how these issues intersect with CA’s civil engagement mission. This is a critical oversight: CA officers routinely interact with the very institutions, such as customs services, local law enforcement, trade ministries, and importers/exporters that proliferators exploit, yet they are rarely integrated into the counterproliferation enterprise.  The U.S. Army’s Civil Affairs branch houses advanced subject-matter experts in industry and production, law and border enforcement, and commerce and trade.   These U.S. Army reservists bring with them their civilian careers that provide direct experience with export regulations and trade networks, giving them specialized knowledge well-suited to identifying and addressing export-controlled violations.   

U.S. military doctrine outlines counterproliferation within the broader framework of Departments of Defense (DOD) Countering Weapons of Mass Destruction (CWMD). Joint Publication (JP) 3-40 defines counterproliferation as actions to “dissuade, prevent, or roll back programs and networks” that support WMD acquisition.[iii] It emphasizes disrupting the “people, money, and materials” behind adversary programs, while the 2022 and 2023 DoD CWMD strategies highlight the importance of impeding procurement and financing.[iv][v] Yet in practice, doctrine focuses primarily on Special Operations Forces (SOF), intelligence agencies, and federal law enforcement. CA forces are absent, despite their mandate to engage with ministries of trade, customs authorities, and the commercial sector. 

This doctrinal orientation has shaped the academic literature. Analysts often emphasize the technical and operational dimensions of counterproliferation while giving less attention to the economic terrain. William Tobey argues that illicit nuclear trade thrives “in the cracks of globalization,” where enforcement and governance are weakest. Matthew Kroenig highlights that sanctions succeed or fail at the weakest enforcement link in international supply chains.[vi] These insights reinforce what doctrine implies but does not act upon: effective counterproliferation must address civil-economic vulnerabilities, yet both doctrine and scholarship tend to relegate these domains to the margins.

CA doctrine itself acknowledges governance and economic engagement, but stops short of linking these competencies to counterproliferation. ATP 3-57.80 directs CA forces to conduct civil reconnaissance and engagement across governance, economic, infrastructure, and social domains, while FM 3-57 references CA contributions to CWMD to promote awareness, improve preparedness, and help secure dual-use materials.[vii][viii] However, neither explicitly uses the term “counterproliferation” nor assigns CA officers tasks in sanctions enforcement, export control implementation, or the denial of illicit procurement.  CA scholarship similarly identifies CA’s relevance but does not extend the analysis to threats of proliferation. Christopher Holshek, for example, emphasizes CA’s role in “gray zone competition” and irregular warfare, yet stops short of linking CA expertise to nonproliferation or sanctions enforcement.[ix]

ATP 3-57.30 directs CA forces to identify civil networks that should be neutralized if they are determined to be a hindrance to mission objectives.[x]  CA forces provide the necessary network perspective on the relationships among threat elements and other threat, neutral, friendly, and unknown elements.  This process supports the operational framework outlined in JP 3-40, titled "Pathway Defeat." The concept of pathway defeat refers to a set of activities and operations aimed at preventing adversaries from developing and acquiring WMD.[xi]  Rather than focusing on neutralizing existing stockpiles, pathway defeat focuses on disrupting the networks, resources, and processes that enable WMD development and proliferation.  These efforts include delaying or complicating procurement, undermining technical cooperation, and targeting economic and logistical infrastructures that facilitate proliferation. 

In contrast, the broader literature on sanctions and economic statecraft underscores the importance of including CA in the counterproliferation mission. Daniel Drezner has shown that sanctions are effective only when enforcement is credible and multinational.[xii] Juan Zarate highlights how financial warfare has become central to U.S. strategy, but also how proliferators adapt by exploiting weak enforcement regimes.[xiii] RAND and CSIS studies confirm that uneven compliance across states undermines sanctions, particularly in regions with fragile customs systems and governance.[xiv][xv] For example, Ayushman Mukherjee highlights how countries such as China, India, Turkey, and the UAE have bolstered Russian resilience by offering financial incentives to sustain trade, illustrating a common sanctions-evasion model that complicates enforcement.[xvi]  U.S. Treasury and Commerce Department reports consistently identify capacity gaps in partner nations’ regulatory systems.[xvii][xviii] These findings converge on the same point: enforcement is local, fragile, and often dependent on the very institutions where CA forces routinely engage.

The Army’s creation of Functional Area 52 (FA52) Nuclear and Counterproliferation Officers demonstrates recognition that proliferation is a specialized mission. Yet FA52s are relatively few, concentrated at higher echelons, and often tied to strategic-level billets.[xix] Operational and tactical commanders, therefore, lack accessible expertise on the ground, even as proliferators exploit free trade zones, customs regimes, logistics corridors, and financial channels in their area of operations (AO). CA officers, particularly those with the D1 CWMD Specialist identifier, can complement FA52s by projecting forward civil-economic counterproliferation capacity. Through civil reconnaissance, economic and financial expertise, capacity-building, and institutional engagement, they can address enforcement gaps in the very places proliferators exploit.  At a minimum, these capabilities should be integrated within Joint Task Force intelligence cells and working groups, creating a mechanism to share actionable insights directly with U.S. enforcement agencies.

Taken together, U.S. military doctrine acknowledges the economic dimensions of proliferation without operationalizing them, CA doctrine emphasizes economic engagement without linking it to counterproliferation, and sanctions scholarship highlights enforcement gaps while assuming interagency leads will fill them.  This convergence reveals a seam in both practice and analysis. CA officers, especially with specialized CWMD advisor training (D1 ASI – discussed below) and commerce and trade, are uniquely positioned to close that seam and navigate economic and military spaces simultaneously  by extending counterproliferation into the civil-economic domain, strengthening local enforcement capacity, and connecting military operations with interagency action.

Civil Affairs Capabilities in the Counterproliferation Mission

The CA Proponent System recruits officers with deep civilian expertise in 23 different areas of civil society to include governance, law, infrastructure, economics, and related domains. The 6E Commerce and Trade specialty focuses on officers with advanced knowledge of economics, trade systems, international business, customs, and financial regulation. These skills uniquely position CA officers to support counterproliferation by assessing supply chains, customs systems, and financial/economic mechanisms vulnerable to exploitation.

Trade routes and networks are inherently complex, with the movement of dual-use goods and technologies often sustaining rogue military capabilities that span multiple jurisdictions. These flows are reinforced by adaptive payment systems designed to obscure links to sanctioned entities.  A rare success, U.S. v. Goltsev (2024), exposed a criminal network that transshipped millions of sensitive microchips to Russian defense contractors by exploiting U.S.-based procurement firms, free trade zones in Hong Kong and Dubai, and falsified or incomplete customs and end-user documentation.[xx] Common techniques of sanctions evasion include fictitious invoices, routing payments through third parties unconnected to sanctioned entities, undervaluing shipments, and employing ambiguous language to disguise tactical items as benign. Detecting such practices requires deep familiarity with global supply chains, trade networks, and customs processes.  This is expertise, that is typically gained through years of field experience, is indispensable to effective counterproliferation.

Applied to counterproliferation, the CA officer provides a skill set distinct from that of traditional intelligence, SOF, or FA52 specialists. They understand how legitimate trade networks function, how customs regulations are structured, and how proliferators exploit gaps in both. A CA officer who previously worked in global logistics may identify suspicious spikes in re-exports of dual-use electronics from a partner nation to a sanctioned jurisdiction; unlike a purely intelligence-focused approach, the CA officer can sit with the host-nation customs service to explain the risk, strengthen compliance, and close the loophole.  Further, CA enables cost imposition by employing civil engagement, civil reconnaissance, and civil network development to bolster partner-nation capacity for enforcing WMD-related rules and norms. These activities help deny proliferators access to permissive civil environments, increase the operational and financial costs of illicit procurement, and support the broader diplomatic and economic measures outlined in the 2023 DoD Strategy for Countering WMD.[xxi]

The D1 Additional Skill Identifier (Countering WMD Specialist) adds doctrinal depth. D1-trained CA officers combine trade and governance knowledge with familiarity in CWMD doctrine, proliferation pathways, and interagency networks.[xxii] They can “speak both languages,” explaining sanctions and trade data to interagency partners while advising military commanders on how adversaries use civil institutions to circumvent controls. Given the shortage of FA52s, D1-qualified CA officers offer commanders a way to project counterproliferation knowledge into operational and tactical environments. While they cannot replace the technical nuclear engineering knowledge of an FA52, they complement it by covering the civil and economic aspects of the mission.

Lines of Effort for Civil Affairs

CA officers can structure their contributions around four mutually reinforcing lines of effort.

LOE 1: Trade Network Mapping. Proliferators depend on complex global trade networks in which illicit shipments are hidden among legitimate flows. Russian oil exporters use shell companies and opaque registries; North Korean firms re-export dual-use electronics through Southeast Asia; and Chinese Money Laundering Organizations (CMLOs) use front companies abroad to ship drone components. CA officers conduct economic civil reconnaissance by reviewing trade data and customs data, processes and regulations, meeting with freight forwarders and chambers of commerce, and mapping vulnerable industries, including chemical, electronics, and energy infrastructure. These findings feed commanders’ situational understanding and inform interagency targeting.

LOE 2: Export Control and Sanctions Advising. Sanctions regimes only work if enforced locally. Many partner nations lack resources or training to implement complex control lists or investigate layered shell-company structures. CA officers can help translate UN, U.S., and EU sanctions into practical inspection and documentation procedures; advise on best practices in customs; and link partner ministries to programs such as the Export Control and related Border Security Program and the Proliferation Security Initiative. Within U.S. formations, CA officers can brief commanders on host-nation enforcement gaps to align operational plans with real-world capacity.

LOE 3: Resilience and Denial. Counterproliferation is not just about catching smugglers and traffickers or interdicting shipments; it is about hardening systems so adversaries cannot exploit them in the first place. CA officers promote best practices for customs processes to reduce corruption, encourage governments to adopt international transparency agreements, advise on anticorruption legislation specific to trade, and connect governance reforms with nonproliferation and security cooperation. This long-term engagement denies proliferators the permissive environments they require and builds resiliency within trade systems.

LOE 4: Partner Engagement and Capacity Building. CA is uniquely suited for sustained engagement.  CA officers train customs officers to identify dual-use items, run tabletop exercises on sanctions enforcement, and facilitate multinational training alongside allies. Over time, these relationships help partners join frameworks like the Proliferation Security Initiative or implement Wassenaar best practices. Further, these relationships can facilitate additional bilateral exchanges of information needed to identify and target additional illicit networks.  Investing in local institutions builds enforcement capacity that persists long after U.S. deployments.

Case Studies (With Operational Vignettes)

Case 1: Russia’s Shadow Fleet. Following sanctions on Russian oil exports in 2022, Moscow assembled a fleet of hundreds of tankers operating under flags of convenience. Many ships disabled AIS tracking, used shell companies, or falsified documents, and enforcement varied widely by port and flag state.[xxiii] A CA officer deployed to a Baltic or Mediterranean port could conduct civil reconnaissance with port authorities, map local shipping companies and registries, and highlight enforcement gaps to NATO allies participating in maritime interdiction.[xxiv] This illustrates how CA officers with the 6E skill identifier bridge maritime security and civil enforcement.

Case 2: Chinese Money Laundering Organizations (CMLOs). CMLOs launder drug proceeds and purchase dual-use goods for proliferators, exploiting both formal and informal trade/finance systems.[xxv] A CA officer can engage financial regulators, map trade-finance links in free trade zones, and support Treasury/HSI (need to spell out HIS?) investigations by providing local civil reconnaissance and outreach to industry associations. This shows how trade and finance overlap in proliferation networks and why civil engagement is essential.

Case 3: North Korea’s Sanctions Evasion. North Korean entities use front companies, reflagged vessels, and ship-to-ship transfers to import fuel and export arms and dual-use components. Documentation is falsified, and company identities are constantly rotated.[xxvi] CA officers can strengthen customs enforcement in Southeast Asian partner states, design Proliferation Security Initiative exercises with local navies and customs officials and advise commanders on enforcement gaps that enable North Korean operations. This case shows how CA can reinforce sanctions pressure at the operational level.

Interagency and Multinational Integration

Counterproliferation is inherently interagency. The Office of Foreign Assets Control (OFAC) designates entities; BIS (Spell it out?) regulates dual-use exports; HSI and the FBI investigate trafficking networks; and the Department of Energy’s National Nuclear Security Administration provides technical expertise. Yet in many regions, these agencies lack a persistent forward presence. CA officers provide connective tissue. They can liaise between commanders, interagency partners, and host-nation institutions; host joint workshops with interagency trainers; and ensure local insights flow back into targeting pipelines (and again: they speak civilian and green suiters languages). Within the Joint Force, CA officers complement SOF CWMD missions by adding a civil-economic perspective. In NATO and European Union (EU) contexts, CA officers can link military exercises to partner civil enforcement and help translate EU dual-use regulations into day-to-day customs practice, making the exercises more realistic.

An Economic Common Operating Picture (ECOP) would institutionalize this role: a data-driven map of trade flows, sanctions enforcement, and civil vulnerabilities that commanders can use to synchronize operations with interagency actions.  CA officers are logical stewards of an ECOP because they combine civil reconnaissance, economic analysis, and partner or civil engagement.

Challenges and Recommendations

Despite their potential, several challenges limit CA contributions to counterproliferation:

1. Doctrinal gaps. Neither FM 3-57 nor ATP 3-57.80 explicitly assigns CA a counterproliferation role. Recommendation: update doctrine to codify counterproliferation tasks for CA officers, including trade network mapping and export-control advising.

2. Limited awareness. Many commanders are unfamiliar with CA capabilities or underutilize CA Officers. Recommendation: integrate CA counterproliferation modules into PME and division/corps staff training; incorporate CA injections into exercises.

3. Interagency integration. CA officers often lack direct access to OFAC, BIS, and HSI channels. Recommendation: establish exchange programs, create habitual liaisons, and embed CA officers in interagency task forces as well as the Export Enforcement Coordination Center.

4. Partner weakness. Corruption, weak governance, competing economic interests, and resource constraints undermine sanctions enforcement. Recommendation: integrate counterproliferation into broader governance and anticorruption initiatives and align with the Department of State and MCC (spell it out?) programs.

5. Resourcing. The CA community is small, and D1 billets are limited. Recommendation: expand force structure at CACOMs and Geographic Combatant Command headquarters; prioritize D1 for CA officers assigned to commands with counterproliferation-relevant missions.  Further, grant CA officers access to real-time commercial trade data and ship tracking resources.

Conclusion: Closing the Civil-Economic Seam

The contest of networks increasingly defines the global security environment. Proliferators exploit civil-economic systems, such as trade corridors, financial flows, and weak governance institutions, just as decisively as they exploit military or informational domains. Counterproliferation, therefore, is not solely about technical denial or intelligence targeting; it is fundamentally about disrupting the civil and economic pathways that sustain illicit programs. JP 3-40 and the DoD CWMD Strategy acknowledge these realities, while FM 3-57 recognizes CA support to CWMD (preparedness and securing dual-use materials). Yet FM 3-57 never uses the term “counterproliferation,” nor does it assign CA officers explicit roles in sanctions enforcement, export controls, or the denial of illicit procurement, leaving a doctrinal seam.

The Army faces a shortage of FA52s, Nuclear and Counterproliferation Officers. While essential, they are too few to cover every theater. CA officers, especially those with D1 ASI, provide a complementary capability: the ability to operate in the civil-economic space where proliferators thrive. By mapping supply chains, advising on sanctions enforcement, strengthening partner institutions, and linking civil reconnaissance to interagency enforcement, D1-qualified CA officers extend counterproliferation capacity to levels where proliferators exploit seams in globalization. Integrating CA into counterproliferation doctrine and operations will help eliminate the trade networks that proliferators have long exploited, ensuring that counterproliferation is contested not only at the strategic level, but at every echelon where the fight is waged.

The views and opinions expressed in this article are those of the authors and do not reflect any official policy or position of the U.S. Army, the Department of Defense, of any other U.S. government agency.

About the Authors

CPT Nathan Emery is a U.S. Army Civil Affairs officer serving as a 38G Military Government Specialist with the 6E (Commerce and Trade) skill identifier. He is currently assigned to the 353 Civil Affairs Command in New York, NY. His professional background includes more than two decades of experience in counterproliferation, sanctions enforcement, and trade-based financial investigations, with particular expertise in export controls and illicit procurement networks. CPT Emery is a doctoral candidate at Missouri State University and holds a Master of Arts from the National Defense University’s College of International Security Affairs. His research focuses on integrating civil-economic engagement into counterproliferation operations and addressing the enforcement gaps that proliferators exploit.

CPT Yevgeny Gershman is a U.S. Army Civil Affairs officer assigned to the 353rd Civil Affairs Command (CACOM) in New York, NY, where he serves as a 38G Military Government Specialist with the 6H (Law and Border Enforcement) skill identifier. His professional experience includes fifteen years of investigations against transnational criminal networks in counter-proliferation and export-control enforcement, focusing on illicit procurement and human trafficking networks, trade-finance vulnerabilities, and sanctions evasion schemes. CPT Gershman received his Master of Arts from John Jay College of Criminal Justice.

Works Cited

[i] U.S. Joint Chiefs of Staff, Joint Publication 3-40: Countering Weapons of Mass Destruction (Washington, DC: Joint Chiefs of Staff, November 2019).

[ii] U.S. Department of Justice, Justice Department Announces Five Cases Tied to Disruptive Technology Strikeforce, September 16, 2024, https://www.justice.gov/archives/opa/pr/justice-department-announces-five-cases-tied-disruptive-technology-strike-force

[iii] U.S. Joint Chiefs of Staff, Joint Publication 3-40: Countering Weapons of Mass Destruction (Washington, DC: Joint Chiefs of Staff, November 2019).

[iv] U.S. Department of Defense. 2022 Department of Defense Strategy for Countering Weapons of Mass Destruction. Washington, DC: OSD, 2022.

[v] U.S. Department of Defense, Strategy for Countering Weapons of Mass Destruction (Washington, DC: Department of Defense, September 28 2023).

[vi] Tobey, William H. Illicit Nuclear Trade and Black Markets. Cambridge, MA: Belfer Center, Harvard Kennedy School, 2019.

[vii] Department of the Army. ATP 3-57.80: Civil Affairs Operations. Washington, DC: Headquarters, Department of the Army, January 2022.

[viii] Department of the Army. FM 3-57: Civil Affairs Operations. Washington, DC: Headquarters, Department of the Army, July 2021.

[ix] Holshek, Christopher. “Civil Affairs in Strategic Competition.” Civil Affairs Association Journal, 2020.

[x] Headquarters, Department of the Army. Army Techniques Publication 3-57.30: Civil Network Development and Engagement. Washington, DC: Headquarters, Department of the Army, 06 February 2023.

[xi] U.S. Joint Chiefs of Staff, Joint Publication 3-40: Countering Weapons of Mass Destruction (Washington, DC: Joint Chiefs of Staff, November 2019).

[xii] Drezner, Daniel W. The Sanctions Paradox: Economic Statecraft and International Relations. Cambridge: Cambridge University Press, 1999.

[xiii] Zarate, Juan. Treasury’s War: The Unleashing of a New Era of Financial Warfare. New York: PublicAffairs, 2013.

[xiv] Stephen Watts, Jeffrey Martini, Jason H. Campbell, Mark Toukan, and Inhyok Kwon, Securing Gains in Fragile States: Using U.S. Leverage in Iraq, Afghanistan, and Beyond (Santa Monica, CA: RAND Corporation, 2021).

[xv] William A. Reinsch, “The Story of Sanctions,” Center for Strategic and International Studies, March 17 2025.

[xvi] Ayushman Mukherjee, Sanctions Evasion in the Russo-Ukrainian War: Challenges, Case Studies, and Policy Recommendations for the U.S. and EU, YIP Policy Journal, August 2025.

[xvii] U.S. Department of the Treasury. Sanctions Programs and Country Information. Washington, DC: Treasury, 2023.

[xviii] U.S. Department of Commerce, Bureau of Industry and Security. Annual Report to Congress. Washington, DC: BIS, 2022.

[xix] Fred J. Burpo and Stephen G. Hummel, “West Point Department of Chemistry and Life Science — Nexus of Army Chemical and Biological Intellectual Capital,” Countering Weapons of Mass Destruction Journal, no. 16 (Winter 2018): 34–45, accessed 24 OCT 2025, https://athena.westpoint.edu/bitstreams/87b3bc20-d510-411e-9691-af1811c9299d/download

[xx] Immigration and Customs Enforcement.  New York Resident, Canadian National Plead Guilty to Multimillion-Dollar Export Control Scheme.  July 11, 2024. https://www.ice.gov/news/releases/new-york-resident-canadian-national-plead-guilty-multimillion-dollar-export-control

[xxi] U.S. Department of Defense, Strategy for Countering Weapons of Mass Destruction (Washington, DC: Department of Defense, September 28 2023).

[xxii] U.S. Army Nuclear and Countering Weapons of Mass Destruction Agency, “(CWMD) Advisor Course,” accessed October 24, 2025, https://www.usanca.army.mil/Our-Courses/-CWMD-Advisor-Course/

[xxiii] Nathan Emery and Mariya Golotyuk, “Echo Newsletter Q3 2024,” Export Enforcement Coordination Center, U.S. Immigration and Customs Enforcement, accessed October 24, 2025, https://www.ice.gov/doclib/e2c2/echoNewsletter_2024_q3.pdf

[xxiv] NATO. Civil Emergency Planning Committee, Final Report on Crisis Management Exercise (CMX) 2022. Brussels: NATO Headquarters, 2022.

[xxv] Brian Nelson, “Chinese Money Laundering Organizations (CMLOs): Cleaning Cartel Cash,” written testimony of the Under Secretary for Terrorism and Financial Intelligence, U.S. Department of the Treasury, before the Senate Caucus on International Narcotics Control, 118th Cong., 2nd sess., April 30 2024.

[xxvi] Anthony Ruggiero, “Charged with Using Front Companies to Evade U.S. Sanctions Targeting North Korea’s Nuclear Weapons and Ballistic Missile Programs,” testimony before the U.S.-China Economic and Security Review Commission, February 20 2025.