Category Archives: China

Refugee, Spy, Hacker, Thief Problems with China?

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Not just in the United States, but add Canada as well. Seems there could be many moving parts to this and many questions. Apparently this is a big enough issue that Barack Obama dispatched one of his pesky sternly worded letters to China.

Operation Fox Hunt

Obama Administration Warns Beijing About Covert Agents Operating in U.S.

NYT: WASHINGTON — The Obama administration has delivered a warning to Beijing about the presence of Chinese government agents operating secretly in the United States to pressure prominent expatriates — some wanted in China on charges of corruption — to return home immediately, according to American officials.

The American officials said that Chinese law enforcement agents covertly in this country are part of Beijing’s global campaign to hunt down and repatriate Chinese fugitives living abroad and, in some cases, recover allegedly ill-gotten gains. The Chinese government has officially named the effort Operation Fox Hunt.

The American warning, which was delivered to Chinese officials in recent weeks and demanded a halt to the activities, reflects escalating anger in Washington about intimidation tactics used by the agents. And it comes at a time of growing tension between Washington and Beijing on a number of issues: from the computer theft of millions of government personnel files that American officials suspect was directed by China, to China’s crackdown on civil liberties, to the devaluation of its currency.

Those tensions are expected to complicate the state visit to Washington next month by Xi Jinping, the Chinese president.

The work of the agents is a departure from the routine practice of secret government intelligence gathering that the United States and China have carried out on each other’s soil for decades. The Central Intelligence Agency has a cadre of spies in China, just as China has long deployed its own intelligence operatives into the United States to steal American political, economic, military and industrial secrets.

In this case, American officials said, the Chinese agents are undercover operatives with the Ministry of Public Security, China’s law enforcement branch charged with carrying out Operation Fox Hunt.

The campaign, a central element of Mr. Xi’s wider battle against corruption, has proved popular with the Chinese public. Since 2014, according to the Ministry of Public Security, more than 930 suspects have been repatriated, including more than 70 who have returned this year voluntarily, the ministry’s website reported in June. According to Chinese media accounts, teams of agents have been dispatched around the globe.

American officials said they had solid evidence that the Chinese agents — who are not in the United States on acknowledged government business, and most likely are entering on tourist or trade visas — use various strong-arm tactics to get fugitives to return. The harassment, which has included threats against family members in China, has intensified in recent months, officials said.

The United States has its own history of sending operatives undercover to other nations — sometimes under orders to kidnap or kill. In the years after the Sept. 11 terrorist attacks, the C.I.A. dispatched teams abroad to snatch Qaeda suspects and spirit them either to secret C.I.A prisons or hand them over to other governments for interrogation.

POTUS Far From Lame Duck, Progressive ‘To-Do’ Items

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The arrogance of Barack Obama continues. Just a week ago, he declared he could win a third term if he ran again.

“I actually think I’m a pretty good President. I think if I ran, I could win. But I can’t,” Obama ad-libbed during a speech in Ethiopia. “There’s a lot that I’d like to do to keep America moving. But the law is the law, and no person is above the law, not even the president.”

So imagine how blindsided America is about to be from now until January 2017. What more is planned? Normalizing relations with Bashir al Assad? Normalizing relations with North Korea? Suspending Border Patrol operations completely? Federalizing all national banks? Imposing more agency regulations on Americans and business? Making all interstate roads toll roads?

Lack of imagination now could prevent you from being prepared. Consider other countries that don’t impose government tyrannical policies and have a better competing edge. Cutting military personnel to roving 4 day work weeks? Replacing Ruth Bader Gingsberg on the Supreme Court with Cass Sunstein? Bailing out the City of Chicago to the tune of $7 billion?

Let us start with what is coming almost immediately.

Obama’s big climate rule ready for Monday launch

Politico: Supporters say they plan to be at the White House for the announcement of an EPA rule that will take on power plants’ pollution.

President Barack Obama is poised to push ahead with the nation’s most ambitious environmental regulation in decades — a crackdown on power plants’ greenhouse gas emissions that the administration hopes will put the U.S. in striking distance of achieving a global agreement to combat climate change.

Environmentalists supporting the rule say they plan to be at the White House for a Monday afternoon announcement that they hope will feature the president himself, as part of what’s shaping up to be a major sales pitch both within and outside the administration. Allies including Virginia environmental groups, elected officials and green-minded business groups have also scheduled media calls for 3 p.m. Monday to react to the news.

The White House has not confirmed the timing of the announcement.

The regulation is expected to ease up on a few of the most controversial provisions that the Environmental Protection Agency included in its draft proposals in the past two years. But it will still set up a years-long legal and political battle with congressional Republicans and other opponents, who call it the major weapon in Obama’s “War on Coal,” and it promises to become a major point of contention for the 2016 presidential race.

The regulation also puts a capstone on Obama’s efforts to secure a legacy as the president who made a serious assault on global warming, without waiting for action from Congress — though he will have to depend on his successors to carry it through. States will also play a big role, with six governors so far indicating they won’t comply with EPA’s mandates.

Environmentalists, who have been pressing for Obama to announce the rule personally, call it a crucial first step in cutting the pollution that scientists blame for boosting the Earth’s temperatures and lifting sea levels. But they say far steeper cuts will still be needed if the world is to avoid the worst effects of climate change.

“This is a huge part of the president’s commitment to reducing greenhouse gases,” said Carol Browner, Obama’s first-term climate czar, who left the White House several months after the administration’s attempt at comprehensive climate legislation failed in 2010. “He has viewed the issue of climate change as something he has responsibility for under the law — the moral and ethical responsibility domestically, but also globally.”

Opponents vow that the rule will not stand. “We believe it’s legally deficient on a number of fronts and believe it’s going to have a terrible impact on citizens across the country,” said West Virginia Attorney General Patrick Morrisey, one of several plaintiffs who won a Supreme Court victory this summer over an EPA mercury rule.

Future legal challenges against the climate rule are also likely to end up in front of the Supreme Court.

The broad strokes of the rule are expected to match the drafts that EPA has issued over the past two years: By 2030, existing power plants will have to put out an average of 30 percent less carbon dioxide than they did in 2005 — a goal the U.S. is about halfway to meeting. And the rule effectively bars the construction of new coal-fired power plants, the biggest source of carbon pollution in the U.S.

Together, the requirements would change the way the U.S. produces and uses electricity, continuing an ongoing wave of coal-plant shutdowns while offering legs up to natural gas, solar, wind and maybe nuclear.

For people closely following the rule, the major questions concern how much the final rule will differ from what EPA originally proposed in September 2013 and last June. Sources have said EPA will roll back an interim pollution-cutting deadline that states and power companies attacked as unworkable, to 2022 from 2020. The agency is also expected to abandon its proposal to require future coal-burning plants to capture and store their carbon pollution, an expensive mandate that opponents said would be vulnerable in court because it violates a 2005 energy law.

States are also expected to get an extra year to submit their compliance plans to EPA — 2018 instead of 2017.

Other potential changes could include making it easier for nuclear power plants and their carbon-free emissions to count toward meeting states’ cleanup targets, changing the way that energy-efficiency initiatives are included in calculating states’ reduction goals, and altering the way that EPA’s formulas treat green energy that is produced in one state but sold in another.

And EPA could tweak the complicated formulas that set widely varying cleanup targets for each state, which in last year’s draft ranged from cuts of 11 percent for North Dakota to 72 percent for Washington state. The raw numbers don’t necessarily reflect the degree of difficulty: Washington, for instance, could meet most of its goal by closing one coal plant that’s already scheduled for retirement, EPA has said.

The costs of the rule will be big — but so will the benefits, the administration contends. Last summer, EPA estimated that the portion dealing with existing power plants would bring $55 billion to $93 billion in economic benefits, compared with $7.3 billion to $8.8 billion in costs to the economy.

But EPA’s critics note that the rule comes amid troubling financial times for the coal industry, and might even arrive on the same day that a major coal producer — Virginia-based Alpha Natural Resources — is expected to file for bankruptcy protection. That follows several other high-profile coal company bankruptcy filings.

Environmental regulations like the carbon rule and a forthcoming Interior Department rule meant to protect Appalachian streams are only part of the reason coal has dropped from nearly 50 percent of the nation’s electricity in 2005 to 39 percent last year. Inexpensive natural gas, which burns more cleanly than coal does, has taken a greater share of the market. And in some regions, coal deposits are becoming increasingly more difficult and less economical to mine.

Meanwhile, Obama’s earlier attempts to tackle climate change have struggled too. The House passed a cap-and-trade bill in 2009, but it died in the Senate the following year despite the Democrats holding a large majority. The president also stumbled with an anticlimactic 2009 climate summit in Copenhagen, Denmark. But he revived climate change as a theme late in his 2012 reelection campaign, declaring that “climate change is not a hoax,” and in his second inaugural address, in which he said failing to take on the threat “would betray our children and future generations.”

The credibility of those promises will be at stake in December, when negotiators the U.S. and other nations gather in Paris to try to reach a global climate agreement.

The final rule is also timed for maximum momentum to take advantage of the final year and a half of Obama’s time in office. Litigation over the rule is likely to last through this decade and potentially into the 2020s, making the winner of the 2016 presidential race a key figure in Obama’s climate legacy.

While it remains unclear just how far a Republican president could roll back the regulation, all sides agree a GOP White House would spell significant trouble for the carbon rule. The GOP field of 2016 candidates opposes the rule: Wisconsin Gov. Scott Walker said it is “unworkable,” while former Florida Gov. Jeb Bush has called it “irresponsible and ineffective.”

Meanwhile, Democratic front-runner Hillary Clinton has pledged to protect the rule, while it garnered praise from rival Martin O’Malley and Bernie Sanders has called for even further climate action.

 

 

Every U.S. Corporation Hacked by China

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From the Former NSA Director McConnell via CNN:

“The Chinese have penetrated every major corporation of any consequence in the United States and taken information,” he said. “We’ve never, ever not found Chinese malware.”
He said the malware lets Chinese spies extract information whenever they want. McConnell, who also led the NSA from 1992 until 1996, continues to investigate hacks as a high-ranking adviser to Booz Allen Hamilton (BAH).
He listed victims he has come across during his investigations: U.S. Congress, Department of Defense, State Department (which is currently dealing with Russian hackers) and major corporations.
The U.S. government has said it has caught Chinese spies stealing blueprints and business plans. Last year, federal prosecutors took the unprecedented step of filing formal criminal charges against five Chinese government spies for breaking into Alcoa (AA), U.S. Steel Corp. (X), Westinghouse and others.

Exclusive: Secret NSA Map Shows China Cyber Attacks on U.S. Targets

A secret NSA map obtained exclusively by NBC News shows the Chinese government‘s massive cyber assault on all sectors of the U.S economy, including major firms like Google and Lockheed Martin, as well as the U.S. government and military.

The map uses red dots to mark more than 600 corporate, private or government “Victims of Chinese Cyber Espionage” that were attacked over a five-year period, with clusters in America’s industrial centers. The entire Northeast Corridor from Washington to Boston is blanketed in red, as is California’s Silicon Valley, with other concentrations in Dallas, Miami, Chicago, Seattle, L.A. and Detroit. The highest number of attacks was in California, which had almost 50.

Each dot represents a successful Chinese attempt to steal corporate and military secrets and data about America’s critical infrastructure, particularly the electrical power and telecommunications and internet backbone. And the prizes that China pilfered during its “intrusions” included everything from specifications for hybrid cars to formulas for pharmaceutical products to details about U.S. military and civilian air traffic control systems, according to intelligence sources.

The map was part of an NSA briefing prepared by the NSA Threat Operations Center (NTOC) in February 2014, an intelligence source told NBC News. The briefing highlighted China’s interest in Google and defense contractors like Lockheed Martin, and in air traffic control systems. It catalogued the documents and data Chinese government hackers have “exfiltrated” — stolen — from U.S. corporate, government and military networks, and also listed the number and origin of China’s “exploitations and attacks.”

The map suggests that NSA has been able to monitor and assess the Chinese cyber espionage operations, and knows which specific companies, government agencies and computer networks are being targeted.

The NSA did not immediately respond to repeated requests for comment.

 

 

The China Hack of United Airlines, Electronic Insurgency

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Warning corporations, industry and government entities is one thing, action and protection and or declaration of a cyber war is yet another.

July 2015:

Aspen Institute: Cyber warfare is one of the most potent security threats the United States faces, National Security Agency Director and Commander of the US Cyber Command General Keith Alexander told the crowd at the Aspen Security Forum in Aspen, discussing in conversation with NBC News Correspondent Pete Williams the nature of the threat and how his department is working to address it.
With the Stuxnet, Duqu, and Flame viruses in the fore of the public consciousness, Alexander took pains to point out that nation-states were not the only potential cyber actors. Citing power and water grids as his chief concerns, he said, “Somebody who finds vulnerability in our infrastructure could cause tremendous problems. They could erase the Input/output of a system so it can’t boot, and would have to be replaced. And these capabilities are not only nation-state-only capabilities.”

Alexander assessed the US’ readiness to confront such an attack as a three on a scale of ten, calling lack of adequately trained cyber defense forces the critical impediment to greater preparedness. “Our issue isn’t [having the tools] to address the threat,” he said. “It’s having the capacity, and building and training cyber forces. We have a big requirement, and a small force that is growing steadily.”

China-Tied Hackers That Hit U.S. Said to Breach United Airlines

Bloomberg:

The hackers who stole data on tens of millions of U.S. insurance holders and government employees in recent months breached another big target at around the same time — United Airlines.

United, the world’s second-largest airline, detected an incursion into its computer systems in May or early June, said several people familiar with the probe. According to three of these people, investigators working with the carrier have linked the attack to a group of China-backed hackers they say are behind several other large heists — including the theft of security-clearance records from the U.S. Office of Personnel Management and medical data from health insurer Anthem Inc.

The previously unreported United breach raises the possibility that the hackers now have data on the movements of millions of Americans, adding airlines to a growing list of strategic U.S. industries and institutions that have been compromised. Among the cache of data stolen from United are manifests — which include information on flights’ passengers, origins and destinations — according to one person familiar with the carrier’s investigation.

 

It’s increasingly clear, security experts say, that China’s intelligence apparatus is amassing a vast database. Files stolen from the federal personnel office by this one China-based group could allow the hackers to identify Americans who work in defense and intelligence, including those on the payrolls of contractors. U.S. officials believe the group has links to the Chinese government, people familiar with the matter have said.

That data could be cross-referenced with stolen medical and financial records, revealing possible avenues for blackmailing or recruiting people who have security clearances. In all, the China-backed team has hacked at least 10 companies and organizations, which include other travel providers and health insurers, says security firm FireEye Inc.

Tracking Travelers

The theft of airline records potentially offers another layer of information that would allow China to chart the travel patterns of specific government or military officials.

United is one of the biggest contractors with the U.S. government among the airlines, making it a rich depository of data on the travel of American officials, military personnel and contractors. The hackers could match international flights by Chinese officials or industrialists with trips taken by U.S. personnel to the same cities at the same time, said James Lewis, a senior fellow in cybersecurity at the Center for Strategic and International Studies in Washington.

“You’re suspicious of some guy; you happen to notice that he flew to Papua New Guinea on June 23 and now you can see that the Americans have flown there on June 22 or 23,” Lewis said. “If you’re China, you’re looking for those things that will give you a better picture of what the other side is up to.”

Computer Glitches

The timing of the United breach also raises questions about whether it’s linked to computer faults that stranded thousands of the airline’s passengers in two incidents over the past couple of months. Two additional people close to the probe, who like the others asked not to be identified when discussing the investigation, say the carrier has found no connection between the hack and a July 8 systems failure that halted flights for two hours. They didn’t rule out a possible, tangential connection to an outage on June 2.

Luke Punzenberger, a spokesman for Chicago-based United, a unit of United Continental Holdings Inc., declined to comment on the breach investigation.

Zhu Haiquan, a spokesman for the Chinese embassy in Washington, said in a statement: “The Chinese government and the personnel in its institutions never engage in any form of cyberattack. We firmly oppose and combat any forms of cyberattacks.”

Embedded Names

United may have gotten help identifying the breach from U.S. investigators working on the OPM hack. The China-backed hackers that cybersecurity experts have linked to that attack have embedded the name of targets in web domains, phishing e-mails and other attack infrastructure, according to one of the people familiar with the investigation.

In May, the OPM investigators began drawing up a list of possible victims in the private sector and provided the companies with digital signatures that would indicate their systems had been breached. United Airlines was on that list.

Safety Concerns

In contrast to the theft of health records or financial data, the breach of airlines raises concerns of schedule disruptions or transportation gridlock. Mistakes by hackers or defenders could bring down sensitive systems that control the movement of millions of passengers annually in the U.S. and internationally.

Even if their main goal was data theft, state-sponsored hackers might seek to preserve access to airline computers for later use in more disruptive attacks, according to security experts. One of the chief tasks of the investigators in the United breach is ensuring that the hackers have no hidden backdoors that could be used to re-enter the carrier’s computer systems later, one of the people familiar with the probe said.

United spokesman Punzenberger said the company remains “vigilant in protecting against unauthorized access” and is focused on protecting its customers’ personal information.

There is evidence the hackers were in the carrier’s network for months. One web domain apparently set up for the attack — UNITED-AIRLINES.NET — was established in April 2014. The domain was registered by a James Rhodes, who provided an address in American Samoa.

James Rhodes is also the alias of the character War Machine in Marvel Comics’ Iron Man. Security companies tracking the OPM hackers say they often use Marvel comic book references as a way to “sign” their attack.

Targeting Pentagon

This isn’t the first time such an attack has been documented. Chinese military hackers have repeatedly targeted the U.S. Transportation Command, the Pentagon agency that coordinates defense logistics and travel.

A report last year from the Senate Armed Services Committee documented at least 50 successful hacks of the command’s contractors from June 2012 through May 2013. Hacks against the agency’s contractors have led to the theft of flight plans, shipping routes and other data from organizations working with the military, according to the report.

“The Chinese have been trying to get flight information from the government; now it looks as if they’re trying to do the same in the commercial sector,” said Tony Lawrence, a former Army sergeant and founder and chief executive officer of VOR Technology, a Columbia, Maryland-based cybersecurity firm.

It’s unclear whether United is considering notifying customers that data may have been compromised. Punzenberger said United “would abide by notification requirements if a situation warranted” it.

The airline is still trying to determine exactly which data was removed from the network, said two of the people familiar with the probe. That assessment took months in the OPM case, which was discovered in April and made public in June.

M&A Strategy

Besides passenger lists and other flight-related data, the hackers may also have taken information related to United’s mergers and acquisitions strategy, one of the people familiar with the investigation said.

Flight manifests usually contain the names and birthdates of passengers, but even if those files were taken, experts say that would be unlikely to trigger disclosure requirements in any of the 47 states with breach-notification laws.

Those disclosure laws are widely seen as outdated. The theft by hackers of corporate secrets usually goes unreported, while the stealing of customer records such as Social Security numbers and credit cards is required in most states.

“In most states, this is not going to trigger a notification,” said Srini Subramanian, state government leader for Deloitte cyber risk services.

Iran Deal Described but Does it Match Iran’s Interpretation?

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Below is a rather simple explanation of the Iran Deal, known as the JPOA. The details Kerry and Moniz along with the other members of the P5+1 demonstrates some real convoluted trigger points with regard to sanctions and inspections. However, of real importance is whether Iran’s own interpretation of the deal matches that on paper as the West works to sell it.

What is most chilling however, is that Ali Khamenei has pledged continued financial support for the Palestinians, Houthis, Assad’s regime and Hezbollah with his army the Quds Force.

THIS WILL TAKE LAWYERS, A TRUCK LOAD OF THEM TO UNWIND THE TEXT

Frankly, Congress ‘gets-it’ and they know full well Iran will cheat merely on the notion of translations and expectations.

TEHRAN (FNA)- Iranian President Hassan Rouhani blasted the US officials’ recent statements against Tehran after the country and the world powers reached a nuclear agreement in Vienna on July 14, calling on them to give up the bad habit of threatening Iran.
President Rouhani’s remarks came after US State Secretary John Kerry threatened to use military action against Tehran if it failed to respect a historic nuclear deal sealed on 14 July.

“The US should know that it has no other option but respecting Iran and showing modesty towards the country and saying the right thing,” President Rouhani said, addressing a large crowd of people in the Western city of Sanandaj on Sunday.

The Iranian president pointed to the Americans’ catch phrase “all options are on the table” used by the US officials, and called on “the US officials and statesmen to decide to make changes in their political room; the table they are talking about has broken legs.”

Details of the Iran deal on paper is likely not a reality for the Iran side of the table.

What the Iran deal means for blacklisted entities

Analysis from the Bulletin of Atomic Scientists

Editor’s note: The above graphic provides a general overview of timelines for de-listing across various sanctions regimes. National authorities should be consulted for authoritative advice. ** Khatam al-Anbiya, a Revolutionary Guards-controlled construction conglomerate, and its subsidiaries. *** Farayand Technique, Kalaye Electric Company and Pars Trash, all involved in Iran’s centrifuge programme. **** Excludes Malek Ashtar, a military-run university, and the Revolutionary Guards-owned Imam Hossein University and Baghyatollah Medical Sciences University.

Over the past decade, a global patchwork of legal measures has been sewn together by various national authorities with the aim of constraining Iran’s nuclear program. This patchwork makes up the global sanctions regime that Iran has fought so hard to end.

Having been stitched together by dozens of governments, as well as the United Nations and European Union—and with only the loosest of plans to guide it—it’s a patchwork with plenty of knots. Now, with the agreement of the Iranian nuclear deal, known as the Joint Comprehensive Plan of Action, we have been shown the plan the international community will use to try to untangle it.

At face value, the outline of the sanctions relief that the deal proposes is simple. Most sanctions against Iran will be lifted in exchange for Iran capping its nuclear progress and accepting additional verification measures. The UN Security Council will revoke all of its previous resolutions against Iran. The European Union (EU) will reduce most of its sanctions against Iran, over time. The United States will remove many of its. The free flow of everything from oil to gold to Iranian nuclear physics students will eventually be permitted, with some caveats.

But sanctions relief is easier said than done. It’s already hard to understand the intricacies of the major sanctions regimes that are in force across the globe, and the interplay between them—that’s why an entire industry of sanctions consultants and lawyers has appeared over the last decade, who promise to help governments and businesses navigate these treacherous legal waters.

The 159-page nuclear deal agreed to in Vienna will keep these lawyers in business a while yet. It contains more than 100 paragraphs detailing the type of sanctions relief that Iran will get, and another 20 or so paragraphs on when the various stages of sanctions relief will take effect. Read the agreement and you’ll find a tortuous interplay between these provisions that proves that while the agreement was conceived by diplomats and delivered by physicists, it was clearly vaccinated by lawyers, with some painful results.

This complexity has already led to minor scuffles breaking out: the United States has had to defend the deal on the grounds that some thought that Qasem Soleimani, the notorious Iranian general who leads the elite Qods Forces of the country’s Islamic Revolutionary Guard Corps, would be dropped from sanctions. (Soleimani is accused of helping to kill Americans in covert operations in Iraq.) Administration officials have been at pains to state that Soleimani will remain subject to a UN-mandated asset freeze for the next eight years, and that US Treasury and State Department sanctions on Soleimani won’t be removed.

The debate over Soleimani’s removal from different sanctions lists illuminates a broader point that is worth noting—the lack of consistency between the lists, maintained by various authorities, that record and punish those people and companies who have been involved in Iran’s proliferation activities. Analysts call these listings “designations.” People and companies are designated by the United Nations or other authorities as being guilty of having assisted in Iranian proliferation—and in turn, national authorities are expected to freeze their assets and deny them visas.

You might expect that these designation lists are all the same—but that’s by no means the case. The three major sanctions regimes against Iran’s nuclear and missile programs—those of the United Nations, United States, and the European Union—are frustratingly disjointed in this respect. The UN Security Council has designated about 40 people and 75 companies on grounds relating to Iranian proliferation. The EU has sanctioned almost 500 companies and more than 100 people, and designated many entities that the United Nations has not. The United States has designated hundreds of Iranian entities using several different legal rationales, making it a Sisyphean task to try to tally them all. Many US-listed entities match up with those sanctioned by the United Nations and the EU, but others have only been sanctioned by the United States. These inconsistencies are at the root of the nuclear deal’s somewhat convoluted provisions regarding sanctions relief.

The de-listing process explained. According to the terms of the deal and a Security Council resolution that accompanies it, designations will be rescinded in two stages.

On what is known as “Implementation Day,” when the International Atomic Energy Agency (IAEA) certifies that Iran has made certain promised modifications to its nuclear infrastructure, the United Nations will drop sanctions against the people and companies who have been designated in old Security Council resolutions on Iran—but under the terms of the new Security Council resolution, entities from Iran’s military and missile-development sectors will continue to be subjected to a UN-mandated asset freeze. Concurrently, the United States will de-list many of the Iranian entities on the Treasury and State Departments’ sanctions lists, although it will continue to prohibit Americans from doing business with most of them. And the EU will remove most of its designations, with the exception of those entities that the EU has judged to be core to Iran’s proliferation activities.

Eight years after the milestone of Implementation Day, or whenever the IAEA confirms that there is no undeclared nuclear material in Iran, “Transition Day” occurs. The United States will allow its citizens to conduct trade with previously-designated entities and will de-list an additional 43 entities (mostly people historically involved in covert procurement or nuclear weapons-related research); the UN’s asset freeze of the remaining designated entities will be terminated; and the EU will de-list the Iranian proliferators who didn’t gain relief on Implementation Day.

Importantly, other designations on Iran put in place by the EU and United States, unrelated to the nuclear issue, won’t be part of this process. President Obama has been at pains to stress that sanctions relating to Iran’s support for terrorism and for human rights violations will remain—this includes restrictions on dozens of Iranian entities, including Qasem Soleimani. Soleimani will also stay designated by the EU for his support to terrorism, along with nearly 90 other Iranians that the EU has accused of involvement in terrorism or human rights abuses.

For each sector of Iran’s economy and society that has previously been subjected to designations, there will be winners and losers in the de-listing process. Overall, the deal has clearly been designed to give early relief to Iran’s civilian industries and banks, while delaying or avoiding giving relief to the Revolutionary Guards and military. Here’s how it will function, sector by sector.

The shipping industry. Hundreds of Iranian shipping companies will be removed from what is effectively an EU and United States blacklist of the Iranian shipping industry. But those overseeing the sanctions process have tried to avoid giving the Good Housekeeping Seal of Approval to shipping entities that were involved in transferring arms to the Lebanese Shi’a group Hezbollah or are under the thumb of the Islamic Revolutionary Guards, so a few shipping firms will remain designated. And because the United States wants to stagger the relief it provides Iran’s valuable oil industry, it will retain restrictions on Iran’s oil tanker fleet for longer than anyone else.

Civil aviation. Iran’s civil aviation sector has never been subject to as many designation measures as the shipping industry, which the UN Security Council had singled out as a particularly important channel for Iranian proliferation. So few Iranian airlines were ever designated by authorities outside the United States—and few will need to be de-listed. Certain carriers reportedly involved in weapons-smuggling to Syria and Hezbollah on behalf of the Revolutionary Guards and their Qods Force will remain subject to restrictions.

The oil and gas sector. Iran’s oil and gas sector is bound for substantial sanctions relief under the terms of the deal. Hundreds of US-designated oil and gas companies will be removed from the US Treasury’s Specially-Designated Nationals (SDN) list, although this de-listing is conditional: US persons and companies will still be prohibited from dealing with these firms. A small number of Revolutionary Guard-linked entities involved in the oil and gas sector will remain subject to certain designations.

Banks. Iran’s banks have faced some of the severest consequences from being designated under various sanctions regimes—particularly those enforced by the US Treasury, which have effectively cut off Iranian banks from the global financial system. While the United States will remove several Iranian banks from its designated list on Implementation Day, nearly all of them will remain off-limits to US persons and companies. The EU, by comparison, will de-list without any caveats most of those Iranian banks it previously sanctioned—including several banks like Bank Mellat, with whom the EU Council has fought long-running legal battles. A few banks with particularly strong ties to Iran’s proliferation activities or the Revolutionary Guards, such as Bank Sepah, will remain blacklisted for longer.

Iran’s civil nuclear agency. The deal will see the de-listing on Implementation Day of the Atomic Energy Organization of Iran (AEOI), Iran’s civil nuclear authority, which operates the controversial facilities at Natanz, Fordow and Arak. In a turn of events that would have been unforeseeable just a few years ago, Americans and American companies will be permitted to do business with the AEOI, re-opening trade channels that have been largely shut since the time of the Shah. (A couple of AEOI front companies that have caused particular consternation to the IAEA in the past will remain subject to UN-mandated asset freezes and EU sanctions until Transition Day).

Universities. Iran’s universities have largely escaped the perils of being blacklisted, despite being critical to Iran’s nuclear and missile development. On Transition Day, the EU will de-list two universities, Shahid Beheshti and Sharif University of Technology, which have reportedly been involved in nuclear weapon-related research and centrifuge-related research respectively. The military-run Malek Ashtar University will be de‑listed by the United Nations, but will remain subject to an UN-mandated asset freeze, and the United States will continue to blacklist a couple of the Revolutionary Guards’ military colleges.

Military, missile entities and the Islamic Revolutionary Guard Corps. The de-listing process has clearly been designed to avoid delivering relief for as long as possible to Iran’s military and the Revolutionary Guards. Entities and personnel operating under their auspices who have previously been the subject to sanctions—including military commanders, major arms manufacturers, research and development organizations, and ballistic missile producers—will gain the least and latest sanctions relief of all the designated Iranian entities. All will need to wait until Transition Day or later before being de-listed.

Procurers and proliferators. A number of people and companies who have been busted for supplying goods to Iran’s nuclear and missile programs will also have to wait until Transition Day to be de-listed. These include Iranian firms that reportedly supplied electronic equipment to the Natanz centrifuge facility, and individual smugglers such as Hossein Tanideh, who sold specialized valves to Iran’s heavy water program until he was arrested by German police. A handful of procurement agents whom the United States has designated for supplying Iran’s UN‑prohibited programs will remain on the US-designated list, perhaps indefinitely.

Some of the deal’s few obvious mistakes—most likely slip-ups made during the late nights of the negotiation process—can be found in its treatment of a couple of well-known proliferators. Parviz Khaki, an alleged procurer for Iran’s nuclear program who died last July, will not be de-listed until the IAEA gives Iran a clean bill of health, perhaps in a decade’s time. Gerhard Wisser, a German who helped Pakistani nuclear proliferator Abdul Qadeer Khan sell centrifuge technology to Libya but had nothing to do with Iran, will have to wait until then as well before being de-listed.

Looking forward. Complicated as this process will be, it’s only a small element of the overall sanctions relief plan. Sanctions measures restricting trade with various parts of Iran’s economy—such as restrictions on the export of oil, or provision of services to the oil and gas sector—will be relaxed according to other complicated sequencing laid out in the deal’s text. And there are unresolved questions as to how countries outside the EU and the United States will choose to implement sanctions relief measures: Will Canada, for example, which has made its skepticism about the nuclear deal clear, de-list the 600 or so Iranian entities that it has put its own voluntary sanctions on?

These questions will be answered in time. It’s quite possible that there will never be another sanctions regime as broad and far-reaching as the one that is about to be dismantled. Critics of the Iran nuclear deal will mourn its loss, and howl at perceived missteps in the process, such as the storm in a teacup over Qasem Soleimani. Yet the negotiators have done remarkably well in designing in under two weeks a mechanism that looks like it could successfully dismantle 10 years’ worth of aggregated complexity.