REPORT OF THE EXPERTS TEAM
VISIT TO UKRAINE
October 13 - 20, 2002

This report was produced jointly under the aegis of the Government of the United States of America and Her Britannic Majesty's Government
US and UK Government Copyright, 2002

US STATE DEPARTMENT

November 26, 2002

I. Executive Summary

A joint US-UK experts team visited Ukraine October 13-20, 2002 at the invitation of the Ukrainian government. This fact-finding mission was prompted by the recent authentication by the U.S. Federal Bureau of Investigation of a recording of a conversation on July 10, 2000 involving Ukrainian President Kuchma. In the conversation, President Kuchma approved the proposal of Valeriy Malev, the General Director of the Ukrspetsexport state arms sales firm, to covertly transfer a Kolchuga passive detection system to Iraq via a third party (a Jordanian middleman).

The team's main goals were to:

· determine whether a Kolchuga passive detection system was transferred to Iraq either directly or through a third party;

· determine the technical capabilities of Kolchuga and the level of threat it could pose to US and UK forces;

· inquire about the chain of events leading up to and following a conversation on July 10, 2000 between President Kuchma and Malev; and,

· assess the Ukrainian arms export control system.

Level of Cooperation and Transparency

The extent of Ukrainian cooperation and transparency was mixed. The Ministry of Defense and Ministry of Foreign Affairs were very helpful to the team of experts.

The team was allowed to meet with many, but not all of the individuals requested. The Ukrainian side told the team that Leonid Derkach, former head of the Security Service of Ukraine (SBU), and Yuri Orshanskyy, former Honorary Consul to Iraq were unavailable because they were travelling abroad during the time of the team's visit.

Frequently Ukrainian officials refused point blank to answer specific questions central to the team's work, especially when questions touched on the role of senior Ukrainian figures. The team also encountered evasive responses by Ukrainian government officials to straightforward questions on the possible transfer of Kolchuga to or through third parties.

Many documents requested were made available to the inspection team, though with varying degrees of reluctance. Following specific requests from the team leader, the Presidential Administration approved access to additional documents, but some of the most crucial documents were still withheld. For example, Ukrainian officials were unwilling to provide requested documentation on the sale of four Kolchuga stations to the People's Republic of China (PRC).

On October 19, the team was told that pending documents would be declassified and provided in the coming days. The team is still awaiting those documents.

Findings

The main finding of this fact-finding mission is that the Government of Ukraine (GOU) failed to provide the team with satisfactory evidence that the transfer of a Kolchuga to Iraq could not or did not take place. As a result, the issue of the transfer must remain open.

The GOU provided information that confirmed that the meeting between President Kuchma and Valeriy Malev occurred. The avenues of investigation were limited relating to the chain of events leading up to and following President Kuchma's July 10, 2000 approval of the sale and transfer of the Kolchuga system to Iraq.

Given the team's necessary reliance on production figures provided by Ukraine and the lack of full cooperation and transparency overall, particularly on third party transfer issues, the question of whether Ukraine transferred or is transferring Kolchugas to Iraq, through a third country must remain open.

It is assessed that Kolchuga has not been directly transferred to Iraq under openly declared contracts. However, covert or illegal arms transfers, particularly with the complicity of third parties - remain a credible possibility. Despite Ukrainian transparency on declared production, many unanswered questions and contradictions remain.

The GOU provided documentation that purported to show that 72 of the 76 Kolchugas that GOU admits to producing have been accounted for. GOU asserts that 4 Kolchuga are in PRC, but the team was not given access to documents to confirm this. Ukrainian interlocutors stated that the End-User Clause had been modified at the PRC's request.

The team found a production discrepancy in 1993. Kolchuga are normally produced and deployed three stations at a time, but in 1993 GOU reported four were produced - not six. The team also found it unusual that no Kolchugas were produced in 1996, 1997, 1998, 1999, or 2001 as GOU claims.

If Iraq acquired a Kolchuga system, it would increase the threat to Allied aircrews operating in the northern and southern no-fly-zones as well as to ground and maritime forces operating in the region. The main threat comes when Kolchuga stations are operated in combination which would, potentially, allow Iraq to passively track allied aircraft or geolocate ground and naval radar forces and provide enhanced early warning of allied operations in general. However, both Kolchuga and Kolchuga-M would enhance Iraq's strategic intelligence gathering capability.

There has been no satisfactory in-depth investigation carried out by the Ukrainians. The Prosecutor General, the SBU and the National Security and Defense Council (NSDC) each asserted to the team that they carried out investigations and produced reports, but the team was allowed to see only edited and reduced versions of selected reports. Explanation of the degree to which information sources were checked or verified was lacking in the materials provided to the team. As a result, there remain serious concerns about the credibility and completeness of these GOU investigations.

Ukraine's export control process does not have sufficient safeguards against senior officials or entities misusing state organs or bypassing the system. The SBU and Ukrspetsexport have conflicts of interests within the export control system.

When directly questioned about the late Malev's contact(s) with Jordanian middlemen to sell the Kolchuga to Iraq, the SBU--the only entity apparently aware of the Jordanian connection--reluctantly disclosed that they had been aware of the proposed deal and claimed they advised Malev of the "inadvisability" of carrying it out. But no evidence was forthcoming of whether and how the process was stopped and who exactly was involved.

Next steps

In order for the US and UK to determine whether a Kolchuga passive detection system was transferred to Iraq either directly or through a third party, the GOU will need to:

· make available missing documentation for Kolchuga sales to foreign countries, especially regarding the sale of four Kolchuga stations to the PRC.

· provide information on the location of the Kolchuga stations and Ukrainian technicians in the PRC.

· allow US and UK experts to interview individuals that were not available during the visit to Ukraine, especially Leonid Derkach, former head of the SBU, and Yuri Orshanskyy, former Honorary Consul to Iraq.

· resolve remaining production questions.

II. Purpose and Mandate of the Experts Team

The US-UK Experts Team was formed following separate meetings with President Kuchma by UK Secretary of State for Defense Geoff Hoon and a US delegation led by Assistant Secretary of State for Europe and Eurasia Elizabeth Jones. These visits were prompted by the release of a recording authenticated by the U.S. Federal Bureau of Investigation of President Kuchma authorizing the sale of the Kolchuga passive detection system to Iraq in July 2000. During the meetings with Minister Hoon and Ambassador Jones, President Kuchma invited the team to carry out a review on the basis of full openness and transparency.

The team's main goals were to:

· determine whether the Kolchuga system was transferred to Iraq either directly or through a third party;

· determine the technical capabilities of Kolchuga and the level of threat it could pose to US and UK forces;

· obtain information on the chain of events and leadership decisions leading up to and following President Kuchma's approval of the Kolchuga transfer in July 2000; and,

· assess the Ukrainian arms export control system.

The Experts Team arrived in Ukraine on October 13 and departed on October 20. The team was subdivided into three sub-teams. Sub-team 1 studied the historical record of the Kolchuga issue, export policy, and state controls. Sub-team 2 examined arms sales, manufacturing, contracting, marketing and sales. Sub-team 3 investigated Kolchuga system technical parameters, its range of application, and inventory issues.

During the course of its work, sub-team 1 met with a number of senior GOU officials and parliamentarians, including head of the Presidential Administration Viktor Medvedchuk, National Security and Defense Council (NSDC) Secretary Yevhen Marchuk, Security Service of Ukraine (SBU) Chairman Volodymyr Radchenko, Rada Chairman Lytvyn, Chairman of the State Commission on the Military-Industrial Sector Horbulin, as well as with the Chairmen of the State Service for Export Control, State Committee on the Protection of Borders, and the State Customs Service.

Sub-team 2 visited the various Ukrainian state entities engaged in arms sales, including the umbrella organization Ukrspetsexport and its subsidiaries, and Topaz plant in Donetsk, as well as the Montelekt firm in Kharkiv.

Sub-team 3 also visited the Topaz plant in Donetsk, as well as all Kolchuga sites declared by the GOU.

III. Transparency and Cooperation

The GOU's cooperation and transparency was mixed. The Ministry of Defense and Ministry of Foreign Affairs were very helpful to the team of experts.

The extent to which the sub-teams were able to fulfill their mission was affected by the extent of cooperation and transparency afforded by the GOU. The sub-team engaged in technical aspects and verification of the Kolchuga capability and their locations in Ukraine, enjoyed the greatest degree of cooperation and transparency. This sub-team received full support from their Ukrainian escorts and all of the sub-team's requirements and requests for information were fulfilled.

The sub-team that investigated the inner workings of the Ukrainian arms manufacture and marketing system, particularly in the area of contractual obligations by the end-user, did not receive full cooperation. Not all documentation for Kolchuga sales to foreign countries was made available.

The sub-team that examined historical records and export policy directly related to the Kolchugas encountered the most problems. Access to the people and documents requested were problematic. After requests directly to the Presidential Administration some but not all of these problems were addressed.

The GOU provided requested documentation covering the sale of Kolchugas to Ethiopia. However, Ukrainian officials were unwilling to provide requested documentation on the sale of four Kolchuga stations to the PRC. Ukrainian interlocutors cited classification requirements and confidentiality restrictions in the PRC contract.

The team was allowed to meet with many, but not all of the individuals requested. The Ukrainian side told the team that Leonid Derkach, former head of the Security Service of Ukraine (SBU), and Yuri Orshanskyy, former Honorary Consul to Iraq were unavailable because they were travelling abroad during the time of the team's visit.

The team also encountered difficulty in resolving contradictions. For example, Ukrspetsexport refused to acknowledge Iraq's interest, through a Jordanian intermediary, in the Kolchuga system, though the point was acknowledged publicly and in writing by the SBU. Often answers to the questions posed, particularly those that touched on the role of senior Ukrainian leadership figures, were evasive. In addition, key reports of the various Ukrainian investigations should have been made available to the team on day one. They were not.

On October 19, the team was told that pending documents would be declassified and provided in the coming days. The team is still awaiting those documents.

IV. The Potential Transfer of Kolchugas to Iraq, Directly or Via Third Parties

Based on records provided by Ukraine the team prepared a chart showing the recipients of Kolchuga systems produced at the Topaz plant from 1987 to 1991 and later production from 1992, including those sold to Russia and other countries (Annex B). The team was not in a position to account for the possible later transfer of the oldest Kolchuga equipment, although no evidence was found of any Ukrainian complicity in upgrades or illegal transfers of upgraded older stock. However this may be of lesser concern because of the lower capabilities of early models.

Despite Ukrainian transparency on declared production, many unanswered questions and contradictions remain. It is assessed that Kolchuga has not been directly transferred to Iraq under openly declared contracts. However, illegal arms transfers, particularly with the complicity of third parties - remain a credible possibility. The team encountered evasive responses by Ukrainian government officials to straightforward questions on the possible transfer of Kolchuga to or through third parties.

The GOU provided documentation which purported to show that 72 of the 76 Kolchugas that Ukraine admits to producing have been accounted for. GOU asserts that 4 Kolchuga stations are in China, but the team was not given access to documents to confirm no third party transfer.

The team found a production discrepancy in 1993. Kolchugas are generally produced and normally deployed three stations at a time, but in 1993 GOU reported four were produced - not six. The team also found it unusual that no Kolchugas were produced in 1996, 1997, 1998, 1999, or 2001 as GOU claims.

Contract issues

The sub-team that investigated the arms sales and contracting issues sought to examine Kolchuga sales to Ethiopia and the PRC. At Ukrspetsexport the team met managers of its subsidiary companies and also interviewed a representative from LR Avionics (based in Tel Aviv), the company that brokered the Ethiopian contract for Kolchuga. The Ukrainian side was led by Valeriy Shmarov, General Director of Ukrspetsexport.

The team questioned Shmarov on the Ethiopian and Chinese transactions, placing emphasis on the contract clauses limiting transfer of Kolchuga to third parties. While the team did not seek to compromise Ukraine's legitimate dealings with foreign countries, a satisfactory level of transparency was requested in key areas of concern.

In response to a US "Non-Paper" that had been previously presented to the Government of Ukraine, the Government of Ukraine responded:

"In drawing up the contracts, Ukraine obliges other countries not to transfer stations and their components to third countries."

The team interpreted this statement as meaning that in the template for Ukrspetsexport contracts a standard clause would in all cases be inserted that governed third part transfers. A copy of this template was requested and provided by Ukrspetsexport.

A copy of the standard clause in the Ethiopian contract was provided on request. A similar request for copy of the clause governing third party transfers in the Chinese contract was requested but this was refused. Ukrainian interlocutors stated that this clause had been modified at the PRC's request.

After the team's departure, the GOU provided a copy of a clause precluding re-transfer without approval, which the GOU said was from the PRC contract. However, this clause was on an otherwise blank page, and its authenticity was impossible to judge without access to the full contract. The GOU did not explain the discrepancy between the written clause and the interview with Ukrainian experts who explicitly told the team that the clause had been modified.

Maintenance and spare parts

When asked whether Ukraine had received any maintenance or spares inquiries from countries of the former Soviet Union, Ryabkin of the Topaz plant stated that since 1992 not a single Kolchuga station supplied had come back to the plant for maintenance or upgrade. He agreed that in the normal course of events requests for after sales support would be anticipated. His hypothesis was that the reason for this lay in the lack of finance in those countries with older Kolchuga stations.

The Experts Team found no documentary evidence or audit trail at any location visited that would contradict Ryabkin's statement. The only known upgrade to older equipment, that was exported, were the Kolchuga stations supplied to Ethiopia in 2000 from previous production (1991). A full and comprehensive audit trail for the sale of three Kolchugas in 2000 was identified for the Ethiopian transaction and no anomalies were noted.

Given the team's necessary reliance on production figures provided by Ukraine and the lack of full cooperation and transparency overall, particularly on third party transfer issues, the question of whether Ukraine transferred or is transferring Kolchugas to Iraq must remain open.

Iraqi visit to Donetsk

Open reporting states that a delegation of Iraqis visited Ukraine on 17-21 June 2002, under the aegis of a joint Ukrainian-Iraqi commission for trade, scientific and technology cooperation. The two sides also held meetings at Donetsk during this period, where Kolchuga is manufactured, supposedly to discuss the outlook for cooperation in the oil and gas industry. Various GOU officials denied that there was any Iraqi military presence in Ukraine on 17-21 June 2002. This information was contradicted by the team's documentary evidence. Ukrainian denials raised concerns with the fact-finding team about the true nature of the Iraqi visit to Ukraine.

V. The Current Status of Ukraine's Export Control Process

Since independence Ukraine has been developing an export control system for military goods. They have followed international advice in setting up their system. Under current legislation companies involved in arms export, whether state or privately owned, are obligated to notify and receive a permit to undertake negotiations for sale and export of arms. The permit to export is granted via the State Export Control Service (SECS) which checks to ensure the customer is not subject to international sanctions or other bilateral agreements that would prohibit the sale.

If these checks indicate a need for further review, the request is forwarded to either an interagency committee or an internal committee depending on the issue in question. If further problems are identified then the Committee of Military-Technical Cooperation and Export Control Policy, (headed by recently appointed Ihor Smeshko), reviews the request and forwards it to State Export Control Committee (SECC). The team was told that all applications for military export are referred to the SECC for final decision. All arms firms interviewed during the team's visit were aware of the arms export control process.

The team sought insights into how Ukraine's formal export control process prevents or monitors illegal arms sales to countries such as Iraq. Questioning focused on how the export control system could be thwarted or circumvented by individuals or entities that wield considerable influence in the informal decision-making process:

· The SECS has no investigative powers and relies heavily on the SBU. If there is anything that raises suspicion, such as false End-User Certificates, the SECS refers it to the SBU or in the case of clear criminal responsibility, to the Procurator General, for further action. The team also heard about SBU powers to by-pass other agencies such as customs and border guards. The SBU also sits on the NSDC and SECS and is first in line for any investigations into questionable negotiations/sales/exports of military equipment.

· In the interviews it was stated that Malev, the former head of Ukrspetsexport, did not approach the SECS at any point on a sale of Kolchugas to Jordan or Iraq. However, the team was told that Malev approached SECS members outside of the official committee meetings in order to persuade them to allow controversial deals to go through. The current SBU Chief stated that the SBU had rejected Mr. Malev's proposal, after determining that the Jordanian was a front for Iraq. However, there is no record of these conversations or investigations in the formal export control system or even in the SBU, making it impossible to determine what actually took place.

There are several other areas of concern in the export control process.

· Contracts can be adapted too freely, with insufficient assurance against third part transfers. Ukraine verifies End-User-Certificates (EUC) by asking the recipient country's embassy in Kiev but audit trail circumvention though false EUCs and other means remain as possible avenues to circumvent export controls.

· Violations of the process are not openly reported to independent parties. The NSDC, Prosecutor General, and the SBU conducted investigations into the sale of Kolchugas to Iraq, but all of these bodies are subordinate to the president. The scope of investigation was not set by a truly independent body. Sections of reports the team was allowed to see focused too narrowly on the question of whether there was a direct transfer of Kolchugas to Iraq and there was insufficient investigation into indirect and third party transactions.

· The reports were not automatically made available to the Ukrainian Parliament's (Rada) standing committee for investigation into arms sale violations. Parliamentarians interviewed by the team-expressed frustration at the lack of legislative oversight and inability to carry out independent investigations. Parliament created special investigative commissions that also covered the Kolchuga issue. In practice, these commissions lack power because legislation passed giving Rada investigative commissions subpoena and other powers necessary to carry out their work has not been enacted absent President Kuchma's signature.

The July 2000 recording concerns a deal involving transfer of the Kolchuga system to Iraq via a third party (a Jordanian middleman). In the conversation, General Director of the Ukrspetsexport state arms sales firm, Valeriy Malev, proposes to President Kuchma a plan for the covert transfer of the Kolchuga system. President Kuchma approves Malev's proposal. During its investigation the team saw the presidential appointment book kept by the presidential bodyguard, which showed that President Kuchma and Malev did in fact meet on July 10, 2000 in the president's office.

Officials informed the team that they had discussions with Malev and claimed they had to tell him that they could not support his informal proposals. It was suggested by some of the officials interviewed that Malev then sought President Kuchma's approval to pre-empt any decision against the deal in the formal export control process. However, other officials interviewed by the team dismissed this possibility.

In the Kolchuga case, it appears, on balance of evidence available to the team, that Malev avoided the formal export control process and directly approached President Kuchma and the SBU (then headed by Leonid Derkach). This could explain the lack of a formal paper trail in the custody of the various export control bodies.

The Kolchuga controversy highlights serious deficiencies in Ukraine's export control system.

III. Conclusions and Next Steps

Conclusions

The main finding of this fact-finding mission is that the Government of Ukraine (GOU) failed to provide the team with satisfactory evidence that the transfer of a Kolchuga to Iraq could not or did not take place. As a result, the issue of the transfer must remain open.

The GOU only provided information that the meeting between President Kuchma and Valeriy Malev occurred. No information was provided related to the authorization of the transfer.

Given the team's necessary reliance on production figures provided by Ukraine and the lack of full cooperation and transparency overall, particularly on third party transfer issues, the question of whether Ukraine transferred or is transferring Kolchugas to Iraq, through a third country must remain open.

It is assessed that Kolchuga has not been directly transferred to Iraq under openly declared contracts. However, covert or illegal arms transfers, particularly with the complicity of third parties - remain a credible possibility. The team encountered evasive responses by Ukrainian government officials to straightforward questions on the possible transfer of Kolchuga to or through third parties

If Iraq acquired a Kolchuga system, it would increase the threat to Allied aircrews operating in the northern and southern no-fly-zones as well as to ground and maritime forces operating in the region. The main threat comes when Kolchuga stations are operated in combination which would, potentially, allow Iraq to passively track allied aircraft or geolocate ground and naval radar forces and provide enhanced early warning of allied operations in general. However, both Kolchuga and Kolchuga-M would enhance Iraq's strategic intelligence gathering capability.

There has been no satisfactory in-depth investigation carried out by the Ukrainians. The Prosecutor General, the SBU and the National Security and Defense Council (NSDC) each asserted to the team that they carried out investigations and produced reports, but the team was allowed to see only edited and reduced versions of selected reports. Explanation of the degree to which information sources were checked or verified was lacking in the materials provided to the team. As a result, there remain serious concerns about the credibility and completeness of these GOU investigations.

Ukraine's export control process does not have sufficient safeguards against senior officials or entities misusing state organs or bypassing the system. The SBU and Ukrspetsexport have conflicts of interests within the export control system.

When directly questioned about the late Malev's contact(s) with Jordanian middlemen to sell the Kolchuga to Iraq, the SBU--the only entity apparently aware of the Jordanian connection--reluctantly disclosed that they had been aware of the proposed deal and claimed they advised Malev of the "inadvisability" of carrying it out. But no evidence was forthcoming of whether and how the process was stopped and who exactly was involved.

Next Steps

In order for the US and UK to determine whether a Kolchuga passive detection system was transferred to Iraq either directly or through a third party, the GOU will need to:

· make available missing documentation for Kolchuga sales to foreign countries, especially regarding the sale of four Kolchuga stations to the PRC.

· provide information on the location of the Kolchuga stations and Ukrainian technicians in the PRC.

· allow US or UK experts interview individuals that were not available during the visit to Ukraine, especially Leonid Derkach, head of the Security Service of Ukraine at the time of the taped President Kuchma/Malev conversation, and Yuri Orshanskyy, former Honorary Consul to Iraq.

· resolve remaining production issues.

ANNEX A

THE KOLCHUGA SYSTEM

The following assessment is based on Kolchuga stations seen by the sub-team 3. These units comprised 11 stations produced before 1992 and 8 stations produced between 1992 and 1995. One prototype station built in 2000 was also seen. Sub-team 3 saw some stations upgraded to the Kolchuga-M standard, but it did not see any of the Kolchuga-E systems (the export version of the Kolchuga-M) supplied to China. The capabilities of the Chinese Kolchuga system were not revealed to the team except in general terms. The threat this particular system could pose cannot, therefore, be assessed with certainty.

Purpose: The Kolchuga system provides identification, early warning and location of radio frequency emissions from land, sea, or air platforms. Kolchuga can detect communications and navigation emissions, but is designed to detect radar emitters. Kolchuga can assist in the production of the Electronic Order of Battle, as well as providing early warning, target classification and limited tracking.

Function. Both variants of Kolchuga search for electronic emissions. Bearing information is provided for all emissions, but pulsed emissions are analyzed further to allow determination of emitter type and function. Multiple Kolchuga stations can coordinate to allow triangulation of emitters. Kolchuga-M has an improved capability to do this by using computer-to-computer data communications.

Composition and variants. There are 2 design types of Kolchuga, the basic Kolchuga and the Kolchuga-M. All variants comprise an operations vehicle (M1), a support vehicle (M2) and an electrical generator set. The Kolchuga started production at the Topaz production facility during 1987 and the basic design was modified to produce the Kolchuga-M variant in 1999. Kolchuga-M offers the following improvements over the original system: increased frequency coverage, better man-machine interface, the addition of modem connectivity between stations and an improved data processing capability. A third version, Kolchuga-E, is the export version of the Kolchuga-M, which has documentation and labeling in English. Differences between these two version do exist; it may be that the main changes are in technology and not capability. However, small improvements could arise, for example, through software changes but no step change in capability.

Capabilities: The Kolchuga system can detect emitters in the frequency range 1-11 GHz and 15-18 GHz. Kolchuga-M/E has extended frequency coverage of 0.1-18 GHz. An individual receiver station can provide a line-of-bearing to the emitter together with pulse parameters that can be used to classify the emitter. Multiple Kolchuga stations can operate as a complex to locate an emitter through triangulation. The Kolchuga-M has a data-link capability between stations that enables it to operate as a complex. A complex can track at least a single target, but the extent of its multi-tracking capabilities requires further analysis.

Upgrades: Kolchuga systems can be modified to Kolchuga-M capability. This is a considerable modification, which is likely to require access to specialized test equipment and other facilities available at the factory and is therefore considered unlikely that this upgrade could be performed without factory support.

Threat: If Iraq acquired a Kolchuga system, it would increase the threat to Allied aircrews operating in the northern and southern no-fly-zones as well as to ground and maritime forces operating in the region. The main threat comes when Kolchuga stations are operated in combination which would, potentially, allow Iraq to passively track allied aircraft or geolocate ground and naval radar forces and provide enhanced early warning of allied operations in general. However, both Kolchuga and Kolchuga-M would enhance Iraq's strategic intelligence gathering capability.

Verification of Ukrainian MOD Kolchuga Systems: Sub-team 3 and a Ukrainian escort group visited each location, declared by the GOU, where the Ukrainian MOD operates/stores Kolchuga systems. The systems were verified against an inventory of Kolchuga systems provided by the GOU. For each system the variant and serial number were checked against the inventory. There were no discrepancies. A press report stated that Kolchuga systems from Belarus were moved to the vicinity of Lyubichi, where the team visited military unit A3330. The team went to the site and inspected all garages and buildings capable of holding a Kolchuga system. No evidence of any Kolchuga systems was found at this site.

ANNEX B

Annex B is a list of each of the 76 Kolchuga stations reported by the Ukrainian side as having been produced by the Topaz facility between 1988 and 2002. We are withholding Annex B because it contains proprietary information.