Knack and Syrian Archive reveal today that Belgian companies have violated EU sanctions against Syria, according to the summons of an upcoming lawsuit.
Based on information found through the <a href="https://comtrade.un.org/">UN Comtrade database</a>, freedom of information requests, and confirmed by the Belgian Customs, we can reveal that a criminal case regarding exports of chemicals to Syria has been opened in Antwerp Criminal Court. This case is brought by the Belgian Customs against three Flemish companies, one managing director and one manager, according to court press judge Roland Cassiers citing the summons.
Since EU sanctions from September 2013 made export licences compulsory for the export of isopropanol to Syria in concentrations of 95% or higher, Syrian Archive and <a href="https://www.knack.be/nieuws/belgie/isopropanol-schandaal-hoe-een-grondstof-voor-gifgas-door-de-handen-van-de-belgische-douane-glipte/article-longread-1097291.html">Knack</a> can report that Belgian companies exported 168 tonnes of isopropanol, a sarin precursor, to Syria between 2014 and 2016.
Sarin is the nerve gas used by the Syrian government in the Khan Shaykhun attack that killed 74-100 people in April of last year, as <a href="https://www.diplomatie.gouv.fr/en/country-files/syria/events/article/chemical-attack-in-syria-national-evaluation-presented-by-jean-marc-ayrault">attributed</a> by the French Ministry of Foreign Affairs. According to Belgian toxicologist Jan Tytgat (KU Leuven), victims of sarin die a painful death. “Diarrhea, urinary flare, narrowed pupils, spasms that give you the feeling of suffocation, vomiting, lacrimation and saliva production: the victim quickly becomes paralyzed, suffocates and dies. The lethal dose of sarin for adults is estimated to be less than 1 milligram.”
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[Video](https://syrianarchive.org/en/database?unit=e58e64bc) by Hadi Alabdallah of a factory next to the impact site which was targeted by a chemical bomb in Khan Shaykhun

The Organisation for the Prevention of Chemical Weapons (OPCW), that oversees compliance with the Chemical Weapons Convention, examined samples from and around the impact crater in Khan Shaykhun, <a href="http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF168FF9%7D/s_2017_904.pdf">finding</a> in laboratory tests that isopropanol was used in the production of sarin used in the attack.
Isopropanol, also known as isopropyl alcohol, is considered a “dual use” product, much like chlorine, which has ordinary industrial uses (such as in the manufacturing of pharmaceuticals or acetate, where it is favoured due to its low toxicity and small amount of residue). It can also be used in the synthesis process when manufacturing chemical agents such as the nerve agent sarin. Like all chemical weapons, the use of sarin has been banned since the 1993 Chemical Weapons Convention.
The question is: where did Syria get its isopropanol from? In October 2013, Syria acceded to the Chemical Weapons Convention. &quot;It was then necessary to destroy its stocks of isopropanol,&quot; says Jean-Pascal Zanders from consultancy firm <a href="http://www.the-trench.org/author/jp-zanders/">The Trench</a>, a Belgian expert on chemical weapons.
According to the OPCW, Syria <a href="https://www.opcw.org/news/article/opcw-all-category-1-chemicals-declared-by-syria-now-destroyed/">liquidated</a> a stock of 133 tonnes of isopropanol. However, the French Ministry of Foreign Affairs found evidence that since 2014, the Syrian regime has tried to acquire “dozens of tonnes of isopropanol.”
Data found by Syrian Archive staff in the <a href="https://comtrade.un.org/">UN Comtrade database</a> shows that since 2014, an estimated 1.28 million kilograms of propanol and isopropanol (both propanol and isopropanol are registered under the same code) were exported by various countries to Syria, the largest majority coming from United Arab Emirates and Lebanon with a combined 674,880 kilograms since EU sanctions were introduced. See below:
<iframe src="https://public.tableau.com/views/ExportsofisopropanolandpropanoltoSyriainkilograms2013-2017/Sheet1?:showVizHome=no&:embed=true" width="645" height="455"></iframe>


Source: UN Comtrade. Reported exports of isopropanol and propanol to Syria in kilograms (2013-2017)
The UN Comtrade statistics show that Belgium was the only EU member state that continued to export (iso)propanol to Syria since EU sanctions were imposed in 2013. After this discovery, we contacted the Belgian Customs for a reaction.
According to Francis Adyns, spokesperson of the Belgian Federal Public Service Finance (the government department to which the Customs belong), &quot;appropriate permits were not submitted to the Belgian Customs (...) The established facts were the subject of a criminal investigation. The prosecution was initiated at the Criminal Court of Antwerp at the end of March.”
Through information from the Antwerp Criminal Court, we now know that &#39;The customs authorities summon three Flemish companies, one managing director and one manager,&#39; says press judge Roland Cassiers, citing the summons. &quot;The companies are AAE Chemie Trading from Kalmthout, a wholesaler of chemical products for industrial use; Anex Customs from Hoevenen, a business office that provided administrative services until it went bankrupt in 2017; and Danmar Logistics, a logistics company from Stabroek.&quot; Cassiers stresses that they are only charged but that &#39;the facts are not declared proven yet&#39;. The opening session of the lawsuit at the Antwerp Criminal Court is set for 15 May 2018.
Francis Adyns, spokesperson of the Finance department, confirms that the Customs had proposed to A.A.E. Chemie a friendly settlement.
<blockquote>
That proposal referred to a first, closed part, of the investigation. AAE Chemie did not agree with the proposal. When the customs performed additional investigative acts in this case, in which the involvement of AAE Chemie came up again, AAE Chemie referred to the proposal of a friendly settlement. But because the company had not accepted the proposed settlement, the Customs did prosecute the company in the end.
</blockquote>
Contacted by Knack, the three companies <a href="http://www.knack.be/nieuws/belgie/isopropanol-schandaal-hoe-een-grondstof-voor-gifgas-door-de-handen-van-de-belgische-douane-glipte/article-longread-1097291.html">stress</a> that they were not aware that export licenses were compulsory for exports of chemicals to Syria, as they had been exporting chemicals to private companies in Syria for over a decade. They state that they acted in good faith and that they did not have the intention to hide anything. They argue that the Belgian Customs&#39; information system on legal obligations (TARBEL/TARWEB) was not up to date, and that the Belgian Customs scanned and controlled all exports to Syria for 100%. According to the companies, the Customs never refused any of the exports.
The summons of the lawsuit shows that the Belgian Customs only determined that the appropriate export licenses had not been submitted by the companies after the chemicals had already been exported to Syria. 
That chronology raises questions, especially bearing in mind public <a href="https://diplomatie.belgium.be/en/newsroom/news/2018/belgium_supports_fight_against_use_of_chemical_weapons">statements</a> made by the Belgian government last month on the 100th anniversary of the first chemical weapons attack, which took place in Belgium in 1917. The Deputy Prime Minister and Minister of Foreign Affairs Didier Reynders and Minister of Defence Steven Vandeput released a statement that “Belgium condemns the use of chemical weapons by the regime and rebel groups in Syria. These constitute war crimes which must be punished.”
<img src="/uploads/politicians_8efe71459d.jpg" alt="Belgium Politicians">
Deputy Prime Minister and Minister of Foreign Affairs Didier Reynders and Minister of Defence Steven Vandeput and Ahmet Üzümcü, Director-General of the Organisation for the Prohibition of Chemical Weapons (OPCW)
In Belgium, the granting of export licenses is a responsibility of the three regions: Brussels, Wallonia and Flanders. Answers received after Freedom of Information Requests show that no export licenses for isopropanol were requested to the Walloon or Brussels authorities since 2013. 
Public documents from the Flemish authorities show that in October 2016 a requested export license was denied for the export of dual-use chemicals to Syria, totaling €1.93 million. That case did not concern isopropanol, Flemish authorities confirm. But it shows that Belgium is not willing to grant export licenses for the export of dual-use chemicals to Syria.
The upcoming trial at the Antwerp Criminal Court not only concerns the export of isopropanol to Syria. According to the summons cited by court press judge Roland Cassiers, 24 shipments of sanctioned chemicals from Belgium to Syria and Lebanon took place between May 2014 and December 2016, in which 165 tonnes of isopropanol (69 tonnes to Lebanon and the remaining shipments to Syria), 219 tonnes of acetone, 77 tonnes of methanol and 21 tonnes of dichloromethane had been exported without the appropriate licenses.
According to Francis Adyns of the Belgian Federal Public Service Finance, the Belgian Customs have no indication that the isopropanol exported from Belgium has been used for the production of sarin. &quot;Isopropanol is used, among other things, as a solvent in the paint and varnish industry, as a disinfectant in health care and as a coolant. The Customs have no information about any other use than for the paint industry. The export has already been taking place for a decade to the same customers.&quot;
In its response to Clerix, AAE Chemie itself confirmed the transport of isopropanol in a concentration of 95% or higher to Syria but claims that Belgian Customs also bear responsibility for what went wrong.
&lowast; The citations of Roland Cassiers, Jan Tytgat, Francis Adyns, Jean-Pascal Zanders, and the reactions of the companies are translations of the citations published in the Knack article &#39;Isopropanol-schandaal: hoe een grondstof voor gifgas door de handen van de Belgische douane glipte&#39; from 18 April 2018.

Jeff Deutch, additional reporting by Kristof Clerix from Knack

Belgium illegally shipped 168 tonnes of sarin precursor to Syria

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On 18 April 2018 Syrian Archive and Knack revealed information that Belgium violated EU sanctions against Syria according to the summons of an upcoming lawsuit. The Belgian customs found that without having requested the appropriate export licenses three Flemish companies have exported 168 tonnes of isopropanol in a concentration of 95% or higher to Syria since sanctions came into force in September 2013.
The Syrian Archive has worked with Belgian news outlet Knack on this investigation for the past year. All of the information was publicly or collaboratively sourced through searching online databases, submitting Freedom of Information Requests and requesting statements from authorities, courts and companies involved.
This article documents some of the open source investigative methods employed in our investigation that discovered several key pieces of information.
<h3>Global trade figures</h3>
Syrian Archive staff began our investigation in the aftermath of last year April’s sarin attack in Khan Sheikhoun in which the Organisation for the Prevention of Chemical Weapons (OPCW), that oversees compliance with the Chemical Weapons Convention, examined samples from and around the impact crater in Khan Sheikhoun, <a href="http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF168FF9%7D/s_2017_904.pdf">finding</a> in laboratory tests that isopropanol was used in the production of sarin used in the attack.
We consulted The <a href="https://comtrade.un.org/">UN Comtrade</a> database to identify whether any shipments of isopropanol, a sanctioned chemical from EU Member States to Syria, were reported after <a href="http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1493825060366&uri=CELEX:02012R0036-20170321">sanctions were put in place in 2013</a>.
<a href="https://comtrade.un.org/">Comtrade</a>, coordinated by the United Nations Statistical Division, collects monthly and annual trade statistics from more than 170 countries and displays these figures <a href="https://comtrade.un.org/data/dev/portal">online in a public, downloadable and queriable format</a>. The OCCRP similarly queried the Comtrade database in their <a href="https://www.occrp.org/en/makingakilling/croatia-sells-record-number-of-arms-to-saudi-arabia-in-2016/">investigation of Croatian arms sales</a> being diverted to Syria.
Below is a walkthrough of the search we conducted on the Comtrade database.
<video controls autoplay width="100%">
 <source src="https://cube.syrianarchive.org/isopropanoluncomptrade.mp4" type="video/mp4" />
Your browser does not support the video tag.
</video>


While amounts reported to Comtrade may potentially under-represent true trade export figures due to self-reporting bias, the data shows that since 2014, an estimated 1.28 million kilo of propanol and isopropanol were exported by various countries to Syria (both propanol and isopropanol are registered under the same code). See below:
<iframe src="https://public.tableau.com/views/ExportsofisopropanolandpropanoltoSyriainkilograms2013-2017/Sheet1?:showVizHome=no&:embed=true" width="645" height="455"></iframe>


Source: UN Comtrade. Reported exports of isopropanol and propanol to Syria in kilograms (2013-2017)
The distinction between propanol and isopropanol is essential. While isopropanol in concentration of 95% or higher is prohibited without prior approval, propanol is not.
<h3>Data collectors</h3>
In order to find out whether the figures provided by Comtrade referred to propanol or isopropanol, we contacted the Trade Statistics Branch of the United Nations Statistics Division in April 2017 to inquire as to whether disaggregating figures was possible. Comtrade confirmed that they only have a single code in use for both for propanol and isopropanol (HS 290512). As a result, divorcing isopropanol from propanol figures within Comtrade figures was not possible.
In May 2017, we requested any additional information from the European Commission Service for Foreign Policy Instruments Restrictive measures team to inquire as to whether any Member States sought authorisation for the trading of isopropanol to Syria. In their answer, the European Commission stated they were “not in a position to provide advice on whether a concrete product falls under the technical specifications of an Annex to a Regulation” and that “Responsibility for the application of EU restrictive measures falls with the competent authorities of each Member State, as listed in Annex III to <a href="http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1493825060366&uri=CELEX:02012R0036-20170321">Regulation 36/2012</a>.”
Through the Comtrade database we found that Belgium was the only EU Member State to continue exporting propanol/isopropanol to Syria since sanctions came into force in 2013, so we decided to focus efforts on investigating Belgium.
<h3>Courts and industry</h3>
Reaching a roadblock, and needing in country expertise, we reached out to investigative reporter Kristof Clerix of Knack, a Belgian weekly magazine. Clerix wanted to see what was going on out of public view and begun to file Freedom of Information Requests to various Belgium entities.
Belgium is divided into three regions: Flanders; Brussels; and Wallonia. Each with their own freedom of information policies. In Flanders, information about export licenses is published by the authorities on a monthly basis in public <a href="http://www.fdfa.be/nl/maand-en-jaarverslagen">documents</a>. So Clerix submitted Freedom of Information Requests to the other two regions.
Brussels and Wallonia replied to Freedom of Information Requests stating that no licenses were requested for the approval of isopropanol export to Syria during the 2013-2017 period.
After receiving those answers, Clerix also contacted Essenscia, the Belgian chemical sector umbrella organisation. After waiting six months to hear back, Essenscia stated that after extensive research and consultation with relevant stakeholders, it seemed “most likely that the export of (iso)propanol from Belgium to Syria is related to a trading company that has purchased the product abroad and then has handled it and exported it via Belgium.” Continuing on, the statement explains (emphasis in original):
&quot;We have no indication whatsoever that the exported (iso)propanol to Syria has been produced or shipped by a chemical company located in Belgium. Moreover, the exported goods are fully approved by the customs authorities who severely monitor any trade with Syria since several years. All of this indicates that our country and our industry, who both support the Chemicals Weapons Convention and the Organisation for the Prohibition of Chemical Weapons (OPCW) in every possible way, cannot be linked to the intolerable incident in Syria.&quot;
The statement was proven inaccurate by court documents received in subsequent months.
A publicly available document found by a Belgian expert consulted by Clerix revealed that in October 2016 in the Flanders region, authorities denied a permit request, preventing the export of €1.93 million of banned dual-use chemicals to Syria specified under Annex IX of the European sanctions against Syria. It has been confirmed by the Flemish authorities that this did not relate to isopropanol.
Belgian Customs confirmed that indeed shipments of (iso)propoanol to Syria had been made, although propanol and isopropanal figures were not disaggregated.
According to the summons cited by Antwerp Criminal Court press judge Roland Cassiers, <a href="https://syrianarchive.org/en/investigations/belgium-isopropanol/">a criminal case is currently being pursued by Belgian customs against three companies and two individuals</a>. This case is set to begin on the 15 May 2018.
Our year long investigation revealed many key pieces of information located through open source investigative techniques. The Syrian Archive along with Knack will continue to pursue and document the case as it unfolds.

How we tracked the illegal shipment of sarin precursor from Belgium to Syria

Methodology

shippingtracking.png

<h3>Illegal export of isopropanol to Syria</h3>
Today, 7 February 2019, Antwerp Criminal court convicted the three Flemish companies (AAE Chemie Trading, Anex Customs and Danmar logistics) and two managing directors for shipping 168 tonnes of the chemical substance isopropanol with 95% purity to Syria between 2014 and 2016 without submitting the appropriate export licences. The court imposed conditional fines of up to 500.000 EUR as well as (conditional) prison sentences for one managing director and one manager. A export licence for isopropanol 95% has been mandatory since the European Union ratified sanctions on Syria with <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1493825060366&uri=CELEX:02012R0036-20170321">regulation 36/2012</a>. This conviction follows a story published jointly on April 18th, 2018 from <a href="https://syrianarchive.org/en/investigations/belgium-isopropanol/">Knack and Syrian Archive</a>.
AAE Chemie Trading, the wholesaler from Kalmthout that supplied the chemicals, was sentenced to a conditional fine of 346.443 EUR, of which 50.000 EUR is effective. Anex Customs from Hoevenen and Danmar Logistics from Stabroek were sentenced to a conditional fines of 500.000 EUR, of which 100.000 EUR takes is effective, and 75.000 EUR, of which 50.000 is effective.
The manager of AAE Chemie Trading and the manager of Anex Customs and Danmar Logistics were sentenced to a conditional fine of 346.443 EUR, of which 50.000 EUR effective, and 500.000 EUR, of which 100.000 EUR effective. The manager of AAE Chemie Trading also received a conditional 4 months prison sentence, and the manager of Anex and Danmar received a 12 months prison sentence effective.
Isopropanol, also known as isopropyl alcohol, is a so-called “dual-use substance,” as it has a wide range of legitimate civilian uses, but it can also be used in the synthesis process of manufacturing chemical agents such as the nerve agent sarin.
After the 2017 sarin attack in Khan Shaykhun, the Organisation for the Prevention of Chemical Weapons (OPCW), that oversees compliance with the Chemical Weapons Convention, examined samples from and around the impact crater, <a href="http://www.securitycouncilreport.org/atf/cf/%7b65BFCF9B-6D27-4E9C-8CD3-CF6E4FF96FF9%7d/s_2017_904.pdf">finding</a> in laboratory tests that isopropanol was used in the production of sarin used in the attack.
The lawsuit against the three companies began in Antwerp on May 15, 2018 and the sentencing took place on February 7, 2019. 
<h3>Companies faced possible fines and prison sentence</h3>
In the pleadings, lawyer Pieter Borms, representing the Belgian Customs, asked for a minimum fine of 346.443 EUR for AAE Chemie as this was the company&#39;s first infringement.
The lawyer asked a higher fine for Anex Customs (750.000 EUR) and Danmar Logistics (160.000 EUR), as well as a 500.000 EUR fine for the manager. Customs also demanded a forfeiture of the goods.
The Public Prosecutor&#39;s Office joined the Customs&#39; point of view. It asked a prison sentence of 4 months for the manager of AAE Chemie and 18 months for the manager of Danmar Logistics.
Lawyer Joris Vercraeye represented AAE Chemie, which declared bankruptcy on December 20, 2018. The manager of AAE Chemie was not present in the court during the pleadings. Vercraeye mentioned that the bankruptcy of AAE Chemie was a direct consequence of this court case. He also stated that the Belgian Customs had presented a friendly settlement to his client on November 8, 2017, adding &#39;That is at odds with what the Customs declare today, namely that there is deceptive intent. If that would be true, why offer a friendly settlement then?&quot;
Vercraeye stated that Anex Customs and Danmar Logistics (that took care of the administrative obligations on behalf of AAE Chemie) were not aware of the license obligation. He added that the Customs tool TARWEB at the time of the exports did not mention that an export licence was required, and that that was the reason why AAE Chemie hadn&#39;t applied for the required approval. 
According to Vercraeye the last update of TARWEB regarding isopropanol was implemented on April 19, 2018, one day after the article was published by <a href="https://m.knack.be/nieuws/belgie/isopropanol-schandaal-hoe-een-grondstof-voor-gifgas-door-de-handen-van-de-belgische-douane-glipte/article-longread-1097291.html">Knack</a>.
He also stated that all 24 shipments had been checked by the Belgian Customs. “Samples were taken, examined in the lab, and afterwards the products were released by the Customs for shipment. It was only later that the manager learned through Dutch Customs that an export license was required for isopropanol. He then spontaneously sent the Dutch Customs a list of shipments that had been exported to Syria.”
Vercraeye also denounced that the judicial file was not complete: the Belgian Customs had conducted their own internal audit into the matter, but neither the lawyers of the defense nor the judge had access to that audit report.
<h3>Internal audit report of Belgian customs</h3>
Knack submitted a FOIA request to the Belgian Customs in order to get a copy of the audit report. After a procedure battle, on January 25, 2019, Knack received the 31 page document entitled <a href="https://www.knack.be/nieuws/belgie/de-zaak-isopropanol-audit-hekelt-falende-douanecontrole/article-normal-1422901.html">“Audit Control Sensitive Goods in the context of the Isopropanol case.”</a>
According to this internal audit report, the Customs&#39; inspection service was asked on February 23, 2018 to launch an audit into the subject matter. This was shortly after Knack had contacted the Belgian Customs with worrying indications –based on Syrian Archive&#39;s findings in the UN Comtrade database– about the export of isopropanol to Syria.
<img src="/uploads/image2_da1c6e9c45.png" alt="Internal audit">
Screenshot from the pdf of the internal audit by the Belgian Customs, showing the timeline of the audit process and the following action plan.
“Most control weaknesses are in the first line,” the audit concludes. On the basis of a studied sample of isopropanol exports, the inspection service of the Customs found that “many physical checks were requested but virtually none performed.” Customs usually checked only the documents, not the chemicals. Customs officers surveyed indicated that they were under time pressure, that it was difficult to consult European legislation in the internal Customs system, and that the selection profile document to detect fraud was insufficiently informative.
The report also mentioned that the internet capacity at the border inspection post in Antwerp was “very low” until the beginning of 2018, and even insufficient to carry out additional investigations. Moreover, the Customs officers had received insufficient training. Finally, the Customs also argue that the declaration forms of the chemicals had been incorrectly filled out by the exporter.
The audit also examined whether the control process for the export of goods subject to restrictions complies with the principles of internal control.
In this context, “a large number of control weaknesses were identified,” linked to limited human and financial resources. “The inspection service can not give a reasonable assurance that risks are being controlled and that the monitoring process will achieve its objectives”.
There were ambiguities about roles and responsibilities, some instructions were no longer up to date, and education and awareness also turned out to be points for improvement.
Problems were identified with both internal and external communication. There was not even an unambiguous verification method to determine the “purity level or composition of sensitive strategic goods.”
The audit report further addressed the lack of a central database with information about previous violations. And the quality of the checks carried out was not effectively monitored.
Finally, the report showed that it was unclear which procedure the Customs had to follow after establishing an infringement against the export restrictions.
Kristian Vanderwaeren, the Customs&#39; Administrator-General, says that the Customs have, in the meantime, taken several actions to improve the control system. “A structurally better consultation with the licensing services in Flanders, Wallonia and Brussels has also been developed as a vital element for a better assessment of the export risks.”
The audit report lists 17 concrete recommendations and improvement actions, such as practical training for Customs officers and clear communication guidelines. The Customs also carried out a feasibility study regarding digital storage of all submitted documents, and they plan, among other things, a re-evaluation of the workload measurement.
The audit also includes a series of screenshots from the Customs’ TARIC and TARBEL databases. From the screenshots, it appears that the database includes information about the export restrictions for isopropanol.
Below is a screenshot of the TARIC database, with the code of isopropanol entered (2905120000). It is important to note that this search was conducted on “05-05-2018”, roughly a month after the audit was started.
<img src="/uploads/image1_7941374bee.png" alt="TARIC database">
<img src="/uploads/image3_194cc8c617.png" alt="TARIC database">
<img src="/uploads/image5_3763f7d556.png" alt="TARBEL database">
<h2>Methodology</h2>
On 18 April 2018 Syrian Archive and Knack revealed information that Belgium violated EU sanctions against Syria according to the summons of an upcoming lawsuit. The Belgian customs found that without having requested the appropriate export licenses three Flemish companies have exported 168 tonnes of isopropanol in a concentration of 95% or higher to Syria since sanctions came into force in September 2013.
The Syrian Archive has worked with Belgian news outlet Knack on this investigation for the past year. All of the information was publicly or collaboratively sourced through searching online databases, submitting Freedom of Information Requests and requesting statements from authorities, courts and companies involved.
This article documents some of the open source investigative methods employed in our investigation that discovered several key pieces of information.
<h3>Global trade figures</h3>
Syrian Archive staff began our investigation in the aftermath of last year April’s sarin attack in Khan Sheikhoun in which the Organisation for the Prevention of Chemical Weapons (OPCW), that oversees compliance with the Chemical Weapons Convention, examined samples from and around the impact crater in Khan Sheikhoun, <a href="http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF168FF9%7D/s_2017_904.pdf">finding</a> in laboratory tests that isopropanol was used in the production of sarin used in the attack.
We consulted The <a href="https://comtrade.un.org/">UN Comtrade</a> database to identify whether any shipments of isopropanol, a sanctioned chemical from EU Member States to Syria, were reported after <a href="http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1493825060366&uri=CELEX:02012R0036-20170321">sanctions were put in place in 2013</a>.
<a href="https://comtrade.un.org/">Comtrade</a>, coordinated by the United Nations Statistical Division, collects monthly and annual trade statistics from more than 170 countries and displays these figures <a href="https://comtrade.un.org/data/dev/portal">online in a public, downloadable and queriable format</a>. The OCCRP similarly queried the Comtrade database in their <a href="https://www.occrp.org/en/makingakilling/croatia-sells-record-number-of-arms-to-saudi-arabia-in-2016/">investigation of Croatian arms sales</a> being diverted to Syria.
Below is a walkthrough of the search we conducted on the Comtrade database.
<video controls autoplay width="100%">
 <source src="https://cube.syrianarchive.org/isopropanoluncomptrade.mp4" type="video/mp4" />
Your browser does not support the video tag.
</video>


While amounts reported to Comtrade may potentially under-represent true trade export figures due to self-reporting bias, the data shows that since 2014, an estimated 1.28 million kilo of propanol and isopropanol were exported by various countries to Syria (both propanol and isopropanol are registered under the same code). See below:
<iframe src="https://public.tableau.com/views/ExportsofisopropanolandpropanoltoSyriainkilograms2013-2017/Sheet1?:showVizHome=no&:embed=true" width="645" height="455"></iframe>


Source: UN Comtrade. Reported exports of isopropanol and propanol to Syria in kilograms (2013-2017)
The distinction between propanol and isopropanol is essential. While isopropanol in concentration of 95% or higher is prohibited without prior approval, propanol is not.
<h3>Data collectors</h3>
In order to find out whether the figures provided by Comtrade referred to propanol or isopropanol, we contacted the Trade Statistics Branch of the United Nations Statistics Division in April 2017 to inquire as to whether disaggregating figures was possible. Comtrade confirmed that they only have a single code in use for both for propanol and isopropanol (HS 290512). As a result, divorcing isopropanol from propanol figures within Comtrade figures was not possible.
In May 2017, we requested any additional information from the European Commission Service for Foreign Policy Instruments Restrictive measures team to inquire as to whether any Member States sought authorisation for the trading of isopropanol to Syria. In their answer, the European Commission stated they were “not in a position to provide advice on whether a concrete product falls under the technical specifications of an Annex to a Regulation” and that “Responsibility for the application of EU restrictive measures falls with the competent authorities of each Member State, as listed in Annex III to <a href="http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1493825060366&uri=CELEX:02012R0036-20170321">Regulation 36/2012</a>.”
Through the Comtrade database we found that Belgium was the only EU Member State to continue exporting propanol/isopropanol to Syria since sanctions came into force in 2013, so we decided to focus efforts on investigating Belgium.
<h3>Courts and industry</h3>
Reaching a roadblock, and needing in country expertise, we reached out to investigative reporter Kristof Clerix of Knack, a Belgian weekly magazine. Clerix wanted to see what was going on out of public view and begun to file Freedom of Information Requests to various Belgium entities.
Belgium is divided into three regions: Flanders; Brussels; and Wallonia. Each with their own freedom of information policies. In Flanders, information about export licenses is published by the authorities on a monthly basis in public <a href="http://www.fdfa.be/nl/maand-en-jaarverslagen">documents</a>. So Clerix submitted Freedom of Information Requests to the other two regions.
Brussels and Wallonia replied to Freedom of Information Requests stating that no licenses were requested for the approval of isopropanol export to Syria during the 2013-2017 period.
After receiving those answers, Clerix also contacted Essenscia, the Belgian chemical sector umbrella organisation. After waiting six months to hear back, Essenscia stated that after extensive research and consultation with relevant stakeholders, it seemed “most likely that the export of (iso)propanol from Belgium to Syria is related to a trading company that has purchased the product abroad and then has handled it and exported it via Belgium.” Continuing on, the statement explains (emphasis in original):
&quot;We have no indication whatsoever that the exported (iso)propanol to Syria has been produced or shipped by a chemical company located in Belgium. Moreover, the exported goods are fully approved by the customs authorities who severely monitor any trade with Syria since several years. All of this indicates that our country and our industry, who both support the Chemicals Weapons Convention and the Organisation for the Prohibition of Chemical Weapons (OPCW) in every possible way, cannot be linked to the intolerable incident in Syria.&quot;
The statement was proven inaccurate by court documents received in subsequent months.
A publicly available document found by a Belgian expert consulted by Clerix revealed that in October 2016 in the Flanders region, authorities denied a permit request, preventing the export of €1.93 million of banned dual-use chemicals to Syria specified under Annex IX of the European sanctions against Syria. It has been confirmed by the Flemish authorities that this did not relate to isopropanol.
Belgian Customs confirmed that indeed shipments of (iso)propoanol to Syria had been made, although propanol and isopropanal figures were not disaggregated.
According to the summons cited by Antwerp Criminal Court press judge Roland Cassiers, <a href="https://syrianarchive.org/en/investigations/belgium-isopropanol/">a criminal case is currently being pursued by Belgian customs against three companies and two individuals</a>. This case is set to begin on the 15 May 2018.
Our year long investigation revealed many key pieces of information located through open source investigative techniques. The Syrian Archive along with Knack will continue to pursue and document the case as it unfolds.

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Belgium illegally shipped 168 tonnes of sarin precursor to Syria

INVESTIGATIONS