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Uranium One is an international group of companies, part of the management circuit of the TENEX Group of Rosatom State Corporation. Since 2013, it is a wholly owned subsidiary of Moscow-based Uranium One Group, a part of the Russian state-owned nuclear corporation Rosatom.[2]

Key Information

History

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The company was established as Southern Cross Resources Inc. on January 2, 1997, in Toronto, Canada. It was listed on the Toronto Stock Exchange on August 25, 1997. In 2005, Southern Cross Resources Inc. reverse merged with South African Aflease Gold and Uranium Resources Ltd. under the name SXR Uranium One Inc.[3][4] After merger, the company received secondary listing on the Johannesburg Stock Exchange. Aflease Gold and Uranium Resources Ltd. became a subsidiary of SXR Uranium One and was renamed Uranium One Africa Ltd. The main uranium asset of Aflease was the Dominion mine.[4] The gold assets of Aflease were divested by 2008 and Uranium One Africa was sold in 2010 to Gupta family.[5]

In 2007, Uranium One Inc. acquired UrAsia Energy Ltd. And a 70% stake in the Akdala and South Inkai uranium mines, as well as a 30% stake in the Kyzylkum venture in Kazakhstan. In June 2009, JSC Atomredmetzoloto (ARMZ), a subsidiary of Rosatom, acquired a 16.6 percent stake in Uranium One in exchange for a 50 percent stake in its joint venture with Kazatomprom[citation needed] Karatau.

In the same year, Uranium One bought the Shootaring Uranium Mill from the United States Enrichment Corporation. It was sold to Anfield Energy in 2015.[6] Also in 2007, Uranium One acquired Energy Metals Corporation which owned the Hobson uranium processing plant in Texas, and uranium exploration properties located in Wyoming and Texas. The Hobson uranium processing plant and assets in Texas were sold to Uranium Energy Corporation in 2009.[7]

In 2009, the Rosatom subsidiary ARMZ acquired 16.6% of shares in Uranium One in exchange for a 50% interest in the Karatau uranium mining project, a joint venture with Kazatomprom.[8] In 2010, Uranium One acquired 50% and 49% respective interests in southern Kazakhstan-based Akbastau and Zarechnoye uranium mines from ARMZ. In exchange, ARMZ increased its stake in Uranium One to 51%.[9][10] In 2010, Uranium One acquired Irigaray uranium processing plant, the Christensen Ranch satellite uranium processing facility and associated uranium exploration properties in the Powder River Basin in Wyoming from the joint venture of AREVA and Électricité de France.[11] In December 2010, ARMZ increased its stake in Uranium One to 51.4%. At the time of the 2010 sale, the U.S. Nuclear Regulatory Commission estimated that Uranium One held the rights to approximately 20% of the licensed uranium ore production capacity in the United States which in its entirety amounted to 0.2% of the world's uranium production.[12][13] By 2017 additional mining licenses had been issued to other operators, shrinking Uranium One's share of U.S. production capacity to approximately 10%.[12]

ARMZ took complete control of Uranium One in January 2013 by buying all shares it did not already own.[2] In October 2013, Uranium One Inc. was delisted from the Toronto and Johannesburg exchanges and became a wholly owned indirect subsidiary of Rosatom.[14][15] From 2012 to 2014, an unspecified amount of Uranium was reportedly exported to Canada via a Kentucky-based trucking firm with an existing export license; most of the processed uranium was returned to the U.S., with approximately 25% going to Western Europe and Japan.[16][17] In 2015, Uranium One relocated certain head office functions such as finance, internal audit and some technical services to Moscow. In 2017, Uranium One established a trading company Uranium One Trading in Zug, Switzerland. However, in January 2018, trading functions of the company were transferred to Techsnabexport, an export arm of Rosatom.[18]

In 2010–2013, Uranium One acquired Mantra Resources, the developer of Mkuju River mine in Tanzania. The Mkuju River project was suspended in 2017 due to the low uranium price.[19] In 2015, Uranium One Australia, the owner of the Uranium One's Australian operations, including the Honeymoon Uranium Project, was sold to Boss Resources.[20][21] In August 2018, Uranium One closed its Willow Creek mine in Wyoming.[22]

In 2017, Uranium One Trading A. started its trading company. G in Zug, Switzerland. The company aims to increase its share in the international market by carrying out spot and medium-term trading in natural uranium.

At the end of 2019, Uranium One's mineral resource base is estimated at 512.7 thousand tons. Uranium production for the year amounted to 4,6 tonnes.[23]

In 2019, Uranium One's operations were transferred to TENEX (a global brand of TENEX).[24]

In the reporting year, the mineral resource base of Uranium One's enterprises according to international reporting standards was 192 thousand tons (197.1 thousand tons in 2018).[25]

In 2020, Uranium One made its first shipment of wood pellets to a customer in Italy. More than 3 thousand tons of products were delivered by sea.[26]

Operations

[edit]

Through its subsidiaries and joint ventures Uranium One owns Akdala, South Inkai, Karatau, Akbastau and Kharasan uranium mines in Kazakhstan, the conserved Willow Creek uranium mine in the United States, and the Mkuju River uranium project in Tanzania.[27] In Namibia, Uranium One Headspring Pty., a subsidiary of Uranium One, is conducting exploration work. Exploration and pilot works are planned until 2027.[citation needed]

In 2020, Uranium One sold 11.8 million pounds (5,400 t) of triuranium octoxide (U3O8).[28]

Uranium One is considering lithium mining projects in Chile, Argentina, and Bolivia.[29][30]

In 2020, Uranium One started to supply wood pellets produced in Russia.[31]

In June 2023, Bolivia signed an agreement with Rosatom through its Uranium One Group to develop its lithium reserves, which are the largest in the world. Uranium One will invest $600 million in the project and conduct the feasibility and pre-investment studies.[32]

Ownership

[edit]

Uranium One Inc. is an indirect subsidiary of the Russian state-owned nuclear corporation Rosatom. It is directly owned by the Amsterdam-based Uranium One Holding N.V. (89.07%) and Moscow-based Uranium One Group (former name: Uranium Mining Company; 10.93%). Uranium One Holding is wholly owned by Uranium One Group. Uranium One Group is owned by Rosatom direct subsidiaries Atomenergoprom (71.084%) and ARMZ (28.916%).[33] Uranium One Group is managed by Techsnabexport.[34]

Uranium One controversy

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Main article: Uranium One controversy

A conspiracy theory launched during the 2016 presidential election campaign accused Bill Clinton, the Clinton Foundation, Hillary Clinton, the Obama administration, high level officials in Russia, the State Department, Uranium One, and the FBI of allegedly compromising national-security interests, bribery, and suppressing evidence.[35][36][37] All parties have denied the accusations, and no evidence of wrongdoing has been found after five years of allegations, an FBI investigation, a House Intelligence Committee inquiry, and the 2017 appointment by the Justice Department of the U.S. Attorney in Utah, John Huber, to evaluate the FBI investigation.[35][36][37][38][39] Huber's inquiry ended in January 2019 without any findings of consequence.[39]

Activities

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Uranium exploration and mining

Uranium One is engaged in natural uranium mining, exploration and development of uranium deposits in Kazakhstan, the United States, Tanzania, and Namibia. The company produces about 4,6 thousand tons of natural uranium per year. Uranium One supplies natural uranium to energy companies in Europe, North America, and Asia.

Kazakhstan

Uranium One is a participant in six joint uranium mines with NAC Kazatomprom, the national nuclear corporation of Kazakhstan: Akdala, South Inkai, Karatau, Akbastau, Zarechnoye and Kharasan.[40]

See also

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References

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[edit]
Revisions and contributorsEdit on WikipediaRead on Wikipedia

Uranium One

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from Grokipedia
Uranium One Inc. was a Canadian-based and , established in 2005, that held assets and licenses primarily in , the , and , becoming a focal point of controversy due to its stepwise acquisition by , Russia's state-owned , between 2009 and 2013. The pivotal 2010 transaction involved Rosatom's subsidiary ARMZ purchasing a 51% in Uranium One, which required approval from the U.S. Committee on Foreign Investment in the (CFIUS) owing to the company's ownership of projects in representing an estimated 20% of installed U.S. capacity. CFIUS, chaired by the Department and including the State Department under Secretary , unanimously approved the deal despite concurrent FBI evidence from informant William Douglas Campbell documenting a Russian scheme by Rosatom officials to bribe their way into U.S. contracts starting in 2009. Compounding scrutiny, Uranium One's chairman Ian Telfer routed $2.35 million in undisclosed donations to the via his family foundation between 2009 and 2013, while early investor had previously contributed $31.3 million, and former President received a $500,000 speaking fee from a Russian investment promoting the deal in 2010. Rosatom achieved full ownership by 2013, though U.S. regulatory restrictions limited exports, and the American subsidiary's assets were divested to Uranium Energy Corp. in 2021, amid ongoing debates over whether the approval compromised U.S. or reflected undue foreign influence.

Corporate History

Formation and Early Expansion

Uranium One Inc. was established in 2005 as a Canadian listed on the , initially operating as a junior mining firm focused on and development. The company, originally known as sxr Uranium One Inc., targeted opportunities in uranium resources amid rising global demand for . Under the early leadership of Canadian mining financier , who had previously assembled UrAsia Energy Ltd. in 2005 to pursue uranium projects in , the firm emphasized acquiring undervalued assets in geopolitically stable regions with established mining frameworks. UrAsia quickly secured interests, such as a 30% stake in the Kyzylkum project for $75 million in 2005, leveraging 's position as a major producer. This approach aligned with broader strategies to build resource bases through targeted investments rather than greenfield exploration alone. Giustra served as non-executive chairman following key developments but divested his holdings in 2007. A pivotal early expansion occurred in February 2007 when sxr Uranium One announced the acquisition of UrAsia Energy Ltd. for approximately $3.1 billion in shares, completed in 2007, creating a mid-tier with consolidated assets primarily in . The merger enhanced production potential and diversified holdings, positioning the enlarged entity for further growth in operations outside . By 2009, Russian state-owned ARMZ Uranium Holding Co., a subsidiary of , acquired a 17% minority stake in Uranium One through a swap involving a 50% interest in the Karatau uranium project in , marking initial foreign investment without altering majority control.

Key Acquisitions and Growth Phase

In 2007, Uranium One significantly expanded its portfolio through the acquisition of UrAsia Energy Ltd. for approximately $3.1 billion, a transaction completed in that integrated UrAsia's substantial Kazakhstan-based assets into the company. This deal provided Uranium One with a 70% stake in the Betpak Dala with , encompassing the Akdala and South Inkai deposits, which employed in-situ recovery (ISR) techniques to extract from sandstone-hosted orebodies. Akdala commenced production in 2006, while South Inkai initiated trial operations in 2007, contributing to early production ramp-up through ISR methods that minimized surface disturbance and enabled scalable output. Further growth in included the establishment of the Kyzylkum (Kharasan 1 project), in which Uranium One held a 30% interest alongside (30%) and EnergyAsia (40%), with pilot production starting in . These expansions, combined with the Betpak Dala assets, boosted Uranium One's attributable reserves to over 50,000 tonnes of by , driven by measured and indicated resources at South Inkai (13,000 tU), Akdala (10,359 tU total resources), and Kharasan 1 (15,693 tU measured plus 17,940 tU inferred). In , production from these Kazakh operations reached approximately 1,876 tU, equivalent to roughly 2,200 tonnes of U3O8, reflecting the efficacy of ISR in achieving commercial-scale extraction amid rising global demand. Concurrently, Uranium One entered the North American market by acquiring Energy Metals Corp. in 2007 for $50 million plus royalties, gaining control of Wyoming-based assets under its subsidiary Uranium One Americas Inc. These included ISR projects in the , such as Willow Creek, with total resources exceeding 6,500 tU, positioning the company to leverage low-cost ISR for future domestic production capacity potentially up to 1,400 tU annually. This acquisition diversified Uranium One's geographic footprint and enhanced its technical expertise in ISR, aligning with the late-2000s surge in uranium exploration and development.

Rosatom Acquisition Process

In June 2010, JSC Atomredmetzolot (ARMZ), a subsidiary of Russia's state-owned , entered into an agreement to acquire a 51 percent controlling stake in Uranium One Inc., a Canadian with uranium assets primarily in and the . The transaction structure involved ARMZ contributing approximately in cash directly to Uranium One shareholders, along with its 50 percent and 49 percent interests in the Akbastau and Zarechnoye uranium mines in , respectively, to Uranium One itself. This valued the overall deal at around $1.3 billion, granting ARMZ majority ownership while expanding Uranium One's resource base in . The acquisition closed on December 27, 2010, after which ARMZ held 51.4 percent of Uranium One's shares. To consolidate full control, ARMZ launched a on January 14, 2013, for all remaining Uranium One common shares it did not already own, at a price of C$2.86 per share in cash. This offer represented a premium over recent trading prices and implied a total transaction value of approximately $1.3 billion for the minority stake. Uranium One shareholders approved the going-private transaction on March 7, 2013, leading to the company's delisting from the and conversion into a private entity fully owned by ARMZ. Following the completion, Uranium One was integrated as a key component of ARMZ's global operations, which serve as 's mining arm responsible for production outside . This incorporation provided with diversified access to Uranium One's established reserves and production assets in non-Russian jurisdictions, including and legacy interests in the United States, bolstering its position in international supply chains without reliance on domestic sources alone.

Operations and Assets

Primary Mining Operations

Uranium One's primary mining operations center on following the 2013 acquisition by , where in-situ recovery (ISR), also known as in-situ leaching, serves as the core extraction technique across its key assets. ISR entails drilling injection and production wells into sandstone-hosted deposits, circulating an acidic or alkaline leaching solution to solubilize in place, and recovering the pregnant solution for ion-exchange processing at surface facilities. This approach leverages the region's hydrogeological conditions, including permeable aquifers at depths of 200-600 meters, enabling efficient extraction without large-scale excavation. Compared to , ISR minimizes surface land disturbance, piles, and dust emissions, though it requires rigorous monitoring to manage potential migration of leachates beyond the ore zone. Logistically, operations involve phased wellfield development—typically in five-spot or nine-spot patterns for optimal flow dynamics—and supply chains, often sourced locally or via joint ventures, to sustain leaching efficiency at recovery rates of 70-80%. Kazakhstan's ISR dominance, accounting for over 50% of global output by volume in the , aligns with Uranium One's model by prioritizing low operating costs, estimated at $15-25 per pound U3O8 during peak periods, through modular processing plants and minimal capital-intensive . The principal sites—Akdala, Karatau, and Zarechnoye—form the backbone of production, with these ISR fields yielding the bulk of output via joint ventures with . Akdala, operational since 2009, features roll-front deposits amenable to alkaline leaching; Karatau emphasizes acid-based ISR for higher-grade zones; and Zarechnoye integrates advanced well monitoring for sustained yields. These locations collectively drove annual production to a peak of approximately 6,000 tonnes U3O8 equivalent in 2017, supported by wellfield expansions and optimized pumping regimes before market-driven curtailments.

Production Capacity and Key Projects

Uranium One's mining operations in utilize in-situ recovery (ISR) techniques, with total production capacity across its key projects reaching several thousand tonnes of (tU) annually prior to adjustments for market conditions. The company's output from these assets has historically represented a notable share of Rosatom's global supply, derived primarily from high-grade deposits in the Chu-Sarysu and Syrdarya basins. The South Inkai project stands as a core high-grade ISR operation, initiating trial production in 2007 and ramping up to a designed capacity of approximately 1,900 tU per year by 2011. In 2022, the South Inkai 4 section of the project yielded 1,600 tU, reflecting operational efficiency in extracting from sandstone-hosted roll-front deposits via acid leaching solutions. This facility's high ore grades enable competitive recovery rates, with wellfield development focused on phased saturation and processes to optimize yield. Supporting projects include Akdala, Kharasan, and Zarechnoye, which function as satellite operations to bolster overall throughput. Akdala and Kharasan employ similar ISR methods on roll-front mineralization, with historical contributions scaling to hundreds of tU annually per site during active phases. Zarechnoye, operated as a , added diversified output until recent stake divestitures, emphasizing modular wellfield expansion for sustained extraction. These projects collectively enable Uranium One to maintain flexible production scaling based on uranium demand and pricing. Amid the 2014-2016 uranium market downturn, when spot prices fell below per pound U3O8 due to post-Fukushima oversupply, Uranium One suspended operations at select sites including Kharasan to conserve resources and avoid uneconomic extraction. Resumptions occurred as prices recovered, allowing reactivation of wellfields while prioritizing higher-grade zones to align with long-term reserve management.

Resource Holdings and Reserves

Uranium One's reserves as of mid-2013 were predominantly located in , with NI 43-101 certified proven and probable reserves totaling approximately 70,000 tonnes U3O8 equivalent on an attributable basis. These holdings were supported by technical reports filed in December 2013 for key projects such as Karatau and Akbastau, confirming economic viability through sandstone-hosted deposits suitable for in-situ recovery (ISR).
ProjectProven and Probable Reserves (tU)Extraction MethodNotes
Karatau (Budenovskoye 2)51,960ISRAttributable share reflects with .
Akbastau (Budenovskoye 1, 3, 4)31,600ISRHigh-grade roll-front deposits; combined measured and indicated resources of 47,293 tU.
Kharasan 17,132ISRSupporting measured and indicated resources of 8,561 tU.
Other (e.g., South Inkai, Akdala, Zarechnoye)~11,645 (combined)ISRLower individual contributions but additive to total portfolio viability.
The ISR-applicable reserves in offered geological and economic advantages over higher-cost conventional reserves in regions like and , with lower permeability requirements and reduced environmental disturbance enabling extraction at depths of 200-600 meters. Measured and indicated resources across these assets provided a buffer supporting 10-15 years of sustained production at rates of approximately 5,000-6,000 tU annually attributable to Uranium One. This resource base underscored the company's focus on low-cost, scalable ISR operations, distinct from capital-intensive conventional mining elsewhere in its portfolio.

Ownership and Corporate Structure

Pre-Acquisition Shareholders

Uranium One Inc. was publicly traded on the under the UUU, with ownership dispersed among a broad base of shareholders that included Canadian institutional investors and pension funds. The company's structure reflected typical public firms of the era, prioritizing diversified equity to fund exploration and development without concentrated control by any single entity prior to foreign stakes. Frank Giustra, a Canadian financier, founded UrAsia Energy Ltd. in 2005 and orchestrated its merger with Uranium One in 2007, positioning himself as an early major stakeholder and chairman. Giustra divested his holdings and resigned from associated board positions by late 2007, severing direct ties to the company. In June 2009, ARMZ Uranium Holding Co., a subsidiary of Russia's state-owned , acquired a minority 17% stake in Uranium One via a shares-for-assets deal involving cash and partial interests in Kazakh uranium projects, without obtaining board control or veto rights over operations.

Post-Rosatom Ownership Changes

Following the full acquisition by JSC ARMZ Uranium Holding Co. (a of ) in , Uranium One Inc. became a wholly owned entity under Russian state control, with ARMZ acquiring the remaining minority shares for approximately $1.3 billion in a privatization transaction. This completed the consolidation initiated in 2010, eliminating prior public shareholdings and integrating Uranium One directly into Rosatom's mining division structure. In late 2013, established Uranium One Holding NV (U1H) in the as a dedicated vehicle to manage its international uranium assets, positioning Uranium One as the operational arm for non-Russian ventures. This structure facilitated Uranium One's alignment with 's vertically integrated , whereby extracted concentrates from its global operations—primarily in , , and —supply raw material for Russia's conversion, enrichment, and fuel fabrication capacities, which account for about 46% of global enrichment services. Under ownership, Uranium One's production contributed to fuel assemblies delivered to over 70 commercial reactors worldwide, enhancing 's role as a key supplier in the international nuclear market without altering the core ownership framework. No material dilutions of control, equity spin-offs, or third-party stake infusions occurred in the subsequent decade, maintaining undivided oversight until targeted asset adjustments elsewhere.

Recent US Asset Divestiture

In November 2021, Uranium One, a of Russia's , agreed to sell its U.S.-based Uranium One Americas Inc. to Uranium Energy Corp., a Texas-based company. The share purchase agreement was executed on November 8, 2021, for a total consideration of approximately $131 million, comprising $112 million in and the replacement of $19 million in bonds held by Uranium One. The transaction closed on December 20, 2021, fully funded by Uranium Energy Corp.'s existing reserves of over $120 million post-closing. The divested assets included Uranium One Americas' portfolio of uranium projects primarily in Wyoming's , encompassing seven in-situ recovery projects, three of which were past-producing mines such as Willow Creek. These holdings represented a significant portion of undeveloped and permitted resources in the U.S., with estimated measured and indicated resources exceeding 50 million pounds of U3O8 equivalent prior to the sale. The acquisition positioned Uranium Energy Corp. as the largest company in the Americas by resource base. This sale marked Rosatom's exit from direct ownership of U.S. operations, transferring control of these assets to a domestic entity and reducing foreign influence over domestic production capacity, which had previously accounted for up to 20% of U.S. potential under Russian-linked ownership. The divestiture aligned with contemporaneous U.S. policy emphases on enhancing domestic uranium supply chains, including Department of Energy initiatives to procure millions of pounds of U.S.-sourced amid efforts to diversify away from Russian dependencies.

Regulatory Approvals and the 2010 Deal

CFIUS Review Mechanism

The Committee on Foreign Investment in the United States (CFIUS) is an interagency body chaired by the Department of the Treasury, tasked with reviewing foreign acquisitions of U.S. businesses or assets to assess potential risks, including threats to , technology, or supply chains. Composed of nine voting member agencies—encompassing the Departments of State, Defense, , , , and , along with the Office of the U.S. Trade Representative and the Office of Science and Technology Policy—CFIUS conducts evaluations through a structured process that emphasizes collaborative analysis across sectors like , defense, and . The review typically begins with a voluntary notification from transaction parties, followed by a 30-day initial assessment and, if risks are identified, a 45-day in-depth investigation involving input from all members to determine mitigation measures or recommend presidential intervention. In cases involving strategic resources such as , CFIUS scrutinizes foreign control over domestic production assets, as these could impact and supply chains. For the Uranium One transaction, the company's U.S. subsidiaries operated mines in that accounted for approximately 20% of the nation's installed uranium production capacity at the time, prompting a mandatory evaluation due to the sector's sensitivity under nuclear non-proliferation and frameworks. The multi-agency composition ensures diverse perspectives, with agencies like the Department of Energy assessing proliferation risks and the Department of Defense evaluating military implications, though decisions require unanimous consensus among voting members or referral to the President if unresolved. The State Department's single vote within CFIUS reflects its role in and export licensing, but the process's decentralized nature distributes authority to prevent any one agency from dominating outcomes, fostering rigorous debate on risks from state-owned foreign entities in extractive industries. Approvals hinge on evidence that transactions do not impair U.S. control over key resources, with CFIUS empowered to impose conditions like security agreements or asset ring-fencing to address vulnerabilities identified in joint assessments.

Timeline of Approvals and Conditions

In June 2009, ARMZ Uranium Holding Co., a subsidiary of Russia's state-owned , acquired a 17% minority stake in Uranium One, prompting an initial review by the Committee on Foreign Investment in the United States (CFIUS). On June 8, 2010, ARMZ announced an agreement to purchase additional shares, increasing its ownership to 51% and gaining effective control of the company, which held rights in the United States representing about 20% of U.S. production capacity at the time. The transaction underwent CFIUS review, which concluded with approval later in 2010 after the committee imposed specific mitigation conditions to address concerns. These included requirements that Uranium One's U.S. maintain a of American directors on its board and obtain explicit U.S. (NRC) licenses for any export of uranium produced from its American mines. Subsequent incremental share purchases by did not trigger a new CFIUS filing, as they fell below thresholds requiring review under then-applicable regulations. By October 2013, had acquired the remaining shares, achieving full ownership of Uranium One without additional CFIUS scrutiny. Post-approval NRC records indicate no approvals for shipments of or from Uranium One's U.S. facilities to , with any processed material remaining subject to domestic licensing restrictions that prohibited direct transfers to the acquiring entity. While some uranium was converted and exported to third countries like under separate NRC authorizations, these movements complied with existing export controls and did not involve Russian destinations.

Involved Agencies and Decision-Making

The Committee on Foreign Investment in the United States (CFIUS), chaired by the Department of the Treasury, led the interagency review of Rosatom's acquisition of Uranium One, evaluating risks associated with the transfer of control over U.S. uranium assets. Participating agencies included the Departments of Defense, , Homeland Security, State, , and , reflecting a decentralized assessment process where each agency analyzed risks within its expertise—such as Defense reviewing potential military supply vulnerabilities, examining implications, and assessing threats—prior to collective deliberation. No individual agency held veto authority; instead, CFIUS operates on a consensus basis, with the Treasury Secretary empowered to suspend or block transactions if unresolved concerns persist, though confirm unanimous approval of the Uranium One deal on October 21, 2010, without documented objections from any member. This multi-agency involvement distributed responsibility across the executive branch, mitigating reliance on any single department's perspective. Approval incorporated binding conditions via agreements, including prohibitions on foreign personnel accessing sensitive U.S. operations and requirements for CFIUS notification before any downstream ownership transfers exceeding specified thresholds. Complementing this, the (NRC) maintained independent oversight of Uranium One's existing U.S. licenses for uranium recovery, enforcing restrictions that barred issuance of new licenses to foreign-controlled entities and preserved U.S. regulatory control over mining and milling activities.

Controversy and Allegations

Clinton Foundation Donations Timeline

, founder of UrAsia Energy—which merged with Uranium One in 2007—donated $31.3 million to the in 2006, following UrAsia's 2005 uranium mining agreement in arranged after a trip with . These contributions preceded both the Russian acquisition of Uranium One stakes starting in 2009 and Hillary Clinton's January 2009 appointment as . From 2008 to 2010, investors affiliated with Uranium One and its predecessor UrAsia contributed an additional $8.65 million to the foundation, overlapping with ARMZ (a subsidiary)'s initial minority stake purchases in the company beginning in 2009. In June 2010, as ARMZ announced its purchase of a 17.4 percent stake in Uranium One, received a $500,000 fee for a speech in sponsored by , a Russian that had promoted Uranium One shares and advised on related transactions. Between 2009 and 2013—spanning the full Russian takeover of Uranium One—executives including chairman Ian Telfer donated approximately $2.35 million to the foundation, with Telfer's contributions exceeding $2 million during this period. Overall, donors linked to Uranium One shareholders reportedly gave $145 million to the foundation across the deal's timeline, though the majority stemmed from pre-2009 pledges like Giustra's.

Claims of Pay-to-Play Influence

Critics, including conservative commentators and investigators, have asserted that , as U.S. from 2009 to 2013, exerted influence over the Committee on Foreign Investment in the United States (CFIUS) to approve Rosatom's acquisition of Uranium One in exchange for financial benefits to the . These allegations posit a , where State Department advocacy—despite its role in CFIUS deliberations—facilitated the deal granting control over uranium mining assets representing about 20% of U.S. production capacity. Proponents argue that Clinton's department's involvement, including reported communications with Canadian officials involved in the transaction, aligned suspiciously with Foundation interests. The timing of contributions from Uranium One-linked individuals has been cited as of influence peddling. Between 2009 and 2013, during Rosatom's phased takeover of Uranium One through three transactions culminating in full control by 2013, executives and investors associated with the company, including chairman Ian Telfer, donated roughly $2.35 million to the ; these included $1.3 million from Telfer alone via his family foundation. Critics highlight that such donations resumed after a lull following earlier pledges, coinciding with key approval milestones, and note the Foundation's policy of accepting foreign donations despite Clinton's pledge to disclose them. Further scrutiny focuses on a $500,000 speaking fee paid to former President in June 2010 by , a Russian that was publicly promoting Uranium One stock and underwriting related share offerings. This payment occurred weeks before CFIUS's October 2010 approval of 's majority stake, amid reports that Clinton sought State Department clearance for meetings with officials around the same period. Allegations suggest the fee, unusually high for Clinton's post-presidency speeches in , served as an indirect benefit tied to the deal's progression. Investigative author amplified these claims in his 2015 book : The Untold Story of How and Why Foreign Governments and Businesses Helped Make Bill and Hillary Rich, framing the Uranium One saga as emblematic of a pattern where access to Clinton's influence correlated with Foundation funding. Schweizer detailed how the intertwined timelines of donations, speeches, and approvals raised questions of dynamics, influencing subsequent media coverage and political discourse on conservative outlets.

FBI Informant and Russian Bribery Evidence

William D. Campbell served as a confidential FBI from 2010 to 2013, tasked with investigating Russian nuclear industry activities, including schemes tied to Uranium One's Kazakhstan operations. His reporting focused on involving executives from Rosatom subsidiary ARMZ and Uranium One, who allegedly paid bribes to secure uranium mining contracts in . These activities predated Rosatom's full acquisition of Uranium One, occurring primarily between 2009 and 2011. Campbell documented evidence of over $2 million in bribes funneled through shell companies in , , and to Kazakhstani officials, aimed at influencing uranium mine access and control. The scheme involved Russian efforts to dominate uranium resources via Uranium One's Kazakh assets, which included joint ventures like the South Inkai mine operated with . Court records and informant materials described kickbacks, , and tactics employed by Rosatom-linked entities to expand influence without full ownership at the time. In congressional interviews, Campbell testified that his findings revealed no of U.S. officials and no connections to or the . He emphasized that the corruption centered on Russian and Kazakh entities, with no evidence of involving American decision-makers in the CFIUS approval process. This testimony, drawn from declassified summaries, underscored the probe's focus on foreign graft rather than domestic influence.

Investigations and Outcomes

DOJ and FBI Probes

The FBI initiated an undercover investigation in into a and scheme involving executives from Tenex, a subsidiary of Russia's state-owned , which sought to expand influence in the U.S. nuclear sector. The probe, active during the 2010 Uranium One acquisition approval, uncovered evidence that Russian officials paid approximately $2.35 million in bribes to a U.S. transportation company executive between 2009 and 2014 to secure contracts for transport and storage. FBI confidential human source William D. Campbell, who posed as a lobbyist, gathered recordings and documents detailing these illicit payments, but the investigation did not pursue allegations tying the scheme directly to the Committee on Foreign Investment in the United States (CFIUS) review process. The FBI's probe culminated in the November 2015 guilty plea of Tenex executive Vadim Mikerin to and charges, with sentencing deferred as part of a broader case; however, it concluded in 2014 without indictments or charges related to the Uranium One deal's approval or any U.S. government officials involved in CFIUS. Federal prosecutors later confirmed the scheme focused on commercial contracts rather than the acquisition itself, and no evidence emerged during the investigation linking the to influence over regulatory approvals. In November 2017, amid congressional scrutiny, Attorney General Jeff Sessions directed the DOJ to review prior Uranium One-related records and assess potential grounds for further action, including possible scrutiny of Clinton Foundation activities. The DOJ permitted Campbell to be debriefed by Senate Judiciary Committee staff in late 2017, where he testified under immunity but provided no evidence of quid pro quo arrangements involving Hillary Clinton, the State Department, or CFIUS decisions. DOJ officials concluded there was insufficient basis to prosecute Clintons or others for influencing the deal, and no charges were filed following the review.

Congressional Inquiries

In October 2017, the House Committee on Oversight and Government Reform, chaired by Representative (R-SC), and the House Permanent Select Committee on Intelligence, chaired by Representative (R-CA), announced a joint investigation into the Uranium One deal, focusing on the FBI's and Department of Justice's handling of allegations of Russian in the nuclear sector during the 2010 CFIUS review process. The probe examined whether executive branch agencies adequately shared informant-derived intelligence on bribery attempts involving subsidiaries and Uranium One executives with CFIUS members prior to approval. The committees conducted a closed-door with FBI confidential human source William D. Campbell on February 13, 2018; Campbell, who had gathered evidence from 2007 to 2013 on Russian efforts to influence U.S. approvals through bribes and kickbacks, testified that the FBI sought ongoing updates from him even after the deal's approval but provided no testimony linking , the State Department, or donations to the transaction's outcome. Republicans highlighted discrepancies in the timeline of Campbell's reports—some predating the CFIUS vote—and accused the DOJ of withholding key details from , while Democrats noted the interview yielded no substantiation for claims of political interference. In the , Committee Chairman (R-IA) initiated scrutiny by requesting on October 19, 2017, that the DOJ lift a non-disclosure agreement on Campbell to allow his full cooperation with congressional investigators and calling for a to examine the deal alongside activities. On November 14, 2017, Grassley directed the DOJ to preserve all records related to the FBI's parallel probe into Russian bribery in the industry, citing concerns over potential suppression of evidence during the acquisition review. Grassley issued further requests, including to the on October 12, 2017, for assessments of risks in the transaction, and to the DOJ on November 30, 2018, regarding investigative steps on ties. These inquiries reflected partisan tensions, with Republicans alleging executive branch opacity and conflicts of interest undermined transparency, whereas Democrats maintained the efforts recycled unsubstantiated allegations without yielding novel evidence of misconduct in the approval process.

Key Findings and Lack of Charges

Investigations by the Department of Justice (DOJ) and (FBI), including a review led by U.S. Attorney John Huber appointed in to examine -related matters and Uranium One, concluded without any indictments or charges against U.S. officials, principals, or parties involved in the Committee on Foreign Investment (CFIUS) approval process. The FBI's parallel probe into Russian nuclear sector activities, which began prior to the 2010 deal, uncovered a scheme involving Tenex—a —where Russian Vadim Mikerin and associates extorted and defrauded U.S. companies for contracts between 2009 and 2014, leading to Mikerin's guilty plea in 2015 on charges; however, this was unrelated to the Uranium One acquisition or CFIUS deliberations, with FBI William Campbell testifying he possessed no evidence linking the scheme to influence over the deal or donations. CFIUS internal documents from the 2010 review, involving nine agencies including the State Department, reflect unanimous approval of the acquisition without any formal objection or veto recommendation from State, and no evidence of atypical influence or deviation from standard procedures. Following the approval, Uranium One's U.S. mining and milling operations persisted under ownership through 2021, subject to (NRC) oversight that prohibited uranium exports to without specific licenses—none of which were issued or violated during this period, ensuring no material transfer contravened deal conditions.

Criticisms from National Security Perspective

Risks of Russian Control Over US Assets

The acquisition of Uranium One by , Russia's state-owned nuclear energy corporation, granted a foreign adversary control over domestic assets critical to the U.S. . , established in 2007 under direct oversight of the Russian government, maintains deep integration with the country's military-industrial complex, including production of systems for and icebreakers, as well as contributions to the defense sector's and technologies. This structure enables potential dual-use applications, where civilian operations could facilitate intelligence gathering or technology transfers beneficial to Russian strategic interests, particularly given Rosatom's subsidiaries' provision of armaments and components to Russia's defense industry. Uranium One's U.S. holdings, primarily in Wyoming's , encompassed approximately 20% of licensed U.S. capacity at the time of the deal, though actual output contributed only 5-10% of domestic production due to depressed market prices and idled operations. Russian control introduced vulnerabilities such as access to proprietary geological surveys, reserve data, and operational expertise, which could inform Moscow's assessments of U.S. or enable subtle influence over future extraction decisions. Pre-full divestiture phases allowed Rosatom personnel or affiliates proximity to U.S. sites, raising concerns over infiltration or potential in a geopolitical , as evidenced by Rosatom's later documented roles in tactics. Such transfers deviated from post-Cold War U.S. policy norms prioritizing retention of strategic minerals against adversarial , as articulated in frameworks emphasizing supply chain resilience for nuclear deterrence and power generation. Empirical risks materialized in heightened dependence dynamics, where even marginal foreign sway over in-situ resources could amplify leverage during supply disruptions, contrasting with deliberate U.S. efforts to diversify away from Russian dominance observed in global markets. This control persisted until partial mitigations post-2013, underscoring causal pathways from asset to potential economic or advantages for an entity intertwined with Russian state apparatus.

Uranium Supply Chain Vulnerabilities

The United States relies on imports for approximately 95% of the uranium purchased by its nuclear power plant operators, with domestic production accounting for only a small fraction of requirements as of 2022. This dependence extends across the nuclear fuel cycle, including uranium concentrate, where foreign sources supplied 99% of needs in 2023 according to the U.S. Energy Information Administration. The Uranium One acquisition by Rosatom in 2010 and its completion in 2013 integrated significant mining assets, particularly in Kazakhstan—a country producing about 43% of global uranium—into Russian state-controlled operations, thereby enhancing Rosatom's influence over a key segment of the international supply chain. Rosatom, through subsidiaries like ARMZ Uranium Holding Co., gained control over Uranium One's reserves and production facilities, which at the time represented a notable portion of non-Russian global output, amplifying Russia's leverage in despite its direct production share being around 6-7% worldwide. This structure introduced causal vulnerabilities by concentrating decision-making authority over substantial reserves in an entity aligned with Russian geopolitical interests, potentially enabling supply disruptions or price manipulations during conflicts. For instance, amid the 2014 annexation of and ensuing sanctions, Russian entities could theoretically redirect or withhold Kazakh-sourced uranium—exported globally as concentrate—exacerbating shortages in import-dependent markets like the U.S. While empirical data shows limited actual exports of from U.S.-based Uranium One assets to post-deal, the ownership transfer posed a latent of broader interference through control of high-grade reserves in , where Rosatom's joint ventures facilitate export dependencies. Such control could manifest as strategic withholding, as evidenced by 's later restrictions on exports to the U.S. in November 2024, highlighting the precedent for using assets as leverage in dynamics. This theoretical disruption potential underscores the deal's contribution to U.S. vulnerabilities, given the inelastic demand for in powering roughly 20% of the nation's via nuclear reactors.

Broader Geopolitical Ramifications

The intensified bipartisan skepticism toward Russian involvement in the U.S. nuclear sector, amplifying long-standing concerns about dependency on adversarial suppliers for critical materials. Although the deal itself transferred mining rights rather than processed fuel, it symbolized perceived vulnerabilities in allowing —Russia's state-owned nuclear corporation—to gain footholds in Western assets during a period of deteriorating U.S.- relations post-2008 Georgia . This distrust manifested in policy actions to curtail Russian influence, including repeated congressional efforts from 2017 onward to impose sanctions on uranium imports, culminating in heightened scrutiny amid the 2022 conflict. A direct ramification was the acceleration of measures to ban Russian uranium imports, addressing the fact that supplied approximately 20% of U.S. needs by the early 2020s despite the Uranium One assets representing only about 10% of domestic production capacity. In May 2024, President Biden signed the Prohibiting Russian Uranium Imports Act, effective August 2024, which prohibits low- imports from until 2040, with limited waivers for supply shortages; this unlocked $2.72 billion in funding to bolster domestic production. While triggered proximally by the Ukraine war, the Uranium One episode provided evidentiary fodder for proponents arguing that earlier complacency enabled such leverage, as Russian exports had continued unabated despite known schemes involving Uranium One executives convicted in 2014 and 2015. The deal exposed structural gaps in the Committee on Foreign Investment in the United States (CFIUS) framework, particularly its limited purview over incremental foreign acquisitions that evade full scrutiny by not triggering immediate control thresholds. Rosatom's stepwise purchases—from 17% stake in 2009 to control by 2013—bypassed comprehensive review until the final phase, highlighting how partial investments can consolidate power without proportional oversight. This prompted the 2018 Foreign Investment Risk Review Modernization Act (FIRRMA), which broadened CFIUS jurisdiction to include non-controlling investments in and technology, enabling earlier intervention in serial acquisitions; Uranium One served as a in congressional debates underscoring the need for proactive in strategic sectors. From a vantage, conservative analysts and congressional investigators have framed the affair as emblematic of , where potential conflicts involving high-level officials undermined rigorous vetting, prioritizing financial inflows—such as $145 million in pledges from Uranium One investors between 2007 and 2013—over safeguarding reserves amid Russia's nuclear saber-rattling. This perspective posits causal links between lax approvals and emboldened Russian assertiveness, informing lessons on insulating review processes from donor influence and mandating transparency in foreign deals tied to political figures. Empirical outcomes, including no prosecutions despite FBI evidence of Russian , reinforce arguments for institutional reforms to prevent recurrence, emphasizing causal realism in linking opaque transactions to eroded deterrence.

Defenses and Counterarguments

Absence of Direct Evidence of Quid Pro Quo

The U.S. Department of Justice and Federal Bureau of Investigation probes into the Uranium One transaction, spanning from 2009 through at least 2017, uncovered a Russian bribery scheme involving Rosatom subsidiary executives but yielded no evidence of a quid pro quo arrangement benefiting U.S. officials, including Hillary Clinton or the Clinton Foundation. Key to this conclusion was testimony from FBI confidential informant William D. Campbell, who gathered evidence on illicit payments by Russian nuclear official Andrei Mikerin starting in November 2009 for U.S. transport contracts; Campbell explicitly stated that these activities did not involve U.S. government officials, the Committee on Foreign Investment in the United States (CFIUS), or influence over the 2010 approval of Rosatom's acquisition. Donations to the from Uranium One investors, totaling approximately $145 million between 2005 and 2013, lacked demonstrable causal links to the CFIUS decision, with major contributions predating the Russian acquisition phases. , a primary donor who pledged $31.3 million in 2007 following his 2005 Kazakhstan mining venture, divested his entire stake in Uranium One (via merger predecessor UrAsia Energy) by June 2007, well before Rosatom's initial 2009 investment or the October 2010 CFIUS review. Subsequent donations from Uranium One chairman Telfer and associates occurred amid the multi-phase deal but were not flagged in investigations as conditioning approval, with no records indicating they altered agency deliberations. The State Department's role in CFIUS, one of nine voting agencies, did not position it as the decisive authority, and no contemporaneous emails, documents, or witness accounts surfaced showing Hillary Clinton's direct intervention to sway the unanimous approval. Federal inquiries, including those prompted by congressional Republicans in 2017, reviewed informant files and agency communications but closed without indictments or referrals tied to personal corruption by the Clintons, attributing the absence to insufficient linkage between foreign bribes and domestic decision-making.

Multi-Agency Approval Process

The acquisition of Uranium One by underwent review by the Committee on Foreign Investment in the United States (CFIUS), a multi-agency body chaired by the that assesses foreign investments for national security implications. The committee comprises nine agencies: , State, Defense, , , , , the Office of the U.S. Trade Representative, and the Office of Science and Technology Policy. This structure ensures no single agency dominates decision-making, as consensus is required for approval or referral to the president for potential blockage. CFIUS approved the transaction unanimously on October 21, 2010, following a standard 30-day review with no extensions or objections leading to mitigation demands or presidential intervention. The Departments of Energy and Defense, which hold specialized veto authority over nuclear-related risks under their statutory mandates, participated fully and raised no impediments, reflecting their assessment that the deal posed no unacceptable threats to proliferation or . This diffused oversight counters claims of singular influence, as any veto would have halted the process absent overrides. Separate from CFIUS, the U.S. (NRC) amended source material licenses for One's U.S. operations on December 22, 2010, explicitly barring foreign control over licensed activities. Conditions required that Uranium One Americas Inc., the U.S. licensee, retain independent decision-making on operations, reporting, and compliance, with NRC ensuring no transfer of effective control to without prior approval. These safeguards maintained U.S. regulatory dominion over uranium handling, independent of ownership changes. Precedents for such approvals exist in prior CFIUS reviews of foreign uranium investments, including incremental stakes in Uranium One dating to under the Bush administration, which proceeded without blockage. The process's consistency across administrations underscores its role in balancing economic openness with security vetting, absent evidence of procedural irregularities in this case.

Limited Actual Uranium Transfer

Following the 2010 acquisition of Uranium One by , no bulk shipments of from U.S. mines were exported to , as raw ore is not commercially viable for long-distance transport and requires processing into (yellowcake) under strict U.S. regulations. Any potential exports of yellowcake from Uranium One's U.S. operations—primarily in —were subject to case-by-case licensing by the U.S. (NRC), which prohibits transfers that could undermine national interests. Available records show that post-deal yellowcake shipments were limited, commercially driven, and directed mainly to U.S. or European processors rather than , with no evidence of systematic diversion to Russian facilities. Uranium One's U.S. assets represented a minor fraction of domestic production capacity, contributing no more than 5.9% of total U.S. uranium output in recent years, while U.S. domestic mining as a whole supplied less than 10% of the nation's nuclear fuel requirements, the vast majority of which is imported from sources like Canada and Kazakhstan. This limited output—amid a global uranium market exceeding 140 million pounds of U3O8 annually—further diluted any potential strategic impact from Russian ownership, as uranium is a fungible commodity traded on international exchanges with diverse suppliers. In November 2021, Rosatom's Uranium One Group divested its U.S. operations by selling Uranium One Americas Inc., which held the mining assets, to Texas-based Uranium Energy Corp for an undisclosed sum, restoring full American control over these properties and eliminating any ongoing Russian influence on U.S. uranium extraction. This transaction, approved by U.S. authorities, underscored the transient nature of foreign involvement in the deal's aftermath.

Current Status and Legacy

Post-2021 Developments

In November 2021, Rosatom's Uranium One Group agreed to sell its U.S. subsidiary, Uranium One Americas Inc., to Texas-based Uranium Energy Corp (UEC) for approximately $13.9 million plus royalties, completing the divestiture of Russian-owned uranium mining assets in the United States. The transaction, approved by U.S. regulatory authorities, transferred control of key Wyoming-based projects including the Willow Creek and Reno Creek deposits, ensuring that U.S. uranium production facilities previously linked to Uranium One returned fully to domestic ownership. By early 2022, this sale eliminated any remaining Russian equity stake in American uranium mining operations associated with the original 2013 deal, aligning with heightened U.S. scrutiny of foreign ownership in critical minerals amid geopolitical tensions. Following the divestiture, Uranium One, as a Rosatom subsidiary, redirected its primary operations to , where it maintains significant in-situ recovery (ISR) projects such as the Karatau and South Inkai fields, contributing to the country's status as the world's top producer at 39% of global supply in 2024. This shift has positioned the company to capitalize on 's projected 12% increase in output for 2025, driven by long-term contracts and expansions in ISR technology. No major operational disruptions or new regulatory challenges have emerged for Uranium One's Kazakh assets post-2021, reflecting stable joint ventures with local partners like . Uranium spot prices surged amid these developments, averaging $86 per pound U₃O₈ in 2024 and reaching a 2025 high of $82.63 per pound by late September, fueled by supply constraints and growing nuclear energy demand. Uranium One's Kazakh-focused production has benefited from this market upswing, supporting Rosatom's role in global supply chains without U.S. asset exposure. The company's activities align with broader trends in nuclear revival, including reactor restarts and new builds, though it has not been implicated in fresh controversies beyond routine market fluctuations.

Ongoing Operations Under Rosatom

Uranium One Group, a subsidiary of , maintains active production primarily through in-situ recovery (ISR) operations at multiple joint ventures in , including the Akdala, Karatau, and South Inkai deposits. In 2023, these facilities yielded 4,831 tonnes of concentrate, contributing to 's closed by supplying raw material for conversion, enrichment, and fuel fabrication at Russian state-owned plants such as those operated by TVEL. Production levels in 2024 remained comparable, supported by ISR's advantages in minimizing environmental disruption and operational costs through of in place without surface excavation. The ISR methodology employed by Uranium One enhances efficiency by enabling high recovery rates—typically 60-70%—at lower capital and operating expenses compared to conventional , allowing sustained output amid fluctuating global prices. This output integrates directly into Rosatom's strategy for vertical control over the chain, where Kazakh-sourced undergoes processing to produce fuel assemblies for domestic reactors and contracts, bolstering Russia's position as a key supplier in the global market. Despite Western sanctions imposed on following Russia's 2022 invasion of , Uranium One's Kazakh operations continue under agreements with , adhering to International Atomic Energy Agency (IAEA) safeguards that verify non-diversion of material for military purposes. These safeguards, implemented via Kazakhstan's comprehensive IAEA agreement, include material accountancy and inspections at production sites, ensuring compliance even as faces export restrictions on enriched products to certain markets. Recent adjustments, such as partial divestments in assets like Zarechnoye to partners including Chinese firms, reflect strategic reallocations but do not halt core ISR-based production, with prioritizing resource optimization for long-term fuel security.

Implications for Global Uranium Markets

The Uranium One acquisition by in 2013 granted the Russian state corporation control over key assets in , enhancing Moscow's influence within a where the country produced approximately 43% of the world's in 2022. This positioned to leverage joint ventures and production shares from Uranium One's in-situ recovery operations, contributing to Russia's broader dominance in conversion (20%) and enrichment (46%) capacities prior to 2022 sanctions. Such consolidation amplified geopolitical risks, as disruptions in Kazakh output—often tied to Russian technical partnerships—could constrain global availability, with pre-sanctions exports underscoring Russia's ability to exert pricing and supply pressure on uranium-dependent nuclear utilities. The deal exposed structural vulnerabilities in market dynamics favoring state actors, where foreign approvals facilitated without offsetting measures for supply security. This causal pathway—enabling Russian expansion into high-output regions amid known operational irregularities—prompted retrospective policy shifts toward diversification, as unchecked consolidation risked weaponization of essential inputs. In response, the enacted a ban on Russian uranium imports effective 2024, accelerating domestic mine restarts and boosting concentrate production to 205,000 pounds U3O8 in 2024, the highest since 2018 and a twelvefold increase from prior lows. These developments illustrate lessons for future transactions: rigorous evaluation of cumulative market effects, rather than isolated procedural compliance, is essential to mitigate risks from state-driven monopolies. Heightened Western investment in alternative sources, including Australian and Canadian expansions, aims to dilute such leverage, though global demand growth from nuclear revival—projected to require 80,000-100,000 additional tonnes annually by 2040—underscores the need for proactive .

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