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Although U.S. export controls to Iraq were tightened up in the late 1980s, there were still many loopholes. In December 1988, Dow Chemical sold $1.5 million of pesticides to Iraq, despite U.S. government concerns that they could be used as chemical warfare agents. An Export-Import Bank official reported in a memorandum that he could find "no reason" to stop the sale, despite evidence that the pesticides were "highly toxic" to humans and would cause death "from asphyxiation."

(Source: Washington Post, 12/30/02)