Red Flag: State Department Report on Russian New START Treaty Compliance

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The January 2025 State Department Report on Russian New START Treaty Compliance: A Preemptive Strike Against the Trump Administration

On January 17, 2025, the Department of State published a report on Russian New START Treaty compliance for the year 2024. The timing and content of this report are questionable, having been published at least several months before it should have been. It appears to be a last minute effort by the Biden Administration to coverup the full scope of Russian New START Treaty violations by pre-empting decisions rightfully belonging to the incoming Trump Administration. It is interesting to note that concurrent with the publication of this report, the State Department’s March 15, 2023, report on “Russian Noncompliance with and Invalid Suspension of the New START Treaty” vanished from the State Department’s website. (This author was able to find a copy still posted by the United States Embassy to Italy.)

Since the 2025 report covered the period up to December 31, 2024, it could not have been drafted in 2024 on a professional basis because it was necessary to evaluate a full year of Russian strategic nuclear activities before reaching any conclusions. This document responds to a legal requirement and, hence, normally is given a serious review before publication both with regard to the facts and the law. Short of a miracle, it could not be written in 2025 consistent with the normal drafting process. The Christmas/New Year holiday season, during which there is usually minimal government manning, extended to January 6^th, left only 10 working days to draft and publish a report which was not urgent. None of the other legally mandated noncompliance reports were produced on an accelerated basis. Hence, there had to be some reason to rush this report into print.

Any honest estimate of the number of deployed Russian nuclear warheads in 2024 had to be made in 2025 because Russia frequently deploys additional multiple warhead missiles just before the end of the year. For example, President Putin stated that 94% of Russian strategic nuclear forces had been modernized on October 29, 2024 and he said it had achieved 95% modernization on December 16, 2024. Putin’s statements imply that about five more Russian strategic missiles were deployed between October 29 and December 16. Also, the eighth Borei-class ballistic missile submarine was on sea trials[i] and it could have been armed. If armed, it would be New START accountable, and it could carry almost 100 nuclear warheads.

The 2025 State Department report stated:

The United States is unable to make a determination that the Russian Federation remained in compliance throughout 2024 with its obligation to limit its deployed warheads on delivery vehicles subject to the New START Treaty to 1,550, due to Russia’s proximity to the limit as of its last update and failure to fulfill its obligations with respect to the Treaty’s verification regime. The United States assesses with high confidence that Russia did not engage in any large-scale activity above the Treaty limits in 2024. However, Russia was probably close to the deployed warhead limit during much of the year and may have exceeded the deployed warhead limit by a small number during portions of 2024. Therefore, this constitutes a serious compliance concern.

The State Department’s recognition that Russia “…may have exceeded the deployed warhead limit by a small number during portions of 2024….” is new. However, it is probably a considerable understatement. The conclusion that, “The United States assesses with high confidence that Russia did not engage in any large-scale activity above the Treaty limits in 2024…” is unsupportable. Prior to the 2025 report, the annual State Department report had never asserted that the U.S. could make “high confidence” assessments concerning Russian compliance with the New START Treaty’s 1,550 deployed warhead limit. The “high confidence” claim is repeated three times in the 2025 report. Thus, this is clearly the message that the Biden Administration wanted to promulgate, reflecting its ideological pursuit of arms control. The motive appears to be to establish the precedent that a small substantive Russian New START Treaty violation does not matter, and the U.S. should continue unilateral compliance with the deeply flawed New START Treaty.

Russian Arms Control Noncompliance

There is nothing in the history of Russian compliance with arms control agreements that would suggest that after it violated the New START Treaty and illegally “suspended” it that it would comply with the substantive limitations of the Treaty. The Russian claim that it is abiding by the New START Treaty’s numerical limits appears to be self-serving disinformation designed to prevent U.S. declaration of a material breach of the Treaty. This would allow the United States to upload more nuclear weapons. Russia sees nuclear weapons and the nuclear balance as crucial to its standing as a global power.

Unfortunately, Russian violation of arms control agreements is the norm. Indeed, absent a serious penalty for cheating, Russia will cheat. In 2023, the bipartisan United States Strategic Posture Commission pointed out “…there is no prospect of a meaningful arms control Treaty being negotiated with Russia in the foreseeable future…” and that, “Over the past 20 years, Russia has either violated or has failed to comply with nearly every major arms control treaty or agreement to which the United States is or was a party.” The Commission report itself stated that the Obama Administration’s New START chief negotiator and former Under Secretary of State Rose Gottemoeller wrote the arms control section of the report and that it was cleared by the members of the Commission. The Commission’s conclusions were correct.

The Soviet Union violated arms control agreements from the very beginning of nuclear arms control in the 1960s. In 1987, President Ronald Reagan reported to the Congress that:

The Administration’s most recent studies support its conclusion that there is a pattern of Soviet noncompliance. As documented in this and previous reports, the Soviet Union has violated its legal obligation under, or political commitment to, the SALT I ABM Treaty and Interim Agreement, the SALT II Agreement, the Limited Test Ban Treaty of 1963, the Biological and Toxin Weapons Convention, the Geneva Protocol on Chemical Weapons, and the Helsinki Final Act. In addition, the USSR has likely violated provisions of the Threshold Test Ban Treaty.

The 2005 Department of State noncompliance report detailed important Russian violations of the 1991 START Treaty verification regime. However, the report, despite its great significance, was merely a snapshot in time rather than a complete discussion of the full scope of Russian START Treaty violations.

The 2014 report of the House Armed Services Committee noted:

According to the testimony of senior officials of the Department of State, the Russian Federation is not complying with numerous treaties and agreements, including the INF Treaty, the Open Skies Treaty, the Biological Weapons Convention, the Chemical Weapons Convention, the Vienna Document, the Budapest Memorandum, the Istanbul Commitments, the Presidential Nuclear Initiatives, the Missile Technology Control Regime, and the Russian Federation has recently withdrawn from the Treaty on Conventional Armed Forces in Europe (CFE).

For years, the Department of State bureaucracy fought against turning these judgements into formal government conclusions. Confirmation of these assessments finally appeared in the Trump Administration’s 2020 Noncompliance report which also added Russian nuclear testing treaty violations. The Trump Administration’s findings were confirmed in the 2021 Biden Administration’s New START Treaty report.

Why is the Department of State in Denial About Russian Nuclear Warhead Upload?

The Department of State is in the business of negotiations and it, like many arms control enthusiasts, sees insistence of arms control compliance as an impediment to new arms control negotiations.

Between 2011 and 2016, Russia, according to its own data, provided to and released by the Department of State, increased the number of its New START accountable nuclear warheads from 1,537 to just under 1,800. This increase was the only reason Russia had to make any reductions in deployed warheads under the New START Treaty. In order to comply with the New START Treaty (its limits began to apply in February 2018), since it did not reduce the number of its delivery vehicles, Russia had to download its strategic missiles, removing some of their warheads. Because of the continued Russian nuclear modernization, the additional warheads had to be downloaded every year. Hence, nuclear warhead upload is the easiest and cheapest way to increase Russia’s nuclear capability. This is the reason that multiple warhead missiles were developed in the first place.

A possible motive for the Department of State’s effort to deny large scale Russian nuclear warhead upload is contained in the Biden Administration’s “Report on the Nuclear Employment Strategy of the United States.” It states that, “The United States will abide by the central limits of the New START Treaty for the duration of the Treaty as long as it assesses that Russia continues to do so.” The Biden White House clearly did not want to increase the number of deployed U.S. nuclear warheads and probably feared that the Trump Administration might do so. Under the 2024 Biden Administration Nuclear Employment Strategy report the finding of a violation of the New START limitations would have triggered an escape clause from the Treaty. Apparently, once it became impossible to deny completely that Russia was violating the 1,550 deployed warhead limit (the most important of the “central limits”[ii]) the fallback position was apparently to deny the significance of the violation of the deployed warhead limit.

The Impact of Russian Termination of the Treaty Inspection Regime

If the United States could verify the number of deployed nuclear warheads on strategic missiles without on-site inspections, the Reagan Administration would never have insisted on the on-site inspection regime in the previous START and INF Treaties. It was an enormous challenge to secure Soviet agreement with those provisions. Satellites, reconnaissance aircraft, radars and other National Technical Means of Verification (NTM) systems provide much useful information about the potential of Russian missiles, but they cannot determine how many warheads are actually deployed on them, and, hence, whether Russian missiles were still being downloaded.

When Russia “suspended” its compliance with New START, the United States lost the entire New START Treaty verification regime. Indeed, the 2025 State Department report declares that the on-site warhead inspection regime “…plays an important role in assessing Russia’s compliance with the New START Treaty’s deployed warhead limit by providing information on Russia’s strategic offensive arms that national technical means (NTM) are not able to provide on their own.” If so, how can the State Department possibly make “high confidence” judgements on the scope of Russian nuclear warhead increases without any of the verification regime when it is not possible to do this even with the entire New START Treaty verification regime (which was not very good)?

In 2010, then-Senator Christopher Bond noted the serious problems with the New START verification regime. He stated that, “The Select Committee on Intelligence has been looking at this issue closely over the past several months. As the vice chairman of this committee, I have reviewed the key intelligence on our ability to monitor this treaty and heard from our intelligence professionals. There is no doubt in my mind that the United States cannot reliably verify the treaty’s 1,550 limit on deployed warheads.” Indeed, the 2025 State Department New START report itself acknowledges the limitations in the Treaty’s verification regime when it stated, “Resumption of inspection activities and provision of biannual data updates and notifications would not have eliminated all uncertainty regarding Russia’s precise number of deployed warheads under the New START Treaty in 2024.”

In 2019, Ambassador Marshall Billingslea, President Trump’s special envoy for arms control, observed that “…the Obama Administration negotiated a very weak verification regime. It really has very little of what the original START treaty contained and has significant loopholes in the way verification is physically conducted, which the Russians have been exploiting. So those behaviors also have to stop.”

The opposite actually happened under Biden. According to the Biden Administration, Russia has been violating the New START Treaty verification regime since 2022. A long list of these violations is included in the 2025 State Department report. Thanks to covid and subsequent Russian refusal to allow on-site inspections, the United States has not conducted an on-site inspection in Russia since March 2020. Furthermore, Russia ended providing New START Treaty required notifications in 2023. The Department of State’s asserted ability to make “high confidence assessments” contradicts the content of the 2025 report itself which states that, “Without Type One inspections [warhead counting inspections], the United States lacks the more detailed Treaty snapshots of the number of reentry vehicles on each deployed ICBM and SLBM at Russian nuclear bases and the onsite ability to confirm the actual number of reentry vehicles emplaced on up to ten ICBMs and SLBMs per Treaty year.” Ten on-site inspections a year equates to about 2% of deployed Russian strategic missiles.

The 2025 State Department report states that, “The United States has raised its concern regarding Russia’s compliance with the New START Treaty central limits on a number of occasions.” This information is new. Certainly, the previous State Department reports gave no indication of these actions. Indeed, the 2024 version of the report said that, “The United States assesses that the Russian Federation likely did not exceed the New START Treaty’s deployed warhead limit in 2023.”

The New START Treaty verification regime is substantially degraded from that of the original START Treaty. This makes “high confidence” judgements concerning deployed warhead numbers essentially impossible. Indeed, Rose Gottemoeller has pointed out “…we discarded the counting rules in favor of confirming declared warheads on the front of missiles through reciprocal inspections; in fact, we did not need telemetry measures to confirm compliance with the warhead limits in the new treaty.” Today, the United States lacks all of these assets. The absence of telemetry can degrade understanding of what Russia is testing. Counting rules are critical to counting warheads by national technical means of verification. The only thing the United States may have high confidence about is the maximum number of nuclear warheads Russian can deploy on the deployed missiles that are known to exist.

What are the implications of these loses in terms of potentially increased Russian deployed nuclear warheads above the Treaty limit? In December 2019, Gottemoeller cautioned that the United States may lose nuclear parity because, if freed from the New START warhead limit “…without deploying a single additional missile” Russia “could readily add several hundred – by some accounts, one thousand – more warheads, to their ICBMs.…” A 2023 study by this author estimated that it could be much higher. Warhead upload is the easiest and cheapest way to increase deployed nuclear weapons.

The loss of the original START Treaty-mandated Perimeter Portal Continuous Monitoring (PPCM) of mobile ICBM production in the New START Treaty makes the 2025 State Department assertion of “high confidence” even more dubious. The United States insisted on PPCM in the INF Treaty and the original START Treaty because it was essential for verification of the cessation of production of intermediate-range missiles and for the assessment of the number of Russian mobile ICBMs. This data was entirely lost when the START Treaty expired in 2009.

Under the START Treaty, U.S. inspectors monitored the destruction of all mobile ICBMs. This provision was not included in the New START Treaty. The Heritage Foundation pointed out, “Also gone [from New START] are the START requirements for ‘cooperative measures’ to enhance the capability of National Technical Means (NTM) to monitor mobile missiles at their bases (called ‘restricted areas’ in START I), the restriction on the size of ICBM bases, [and] the restriction on the size of deployment areas for road mobile ICBMs.”

If the United States does not have “high confidence” in number of Russian mobile ICBMs, it cannot possibly have “high confidence” in the number of deployed Russian nuclear warheads.

In 2024, Russia said it had completed the modernization of its mobile ICBM force. This modernization replaced single warhead SS-25 ICBMs with multiple warhead SS-27/RS-24 Yars ICBMs. Without on-site inspections, there would be a major unverifiable upload potential.

Since 2013, Colonel General Sergei Karakayev, Commander of the Strategic Missile Forces, has stated at least five times that Russia had approximately 400 ICBMs on “combat duty.”[iii] That is about 100 more missiles than is possible under Russia’s declared New START force levels.[iv] Karavayev’s statements suggest a covert Russian mobile ICBM force or rapid reload of mobile ICBM launchers. A covert mobile ICBM force is a Treaty violation while rapid reload is a circumvention.

In November 2024, the Defense Intelligence Agency report on “Nuclear Challenges” stated:

Russia has maintained the largest foreign nuclear stockpile in the world. Moscow maintains about 1,550 deployed strategic nuclear warheads on ICBMs and submarine-launched ballistic missiles (SLBMs), as well as a force of heavy bombers which are capable of carrying long-range air-launched cruise missiles (ALCMs). Under the New Strategic Arms Reduction Treaty (New START) counting rules, the heavy bombers count as one warhead each, but each bomber is capable of carrying eight or more air-launched cruise missiles.[v]

The implication of this assessment is that Russia is in violation of the 1,550 deployed warhead limit of the New START Treaty and it appears to be higher than the State Department’s conclusion. This aspect of the DIA report was ignored in the media.

It is clear from the DIA report that its assessment of about 1,550 deployed ICBM and SLBM warheads was based on assumptions that would tend to minimize the total number assessed. For example, the report states that the Russian Sineva SLBM (an improved SS-N-23) carries four warheads (the START Treaty accountability number for the older model of the SS-N-23.)[vi] The Sineva is an improved version of the SS-N-23 which can carry more warheads. The Liner (sometimes translated as Layner), is an enhanced version of the Sineva. According to Russian expatriate Pavel Podvig:

A new book published by the Makeyev Design Bureau…describes [the] Liner as a R-29RMU2.1 missile that can carry “up to ten low-yield warheads with missile defense penetration aids, or eight low-yield warheads with additional penetration aids, of four medium-yield warheads with penetration aids.”[vii]

In December 2022, Sputnik News reported that the Sineva and Liner SLBMs “…are armed with between 4 and 12 MIRV warheads, with firepower of between 100 and 500 kilotons.” Thus, the DIA assessment should be regarded as a minimum estimate.

The Liner is not an isolated issue. Almost all post-Cold War Russian strategic missiles are reported in the Russian press as being able to carry more warheads than they are credited with in the Federation of American Scientists’ annual reports on Russian nuclear forces. (The Department of Defense and the Intelligence Community usually provide almost no detailed public information on Russian nuclear capabilities.) Indeed, there is now proof that the Russian SS-18 heavy ICBM can carry 14 warheads, not the ten which it was limited to in the original START Treaty.[viii] To get the Russian strategic nuclear forces at or below 1,550 warheads, it is necessary to assume (without evidence) that Russian missiles have been downloaded to well below old START Treaty accountability numbers. For example, the Federation of American Scientists states (without any documentation) that, “It is estimated that the SS-18s now carry only five warheads each to meet the New START limit for deployed strategic warheads.” This would create an upload potential of almost a factor of three.

The November 2024 DIA report contained assumptions that reduced the number of assessed Russian deployed nuclear warheads. It indicated that, “The sea-based leg of Russia’s triad contains at least 10 SSBNs under operational control of the Naval High Command.”[ix] The “at least” formulation suggests that Russia has more than 10 missile submarines, although DIA is not sure if the additional submarines (Delta-IVs each carrying 16 Sineva/Liner missiles) are operational. The DIA assessment leaves three Delta-IV submarines unaccounted for. There have been no announced retirements of Russian Delta-IV missile submarines in many years. From a New START Treaty accountability standpoint, as long as these submarines have armed missiles in their launchers, the missiles and their warheads are accountable under the New START Treaty limits. Even if they were not fully operational, they could serve as floating ICBM bases which could launch missiles on warning. Emphasis on launch-on-warning has long been a part of Russian nuclear doctrine and this has been increased in the 2024 iteration of Russian nuclear doctrine.

For many years Russia’s state media have been reporting that Russia’s long-range nuclear-capable cruise missiles have been deployed on its fighter aircraft and Backfire bombers. Such deployment would be a violation of the New START Treaty because it turns them into undeclared heavy bombers which would put Russia further above the New START Treaty limits. It would impact Russian compliance with all of the limitations under the New START Treaty.

Conclusion

The U.S. Department of State has a long history of trying to avoid public disclosure of Soviet/Russian arms control violations. Sven Kraemer, Director of Arms Control in the Reagan administration’s National Security Council staff, records that “…new interagency efforts to assess Soviet violations of the SALT II agreement were blocked by the Department of State during 1981,” and, after this there were “…delaying tactics and resistance within the government bureaucracy, especially in the State Department, ACDA and parts of CIA.”[x] The 2010 State Department compliance report even stated that, “The United States raised new compliance issues since the 2005 Report,” but did not say what they were. The Department of State clearly does not want the full scope of Russian arms control noncompliance to become public.

The 2025 State Department report appears to be related to Biden Administration fears that the Trump Administration would respond to Russian New START Treaty violations as President Trump did to the INF Treaty violations, and punish Russia by terminating the New START Treaty and increasing U.S. strategic nuclear forces to deal with the growing nuclear threat from Russia and China. There are good reasons to do so. According to then-STRATCOM Commander Admiral Charles Richard, “…two thirds of those [U.S. nuclear] weapons are ‘operationally unavailable’ because of treaty constraints, such as provisions of the New START treaty with Russia.” Indeed, as far back as 2010, Russian expert Alexei Arbatov characterized New START as a treaty on limiting the American strategic forces.

The Biden Administration consistently refused to increase U.S. nuclear capabilities despite the rapidly growing Russian and Chinese nuclear threats, numerous Russian nuclear attack threats, its repeated high level war threats and its vicious war against Ukraine. Despite a few statements by senior Biden Administration officials that this may have to happen and even a statement in its new nuclear employment guidance, the Biden Administration ultimately did almost nothing to address the growth of adversary nuclear capabilities.

The early publication of the 2025 New START Treaty report and its assertion that the there was “high confidence” that Russia was not well above the New START limits on deployed nuclear warheads appears to be an attempt to preempt the Trump Administration with its “America First” agenda from dealing with this issue. The Department of State is well aware that President Trump was the only President since Ronald Reagan to terminate an arms control Treaty (the INF Treaty) because of serious and repeated Russian violations (or in the case of Reagan by the Soviet Union). Trump’s Secretary of State Marco Rubio has long urged a strong position on responding to Russian arms control violations. Then-Senator Rubio introduced legislation that he said would make Russia “face real consequences” if it continued to violate arms control agreements. This may explain the State Department’s rush to judgement on the scope of Russia’s violation of the New START Treaty’s deployed warhead limitation.

Biden’s State Department was very much aware that the New START Treaty will expire in February 2026. Delaying the Trump Administration from dealing with this issue would eliminate any chance that Russia would face consequences for its Biden-era New START Treaty violations. By the time the 2026 New START Treaty report would be drafted the Treaty would be dead. The State Department bureaucracy would likely argue that it makes no sense to antagonize Russia when the Treaty it had violated was already dead. To the State Department bureaucracy, Russia is its client, and its approach hardly reflects common sense or an American First policy in dealing with America’s adversaries.

At his swearing-in ceremony, Secretary of State Rubio said that when it comes to foreign policy the priority of the U.S. Department of State “will be the United States.” He further added, “…everything we do must be justified by the answer to one of these three questions: Does it make us stronger; does it make us safer; does it make us more prosperous? If it doesn’t do one of these three things, we will not do it.” Clearly, the New START Treaty fails to