BIS Adds Five Entities to its List of "Unverified" Persons in Foreign Countries
The Bureau of Industry and Security (BIS) has issued a notice, effective October 31, 2005, announcing that it has updated it Unverified List by adding five entities.
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(On June 14, 2002, BIS published a notice that set forth the initial list of persons in foreign countries who were parties to past export transactions where pre-license checks (PLCs) or post-shipment verifications (PSVs) could not be conducted for reasons outside the control of the U.S. Government (Unverified List).
Additionally, on July 16, 2004, BIS published a notice that advised exporters that the Unverified List would also include persons in foreign countries in transactions where BIS is not able to verify the existence or authenticity of the end-user, intermediate consignee, ultimate consignee, or other party to the transaction.
In its notices, BIS advised exporters that participation of a person on the Unverified List in a proposed transaction will be considered a "red flag" under the "Know Your Customer" guidance set forth in Supplement No. 3 to 15 CFR Part 732 of the Export Administration Regulations (EAR).
Under that guidance, whenever there is a "red flag," exporters have an affirmative duty to inquire, verify, or otherwise substantiate that proposed transaction to satisfy themselves that the transaction does not involve a proliferation activity prohibited in 15 CFR Part 744, and does not violate other provisions of the EAR.)
BIS Adds Five Entities to Unverified List
According to BIS, it is adding the following five entities with the following last known address to the Unverified List:
T.Z.H. International Co. Ltd., Room 23, 2/F, Kowloon Bay Ind Center, No. 15 Wany Hoi Rd., Kowloon Bay, Hong Kong, Special Administrative Region
Design Engineering Center, House 184, Street 36, Sector F-10/1, Islamabad, Pakistan
Kantry, 13/2 Begovaya Street, Moscow, Russia 125284
Elaton Company, 20B Berezhkovskaya Naberezhnaya, Moscow, Russia
Pskovenergo Service, 47-A Sovetskaya Street, Pskov, Russian Federation, 180000
Unverified List Now Includes 17 Entities in Hong Kong, Malaysia, Singapore, UAE, Pakistan, and Russia
As a result of the above addition, the Unverified List now contains the following entities (see notice for last known address):
Lucktrade International (Hong Kong)
Brilliant Intervest (Malaysia)
Dee Communications M SDN.BHD (Malaysia)
Peluang Teguh (Singapore)
Lucktrade International PTE Ltd. (Singapore)
Arrow Electronics Industries (United Arab Emirates)
Jetpower Industrial Ltd. (Hong Kong)
Onion Enterprises Ltd. (Hong Kong)
Lucktrade International (Hong Kong)
Litchfield Co. Ltd. (Hong Kong)
Sunford Trading Ltd. (Hong Kong)
Parrlab Technical Solutions, LTD (Hong Kong)
T.Z.H. International Co. Ltd. (Hong Kong)
Design Engineering Center (Pakistan)
Kantry (Russia)
Elaton Company (Russia)
Pskovenergo Service (Russia)
(See ITT's Online Archives or 06/18/02 news, 02061815 for BP summary of BIS' initial Unverified List. See ITT's Online Archives or 07/21/04 news, 04072125, for BP summary of BIS' notice which expanded the Unverified List's criteria, etc. See ITT's Online Archives or 05/03/05 news, 05050310, for BP summary of BIS' most recent amendment of the Unverified List.)
See ITT's Online Archives or 10/15/04 and 10/21/04 news, 04101520 and 04102115, for Parts I and II of BP's summary on BIS' proposed rule to, among other things, amend the Know Your Customer and Red Flags guidance set forth in Supplement No. 3 to 15 CFR Part 732.)
BIS contact - Thomas Andrukonis (202) 482-4255
BIS notice (D/N 051017266-5266-01, FR Pub 10/31/05) available at http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/2005/pdf/05-21621.pdf.)