BIS Adds Three Entities to its List of "Unverified" Persons in Foreign Countries
The Bureau of Industry and Security (BIS) has issued a notice, effective July 12, 2006, announcing that it has updated its Unverified List by the addition of three entities.
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BIS states that the Unverified List includes the names, countries, and last known addresses of foreign persons involved in export transactions with respect to which BIS could not conduct a pre license check (PLC) or a post shipment verification (PSV) for reasons outside of the U.S. government's control; and/or BIS was not able to verify the existence or authenticity of the end user, intermediate consignee, ultimate consignee or other party to an export transaction.
Any transaction to which a listed person is a party will be deemed to raise a 'red flag' with respect to such transaction within the meaning of the "Know Your Customer" guidance set forth in Supplement No. 3 to 15 CFR Part 732.
The 'red flag' applies to the person on the Unverified List regardless of where the person is located in the country included on the list.
Whenever there is a "red flag," exporters have an affirmative duty to inquire, verify, or otherwise substantiate the 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 Export Administration Regulations (EAR).
BIS Adds Three Entities to Unverified List
BIS is adding the following three entities, with their last known addresses, to the Unverified List:
Sheeba Import Export,Hadda Street, Sanaa, Yemen
Aerospace Consumerist Consortium FZCO, Sheikh Zayed Road, P.O. Box 17951, Jebel Ali Free Zone, Dubai, United Arab Emirates (UAE) and Dubai International Airport, Dubai, 3365, UAE
Medline International LLC.,P.O. Box 86343, Dubai, UAE
Unverified List Now Includes 20 Entities in Hong Kong, Malaysia, Singapore, United Arab Emirates, Pakistan, Yemen, and Russia
As a result of the above additions, 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)
Etalon Company (Russia)
Pskovenergo Service (Russia)
Sheeba Import Export (Yemen)
Aerospace Consumerist Consortium FZCO (United Arab Emirates)
Medline International LLC (United Arab Emirates)
(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 11/02/05 news, 05110215, 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 - Ariel Leinwand (202) 482-4255
BIS notice (D/N 060705186-6186-01, FR Pub 07/12/06) available at http://a257.g.akamaitech.net/7/257/2422/01jan20061800/edocket.access.gpo.gov/2006/pdf/06-6165.pdf