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BIS Adds Fourteen Entities to its List of "Unverified" Persons in Foreign Countries

The Bureau of Industry and Security (BIS) has issued a notice, effective October 19, 2006, announcing that it has updated its Unverified List by the addition of fourteen 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 Fourteen Entities to Unverified List

BIS is adding the following fourteen entities, with their last known addresses, to the Unverified List:

Al Aarif Factory Equipment Trading LLC, Sheikh Fahad Saad Alsbah Bldg., Al Maktoum Street, P.O. Box 28162, Dubai, UAE (also located in Al Quoz district of Dubai)

Al-Thamin General Trading LLC, P.O. Box 41364, Dubai, UAE

Amiran Trading Company, Arbift Tower, 1st Floor, Flat No. 1803, Deira, UAE, also P.O. Box 6 1463, Jebel Ali, Dubai, UAE

Bazar Trading Co, Baniyas Tower, Suite 212, Dubai, UAE

Centre Bright Company, Unit 7A, Nathan Commercial Building, 430-436 Nathan Road, Kowloon City, Hong Kong

Davood Khosrojerdi, dba Al Musafer Tourism and Cargo, Concord Tower, Al Maktoum Street, PO Box 77900, Dubai, UAE

Fuchs Oil Middle East, Sharjah Airport International Free Zone, Sharjah, UAE

IC Trading Ltd, Yauzskaya Str. 8, Bldg 2, Moscow, Russia

Part Tech Co, Baniyas Tower, Suite 212, Dubai, UAE

Parto Abgardan, Showroom 5, Sheikh Rashid bin Khalifa al Maktoum building, Dubai, UAE

Reza Nezam Trading, Al Dana Center, Al Maktoum Street, P.O. Box 41382, Dubai, UAE

Sarelica (Sar Elica) FZC, Bldg. 3, Office No. 3 G-08, P.O. Box 41 71 0, Hamariya Free Zone, Sharjah, UAE

Semicom Technology International LLC, Office No. 18, 6th Floor, Horizons Business Centre, Al-Doha Centre, Al-Maktoum St., P.O. Box 41096, Dubai, UAE

Vitaswiss Limited, P.O. Box 61069, Office R/A 8 CB03, UAE

Unverified List Now Includes 33 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)1

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)

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)

Al Aarif Factory Equipment Trading LLC (United Arab Emirates)

Al-Thamin General Trading LLC (United Arab Emirates)

Amiran Trading Company (United Arab Emirates)

Bazar Trading Co (United Arab Emirates)

Davood Khosrojerdi, dba Al Musafer Tourism and Cargo (United Arab Emirates)

Fuchs Oil Middle East (United Arab Emirates)

Part Tech Co (United Arab Emirates)

Parto Abgardan (United Arab Emirates)

Reza Nezam Trading (United Arab Emirates)

Sarelica (Sar Elica) FZC (United Arab Emirates)

Semicom Technology International LLC (United Arab Emirates)

Vitaswiss Limited (United Arab Emirates)

Centre Bright Company (Hong Kong)

IC Trading Ltd (Russia)

1 BIS' most recent prior publication of the Unverified List (dated July 12, 2006) contained two separate listings, with different addresses, for Lucktrade International of Hong Kong. In this publication of the Unverified List, this entity is only listed once.

(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 07/17/06 news, 06071715, for BP summary of BIS' most recent amendment of the Unverified List.)

See ITT's Online Archives or 10/24/06 news, 06102415, for BP summary on BIS' withdrawal of its proposed rule to, among other things, amend the "red flag" guidance.)

BIS contact - Marcus Cohen (202) 482-4255

BIS notice (D/N 060920245-6245-01, FR Pub 10/19/06) available at http://a257.g.akamaitech.net/7/257/2422/01jan20061800/edocket.access.gpo.gov/2006/pdf/06-8771.pdf