BIS Adds Three Entities to its List of "Unverified" Persons in Foreign Countries
The Bureau of Industry and Security has issued a notice, effective July 5, 2007, 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; 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; and/or the person is affiliated with a person on the Unverified List by virtue of ownership, control, position of responsibility, or other affiliation or connection in the conduct of trade or business.
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 persons on the Unverified List regardless of their location 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.
BIS Adds Three Entities to Unverified List
BIS is adding the following three entities to the Unverified List:
Al Minzal Medical Equipment & Instruments, P.O. Box 31107, Sharjah, United Arab Emirates
JSC Chop Vityaz-S, 146 Unikh Pionerov Ave, Samara, Russia
Sistem Dizayners Co., APA: 2 NO.: 60, Merdanov Gardashlari St., Baku, Azerbaijan
Unverified List Now Includes 37 Entities in Hong Kong, Malaysia, Singapore, United Arab Emirates, Pakistan, Yemen, Russia, and Azerbaijan
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)
Lucktrade International (Hong Kong)1
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)
Al Minzal Medical Equipment & Instruments (United Arab Emirates)
JSC Chop Vityaz-S (Russia)
Sistem Dizayners Co. (Azerbaijan)
1BIS' most recent prior Federal Register publication of the Unverified List (dated October 19, 2006) mistakenly contained one listing for Lucktrade International of Hong Kong; however, the current list now correctly contains two separate listings, with different addresses.
(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 10/31/06 news, 06103125, 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 - Deniz Muslu (202) 482-4255
BIS notice (D/N 070206026-7213-01, FR Pub 07/05/07) available at http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/pdf/E7-12894.pdf