US Imposes Nonproliferation Sanctions against 14 Foreign Entities
April 2007
Includes Chinese, Singaporean, Malaysian, and Mexican Entities
In the April 17, 2007, Federal Register the US State Department announced sanctions on 14 new entities due to actions that potentially make a material contribution to the development of Weapons of Mass Destruction in Iran and Syria. The sanctions prohibit export license approvals and US Government procurement from, assistance to, and exports to the listed entities. The sanctions have little impact on the newly listed entities in Syria and Iran because those countries are already subject to comprehensive US trade sanctions.
Bottom Line Issue:
These sanctions do not directly prohibit all transfers of items subject to US export/trade controls to the listed entities. As a practical matter, however, exporters and reexporters should add the listed entities to the prohibited parties list against which they screen their transactions because this notice creates a Red Flag that the listed entities may intend to transfer items to weapons programs in Iran and Syria. If you find a match, you should investigate the Red Flag to determine whether your items will be illegally diverted-if your investigation makes you comfortable that your items will not be diverted, document your investigation and proceed with the transaction. Alternatively, you might want to implement a simple policy of never doing business with the listed entities because they are members of this list, even though you could legally do business with them.
Specifically, the sanctions on the entities are:
- No department or agency of the U.S. Government may procure goods, technology or services from listed entities.
- No department of agency of the U.S. Government may provide assistance to listed entities.
- No department or agency of the U.S. Government may sell any item on the United States Munitions List to listed entities.
- No new licenses for transfer of items controlled under the EAR or the Export Administration Act of 1979 will be granted and all existing licenses will be suspended for transfer to listed entities.
The Listed Entities are:
- China National Precision Machinery Import/Export Corporation (CPMIEC) (China) and any successor, sub-unit, or subsidiary thereof
- Shanghai Non-Ferrous Metals Pudong Development Trade Co. Ltd. (China) and any successor, sub-unit, or subsidiary thereof
- Zibo Chemet Equipment Company (China) and any successor, sub-unit, or subsidiary thereof
- Challenger Corporation (Malaysia) and any successor, sub-unit, or subsidiary thereof
- Target Airfreight (Malaysia) and any successor, sub-unit, or subsidiary thereof
- Defense Industries Organization (DIO) (Iran) and any successor, sub-unit, or subsidiary thereof
- Hizballah and any successor, sub-unit, or subsidiary thereof
- Sokkia Singapore PTE Ltd. (Singapore) and any successor, sub-unit, or subsidiary thereof
- Army Supply Bureau (Syria) and any successor, sub-unit, or subsidiary thereof
- Syrian Air Force (Syria) and any successor, sub-unit, or subsidiary thereof
- Syrian Navy (Syria) and any successor, sub-unit, or subsidiary thereof
- Industrial Establishment of Defense (Syria) and any successor, sub-unit, or subsidiary thereof
- Challenger Corporation (Malaysia) and any successor, sub-unit, or subsidiary thereof
- Target Airfreight (Malaysia) and any successor, sub-unit, or subsidiary thereof
- Aerospace Logistics Services (Mexico) and any successor, sub-unit, or subsidiary thereof
- Arif Durrani (Pakistan)
The penalties will be in effect for 2 years unless the Secretary of State deems otherwise.
Source:
- Federal Register - April 23, 2007 (Volume 72, Number 77, pp. 20158-20159)
