VZCZCXRO4782
OO RUEHBC RUEHDE RUEHDIR RUEHKUK
DE RUEHC #3737/01 2740941
ZNR UUUUU ZZH
O 291401Z SEP 08
FM SECSTATE WASHDC
TO RUEHUL/AMEMBASSY SEOUL IMMEDIATE 8729-8730
INFO IRAN COLLECTIVE IMMEDIATE

UNCLAS SECTION 01 OF 02 STATE 103737 
 
SENSITIVE 
 
C O R R E C T E D   C O P Y (SENSITIVE CAPTION ADDED) 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: ECON EFIN KNNP PARM PTER IR KS
SUBJECT: RESPONSE TO ROKG QUESTIONS REGARDING DELIVERY OF 
SHIPS TO IRISL 
 
REF: A. A) STATE 90303 
     ¶B. B) SEOUL 001830 
     ¶C. C) SEOUL 1746 
 
STATE 00103737  001.2 OF 002 
 
 
¶1.  (U) This is an action request.  Please see paragraph 3. 
 
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SUMMARY/BACKGROUND 
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¶2. (SBU) Washington is providing the nonpaper in paragraph 4 
to answer questions from the ROKG that arose in response to 
our demarche to Seoul regarding the delivery of ships to the 
Islamic Republic of Iran Shipping Lines (IRISL) and the 
designation of IRISL under E.O. 13382 for facilitating Iran's 
proliferation of weapons of mass destruction (REF A). 
 
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OBJECTIVES/ACTION REQUEST 
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¶3. (SBU) Washington requests Post draw from paragraph 4 when 
engaging host government officials on questions regarding the 
implications of the IRISL designation for Korean companies. 
Points in paragraph 4 may be left as a nonpaper. 
 
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NONPAPER FOR SEOUL 
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¶4. (U) Q: WHAT ARE THE FULL IMPLICATIONS OF THE U.S. 
DESIGNATION? 
 
A: This designation publicizes the proliferation activities 
of the Islamic Republic of Iran Shipping Lines (IRISL), with 
the objective of disrupting or stopping Iran's ability to 
procure and develop weapons of mass destruction or their 
means of delivery (including missiles capable of delivering 
such weapons).  It increases pressure on the Iranian regime 
with the goal of persuading Tehran to change course.  More 
immediately, this action helps the United States protect the 
U.S. financial system from abuse by WMD proliferators and 
their supporters, by blocking all property and interests in 
property of IRISL and the other 18 designated entities that 
are in the United States, or that hereafter come within the 
United States, or that are or hereafter come within the 
possession or control of U.S. persons.  Further, no U.S. 
person is permitted to engage in business with these 19 
entities. 
 
Q: WHEN DOES THE U.S. DESIGNATION TAKE EFFECT AND DOES IT 
HAVE RETROACTIVE APPLICATION (E.G., TO PRE-EXISTING 
CONTRACTS)? 
 
A: The designation of IRISL and 18 subsidiaries under E.O. 
13382 took effect when it was announced by the Department of 
the Treasury on September 10, 2008. 
 
Q: HOW DOES THE U.S. VIEW THE ACTIONS OF THIRD-COUNTRY FIRMS 
THAT CONTINUE TO DO BUSINESS WITH IRISL? 
 
A: We urge companies to immediately end any association with 
IRISL to ensure they are not assisting Iran in its evasion of 
UNSC sanctions. 
 
In 2007, IRISL transported a shipment of a precursor chemical 
destined for use in Iran's missile program.  The end user was 
Parchin Chemical Industries, an entity listed in UNSCR 1747 
as a subordinate of Iran's Defense Industries Organization, 
which was also listed in UNSCR 1737. 
 
Any third-country firms doing business with IRISL could 
inadvertently be facilitating IRISL's deceptive shipping 
practices, such as the use of generic terms to describe 
shipments to avoid the attention of shipping authorities and 
the creation and the use of cover entities to conduct 
official IRISL business.  We urge third-country governments 
and firms to heed the lesson learned from the U.S. 
investigation of the Mayrow Trading Company and related 
entities (http://www.bis.doc.gov/news/2008/doj09172008 .htm): 
Iran uses deceptive practices to circumvent national and 
international restrictions. 
 
 
STATE 00103737  002.2 OF 002 
 
 
Q: WHAT ARE THE RISKS TO KOREAN FIRMS THAT CONTINUE TO DEAL 
WITH IRISL IN THE ABSENCE OF A UN-DESIGNATION OF THE FIRM? 
 
A: Korean firms risk designation under E.O. 13382 if they act 
or purport to act for or on behalf of, directly or indirectly 
IRISL, the listed IRISL subsidiaries, or any other E.O. 13382 
designated entity, and/or if they provide, or attempt to 
provide, financial, material, technological, or other support 
for, or goods or services in support of any designated 
entity. 
 
Q: COULD THE U.S. DESIGNATION AFFECT A FIRM OR INDIVIDUAL WHO 
MOVED CARGO TO IRAN ON AN IRISL VESSEL? 
 
A: If a firm or individual transports goods that pose a risk 
of materially contributing to the proliferation of weapons of 
mass destruction or their means of delivery, the firm or 
individual could be designated under E.O. 13382.  We should 
work together to ensure that IRISL does not continue to 
circumvent UNSC sanctions.  The United States continually 
reviews the activities of firms and individuals associated 
with IRISL and will ensure that Iran is not allowed to 
continue its efforts to transport items related to its 
proliferation of sensitive nuclear activities or the 
development of nuclear weapon delivery systems. 
 
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REPORTING DEADLINE 
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¶5.  (U) Please report delivery of the U.S. non-paper and 
any response as soon as possible. 
Please slug replies for ISN, T, TREASURY, and NEA/IR. 
Please use SIPDIS caption on all responses. 
 
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POINT OF CONTACT 
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¶6.  (U) Washington point of contact for follow-up information 
is Kevin McGeehan, ISN/CPI, (202) 647-5408, 
mcgeehankj@state.sgov.gov or Anthony Ruggiero, ISN/CPI, (202) 
647-5181, ruggieroaj@state.sgov.gov. 
 
¶7.  (U) Department thanks Post for its assistance. 
RICE