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DE RUEHC #9141 2891528
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O 102013Z OCT 08
FM SECSTATE WASHDC
TO RUEHBJ/AMEMBASSY BEIJING IMMEDIATE 3535-3539
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UNCLAS STATE 109141 
 
SENSITIVE 
 
C O R R E C T E D C O P Y  (ADDED CAPTION) 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: KNNP MNUC IR GM PREL PARM EFIN
SUBJECT: ADDITION OF IRANIAN-AFFIILIATED MAYROW TRADING 
CO. AND ITS ASSOCIATED ENTITIES AND INDIVIDUALS TO GENERAL 
ORDER 3 
 
 ¶1.  (U) This is an action request.  Please see paragraph 5. 
 
------- 
SUMMARY 
------- 
 
¶2. (SBU) On September 17, 2008, the U.S. took a number of 
actions to help protect Coalition Forces operating in Iraq 
and Afghanistan by implementing regulatory steps to disrupt 
the flow of U.S.-origin commodities that have been, and may 
continue to be, employed in Improved Explosive Devices (IEDs) 
or other explosive devices used against Coalition Forces. 
The Department of Commerce's Bureau of Industry and Security 
(BIS) announced that a significant number of new entities 
arising out of the Mayrow investigation have been added to 
the Entities List. Concurrently, the Treasury Department 
designated six Iranian entities under Executive Order (E.O.) 
13382 ("Blocking the Property of Weapons of Mass Destruction 
Proliferators and their Supporters") for being owned or 
controlled by the Ministry of Defense and Armed Forces 
Logistics (MODAFL) or the Defense Industries Organization 
(DIO).  The Department of Justice also indicted 16 
foreign-based nationals in connection with their 
participation in conspiracies to export 
U.S.-manufactured commodities to prohibited entities and to 
Iran. 
 
¶3.  In addition to the actions listed above, Commerce's BIS 
transferred the parties on General Order #3 to the newly 
expanded Entity List.  This transfer will improve the ability 
of exporters to screen potential recipients of items subject 
to the Export Administration Regulations (EAR) and simplify 
the EAR by reducing the need to issue general orders that 
impose license requirements on specific parties.  This cable 
serves as notification for each respective government of the 
addition of entities and/or individuals under their 
jurisdiction to the Entity List. 
 
¶4. Finally, the United States designated six Iranian entities 
under E.O. 13382 ("Blocking the Property of Weapons of Mass 
Destruction Proliferators and their Supporters") on September 
17, 2008 for being owned or controlled by the Ministry of 
Defense and Armed Forces Logistics (MODAFL) or the Defense 
Industries Organization (DIO). 
 
------------------------- 
OBJECTIVES/ACTION REQUEST 
------------------------- 
 
¶5. (SBU) Washington requests Posts deliver the talking points 
and non-paper in paragraph 5 and appropriate parts of 
paragraphs 6 and 7 to appropriate host government officials 
in the foreign affairs and finance ministries, and other 
appropriate government agencies, such as the Commerce and 
Justice Departments or equivalent.  Please note that some 
countries were notified via phone by Washington on September 
17th. 
 
Please also note that additional activities are already 
taking place in Canada, Hong Kong, South Korea and the UAE 
related to these actions by the USG.  For Posts in these 
jurisdictions, this cable is for Embassy information only. 
 
Post should pursue the following objectives: 
 
-- Inform host government officials of the Commerce 
Department's additions to the Entity List, the indictments by 
the Department of Justice, and the Department of the 
Treasury's designations under E.O. 13382. 
 
-- Urge host governments, in accordance with obligations 
under UNSCRs 1737, 1747 and 1803, to freeze the assets of 
these entities if they have not already done so, as well as 
the assets of persons or entities acting on their behalf or 
at their direction, or by entities owned or controlled by 
them. 
 
-- Note that firms and individuals in the jurisdiction of 
host governments risk designation under E.O. 13382 if they 
are found to be owned or controlled by, act or purport to act 
for or on behalf of, directly or indirectly, entities or 
individuals designated under E.O. 13382, 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. 
 
-- Stress the point that this action is being taken to 
protect all Coalition forces in Iraq and Afghanistan and will 
have a significant positive effect on the security of these 
two countries in particular, and the Middle East and Central 
Asia in general. 
 
-- Request host government assistance where needed in 
completing this action. 
 
-- Urge host governments to use enhanced vigilance when 
examining these firms and to enforce any pertinent laws that 
these entities and individuals have broken. 
 
-- Urge host governments to enact stronger legislation 
restricting the sale or export of dual-use items outside 
their jurisdiction. 
 
-- Inform host governments that the U.S. is willing to 
provide assistance where requested. 
 
----------------------- 
BACKGROUND AND NONPAPER 
----------------------- 
 
¶6.  (U) Begin text of non-paper for all Posts: 
 
To help protect Coalition Forces operating in Iraq and 
Afghanistan, the United States took certain regulatory steps 
to disrupt the flow of U.S.-origin commodities that have 
been, and may continue to be, employed in Improvised 
Explosive Devices (IEDs) or other explosive devices used 
against Coalition Forces in Iraq and Afghanistan. 
 
On September 17, 2008, the Department of Commerce's Bureau of 
Industry and Security (BIS) published a new rule in the 
Federal Register that expanded the grounds for placing a 
party on the Entity List.  The Entity List is a list of 
parties whose presence in a transaction triggers a license 
requirement under the Export Administration Regulations. 
Under the new rule, a party could be placed on the Entity 
List if there is reasonable cause to believe that the entity 
has been involved, is involved, or poses a significant risk 
of becoming involved in activities that are contrary to the 
national security or foreign policy interests of the United 
States.  Those acting on behalf of such entities may also be 
added to the Entity List. 
 
Also on September 17, 2008, BIS transferred the parties on 
General Order #3 to the newly expanded Entity List.  This 
transfer will improve the ability of exporters to screen 
potential recipients of items subject to the EAR and simplify 
the EAR by reducing the need to issue general orders that 
impose license requirements on specific parties. 
 
In addition to transferring the existing General Order #3 
parties to the Entity List, BIS announced that a significant 
number of new entities arising out of the Mayrow 
investigation have been added to the Entity List.  Some of 
these entities and individuals are located in your 
jurisdiction and their names are listed in paragraph 7.  The 
complete Entity List can be found at: 
http://www.bis.doc.gov/entities/default.htm. 
 
The Department of Justice also indicted 16 foreign-based 
nationals in connection with their participation in 
conspiracies to export U.S.-manufactured commodities to 
prohibited entities and to Iran.  More information about 
these indictments can be found in a press release at: 
http://justice.gov/opa/pr/2008/September/08-n sd-828.html. 
 
Finally, the Treasury Department designated six Iranian 
entities under Executive Order (E.O.) 13382 for being owned 
or controlled by the Ministry of Defense and Armed Forces 
Logistics (MODAFL) or the Defense Industries Organization 
(DIO).  These six entities are Iran Electronics Industries 
and two of its subsidiary organizations, Shiraz Electronics 
Industries, and Iran Communications Industries; Iran Aircraft 
Manufacturing Industrial Company (HESA), Armament Industries 
Group, and its subsidiary, Farasakht Industries.  More 
details on these designations can be found in Treasury's 
press release at 
http://treasury.gov/press/releases/hp1145.htm . 
 
An overview of all of these actions can be found at: 
http://www.state.gov/r/pa/prs/2008/sept/10982 2.htm. 
 
These actions by BIS, the Department of Justice, and the 
Department of the Treasury are a continuation of the U.S. 
Government's efforts to halt Iranian proliferation, counter 
Iran's use of deceptive practices in international commerce, 
and prevent Iran's use of the international commercial system 
for nefarious purposes.  These deceptive practices undermine 
confidence in international commerce, in addition to 
threatening Coalition forces and security in Iraq and 
Afghanistan. 
 
These combined actions by the U.S. Government illustrate the 
global reach of Iranian procurement networks and underscore 
the importance of keeping sensitive U.S. technology out of 
Iran's grasp.  They also provide evidence of the importance 
of strong export and dual-use controls. 
 
The U.S. urges you to use enhanced vigilance when examining 
these firms and to enforce any pertinent laws that these 
entities and individuals have broken.  The U.S. also urges 
you to enact stronger legislation restricting the sale or 
export of dual-use items outside your jurisdiction.  The U.S. 
is willing to provide assistance where requested on legal and 
procedural issues regarding export controls. 
 
End text of non-paper for all Posts. 
 
¶7. (SBU) The entities that were added to BIS' Entity List are: 
 
POINTS FOR CANADA ONLY: 
The following entities and individuals from your country have 
been added to General Order #3 due to their involvement with 
Mayrow General Trading and related entities. 
 
Entities 
¶1.    Kitro Corporation: Toronto, Canada. 
 
Individuals 
¶1.    Ali Bakhshien:  Toronto, Canada. 
 
 
POINTS FOR CHINA ONLY: 
The following entities and individuals from your country have 
been added to General Order #3 due to their involvement with 
Mayrow General Trading and related entities. 
 
Entities 
¶1.    A.C. International: Guangzhou, China. 
¶2.    Asia International Trading Company Guangzhou, China 
 
Individuals 
¶1.    Tracy Little: Guangzhou, China 
 
 
POINTS FOR EGYPT ONLY: 
The following entities and individuals from your country have 
been added to General Order #3 due to their involvement with 
Mayrow General Trading and related entities. 
 
Entities 
¶1.    H Logic: Alexandria, Egypt. 
 
Individuals 
¶1.    Hesham Yehia:  Alexandria, Egypt. 
¶2.    Najeeb Al Awadhi:  Alexandria, Egypt. 
 
 
POINTS FOR GERMANY ONLY: 
The following entities and individuals from your country have 
been added to General Order #3 due to their involvement with 
Mayrow General Trading and related entities. 
 
Entities 
¶1.    Nezhad Enterprise Company: Kiel, Germany. 
 
Individuals 
¶1.    Djamshid Nezhad:  Kiel, Germany 
 
 
POINTS FOR HONG KONG AND CHINA ONLY: 
The following entities and individuals from your jurisdiction 
have been added to General Order #3 due to their involvement 
with Mayrow General Trading and related entities. 
 
Entities 
¶1.    Asia Link: Hong Kong 
¶2.    Britestone Limited: Hong Kong 
¶3.    Creative Electronics: Hong Kong 
¶4.    Green Channel Electronics Company Tong: Kowloon, Hong 
Kong 
¶5.    Kong Fat Electronic Trading Limited:  Kowloon, Hong 
Kong. 
¶6.    Pelorus Enterprises Limited:  Hong Kong. 
¶7.    Polar Star International Co. Ltd.:  Hong Kong 
¶8.    Techlink Electronics: Kowloon, Hong Kong. 
¶9.    TLG Electronics:  Hong Kong. 
¶10.   Unite Chance Technology Company:  Hong Kong. 
¶11.   Wing Shing Computer Components Company (H.K.) Ltd.: 
Hong Kong. 
 
Individuals 
¶1.    Amy So:  Hong Kong. 
¶2.    Raz El Mayan: Hong Kong 
¶3.    Gary Chan:  Hong Kong. 
¶4.    Bruce Lam:  Hong Kong 
¶5.    Antony Emmanuel: Dubai, UAE and Hong Kong. 
 
POINTS FOR KUWAIT ONLY 
The following individual from your country has been added to 
General Order #3 due to his involvement with Mayrow General 
Trading and related entities 
 
Entities 
¶1.    Advanced Technology General Trading Company 
 
Individuals 
¶1.    Abubakr Abuelazm:  Kuwait 
 
 
POINTS FOR MALAYSIA ONLY: 
The following entities and individuals from your country have 
been added to General Order #3 due to their involvement with 
Mayrow General Trading and related entities. 
 
Entities 
¶1.    Ace Hub System: Selangor, Malaysia. 
¶2.    Analytical Solutions: Kuala Lumpur, Malaysia 
East Tech:  Malaysia 
¶3.    Antcorp System: Penang, Malaysia 
¶4.    East Tech: Malaysia 
¶5.    Eco Biochem SDN BHD: Selangor D.E., Malaysia. 
¶6.    Fetsco Marketing SDN BHD:  Malaysia. 
¶7.    VTE Industrial Automation SDN BHD:  Selangor, 
       Malaysia. 
¶8.    Nexus Empire:  Selangor, Malaysia. 
 
Individuals 
¶1.    Ann Teck Tong:  Peresekkutuan, Malaysia. 
¶2.    Mohd Ansari:  Kuala Lumpur, Malaysia. 
¶3.    Brian Kaam:  Selangor, Malaysia. 
 
 
POINTS FOR SINGAPORE ONLY: 
The following entities and individuals from your country have 
been added to General Order #3 due to their involvement with 
Mayrow General Trading and related entities. 
 
Entities 
¶1.    Cyberinn PTE LTD: Singapore 
¶2.    Strive Components:  Singapore. 
¶3.    Synoptics Imaging Systems Pte Ltd:  Singapore. 
 
POINTS FOR SOUTH KOREA ONLY: 
The following entity from your country has been added to 
General Order #3 due to its involvement with Mayrow General 
Trading and related entities. 
 
Entities 
¶1.    WASTEC, Inc. / With Advanced Systemic Technology: 
Seoul, South Korea 
 
 
POINTS FOR THE UAE ONLY: 
The following entities and individuals from your country have 
been added to General Order #3 due to their involvement with 
Mayrow General Trading and related entities. 
 
Entities 
¶1.    Advanced Technology General Trading Company: Kuwait 
and Dubai, UAE 
¶2.    Danoush Trading Company: Dubai 
¶3.    Divanizadeh General Trading Company:  Dubai, UAE 
¶4.    Hamed Al Fahid Trading Company: Dubai, UAE. 
¶5.    Telectron:  Abu Dhabi, UAE. 
 
Individuals 
¶1.    Abubakr Abuelazm: Dubai, UAE 
¶2.    Ali Reza Divanizadeh:  Dubai, UAE 
¶3.    Mehdi Rafie: Dubai, UAE. 
¶4.    Mehran Kamalinia:  Dubai, UAE. 
¶5.    Mohsen Saghafi:  Dubai, UAE. 
¶6.    Feroz Jafar:  Abu Dhabi, UAE. 
¶7.    Neda Kargar:  Dubai, UAE. 
¶8.    Baktash Fattahi (UAE): 
¶9.    Mostafa Salehi: Dubai, UAE. 
¶10.   Shaji Muhammed Basheer: Dubai, UAE 
¶11.   Antony Emmanuel: Dubai, UAE and Hong Kong. 
 
------------------ 
REPORTING DEADLINE 
------------------ 
 
¶8.  (U) Please report delivery of the U.S. non-paper and 
any response within seven days of receipt of this cable. 
Please slug replies for ISN, T, TREASURY, NEA/IR, and 
appropriate regional bureaus.  Please use SIPDIS caption on 
all responses. 
 
---------------- 
POINT OF CONTACT 
---------------- 
¶9.  (U)  Washington point of contact for follow-up 
information is Kevin McGeehan, ISN/CPI, (202) 647-5408, 
McGeehanKJ@state.sgov.gov. 
 
¶10.  (U) Department thanks Post for its assistance. 
RICE