P 201151Z OCT 08
FM SECSTATE WASHDC
TO AMEMBASSY ABU DHABI PRIORITY
INFO AMCONSUL DUBAI PRIORITY

S E C R E T STATE 111428 
 
 
E.O. 12958: DECL: 10/08/2018 
TAGS: MNUC PARM PREL XB ZP AE ZO
 
SUBJECT: PRE NOTIFICATION OF SANCTIONS AGAINST UAE ENTITY 
 
Classified By: NEA Gene A. Cretz for reasons 1.4 b,c,d 
 
¶1. (U) This is an action request. Please see paragraph three. 
 
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SUMMARY 
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¶2. (S) The United States will impose sanctions under the 
Iran, North Korea, and Syria Nonproliferation Act (INKSNA) on 
22 October. There are also other firms in other countries 
that will be reported to Congress for INKSNA violations. One 
UAE company - R and M International Free Zone Company (FZCO) 
) will be among those sanctioned. 
 
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ACTION REQUEST 
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¶3. (S) Post is requested to pre-notify the UAE at least 24 
hours in advance of the U.S. announcement of its decision to 
sanction R and M International FZCO under INKSNA and explain 
why we are taking this action. The Department will notify 
Post via email as soon as a decision has been made to make 
the sanctions public. Please draw from the talking points in 
paragraph seven. 
 
End action request. 
 
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OBJECTIVES 
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¶4. (S) Post should achieve the following objectives: 
 
-- Given our close cooperation on counterproliferation, note 
our desire to provide prior notification of a sanction 
decision that will affect one UAE company - R and M 
International FZCO. 
 
-- Emphasize that sanctions are not directed at the UAE but 
only at the company. 
 
-- Encourage the UAE to investigate the company. 
 
End objectives. 
 
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BACKGROUND 
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¶5. (S) The Iran, North Korea, and Syria Nonproliferation Act 
(INKSNA) requires periodic reports to Congress identifying 
foreign entities with respect to whom there is credible 
information indicating that they have transferred to or 
acquired from Iran, North Korea or Syria goods, services, or 
technology on multilateral export control lists (Australia 
Group (AG), Chemical Weapons Convention (CWC), Missile 
Technology Control Regime (MTCR), Nuclear Suppliers Group 
(NSG), and the Wassenaar Arrangement (WA) or certain other 
items with the potential to make a material contribution to 
the development of WMD or ballistic or cruise missile 
systems. The U.S. has the discretion to impose sanctions on 
such foreign entities. 
 
¶6. (S) The USG has determined that R and M International FZCO 
(located in the UAE) has engaged in activities, as noted 
above, that warrant the imposition of sanctions under the 
INKSNA. This case has not been raised previously with the UAE 
Government. Penalties imposed by the sanction will take 
effect shortly and remain in place for two years. This 
sanctions determination and the name of the company will be 
published in the Federal Register once a decision has been 
made by the Department to notify Congress and the public. 
 
End Background. 
 
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TALKING POINTS 
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¶7. (S/REL UAE) Suggested Talking Points: 
 
-- The Iran, North Korea, and Syria Nonproliferation Act 
(INKSNA) requires the USG to report transfers made by 
foreign entities with respect to whom there is credible 
information indicating that they have transferred to or 
acquired from Iran, North Korea or Syria goods, service, or 
technology on multilateral control lists (Australia Group 
(AG), Chemical Weapons Convention (CWC), Missile Technology 
Control Regime (MTCR), Nuclear Suppliers Group (NSG), and the 
Wassenaar Arrangement (WA) or certain other items with the 
potential to make a material contribution to the development 
of WMD or ballistic or cruise missile systems. 
 
-- The United States has determined that there was credible 
information indicating that the UAE-based company, R and M 
International FZCO transferred items listed under the 
multilateral control list Wassenaar Arrangement to Syria - a 
country named in INKSNA. 
 
-- Syria,s Ministry of the Interior arranged for the 
purchase of bullet proof vests worth nearly $700,000 (USD) 
from the R and M International FZCO in July 2006. The vests 
were to be used by the Ministry,s Internal Security Forces 
at the Department of Administrative Affairs in Damascus. 
 
-- These bullet proof vests are controlled under the 
Wassenaar Arrangement and are therefore reportable under the 
INKSNA. 
 
-- We have information that R and M International FZCO is 
located at the Jebel Ali Free Zone, P.O. Box 2619092, Dubai. 
 
-- There are also other firms in other countries that will be 
reported to Congress for INKSNA violations. 
 
-- The imposition of this sanction is directed only at R and 
M International FZCO and not at the UAE. 
 
-- We will announce publicly in the Federal Register the 
imposition of penalties against R and M International FZCO as 
well as sanctions against other entities located in other 
countries. 
 
-- We encourage you to investigate R and M International 
FZCO, its successors, subunits, and subsidiaries for possible 
violations of your laws. 
 
-- The following penalties, which will take effect shortly 
and remain in place for two years, will be imposed on R and M 
International FZCO, its successors, subunits, and 
subsidiaries: 
 
a. No department or agency of the United States 
Government may procure, or enter into any contract for 
the procurement of any goods, technology, or services 
with R and M International FZCO, its successors, subunits, 
and subsidiaries; 
 
b. No department or agency of the United States 
Government may provide any assistance to them, and they 
shall not be eligible to participate in any assistance 
program of the United States Government; 
 
c. No United States Government sales to them of any 
item on the United States Munitions List are permitted, 
and all sales to them of any defense articles, defense 
services, or design and construction services under the 
Arms Export Control Act are terminated; and 
 
d. No new individual licenses shall be granted for the 
transfer to them of items controlled under the Export 
Administration Act of 1979 or the Export Administration 
Regulations, and existing such licenses are suspended. 
 
-- We look forward to continued cooperation on this and other 
related security matters. 
 
End talking points. 
 
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POINT OF CONTACT 
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¶8. (U) Washington point of contact is Stephen Tomchik, VCI/FO 
and Chris Herrington ISN/CPI. Please slug all responses for 
VCI, ISN, NEA, and T. We appreciate Post,s assistance. 
RICE 
 
 
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