VZCZCXRO9059
PP RUEHAG RUEHAST RUEHDA RUEHDBU RUEHDF RUEHFL RUEHIK RUEHKW RUEHLA
RUEHLN RUEHLZ RUEHNP RUEHPOD RUEHROV RUEHSK RUEHSR RUEHVK RUEHYG
DE RUEHLJ #0067 0721635
ZNR UUUUU ZZH
P 131635Z MAR 09
FM AMEMBASSY LJUBLJANA
TO RUEHC/SECSTATE WASHDC PRIORITY 7213
INFO RUEHZL/EUROPEAN POLITICAL COLLECTIVE PRIORITY
RHEHNSC/NSC WASHDC PRIORITY
RUEATRS/DEPT OF TREASURY WASHDC PRIORITY
RUEAIIA/CIA WASHDC PRIORITY

UNCLAS LJUBLJANA 000067 
 
SENSITIVE 
SIPDIS 
 
NEA/IR, EUR/CE, TREASURY FOR OFAC 
 
E.O. 12958: N/A 
TAGS: ETRD ETTC SI IR
SUBJECT: SLOVENIAN COMPANY AKS IF SHIP TRACKING DEVICES 
FALL UNDER IRAN SANCTIONS REGIME 
 
¶1. (U) This is an action request; see paragraph 4. 
 
¶2. (SBU) The Business development manager of the Slovenian 
company EMA, a manufacturer of coding and tracking solutions 
(satellite tracking devices for use on ships), contacted Post 
on 13 March about selling maritime trackers with 
American-made Iridium satellite modems to Iran.  The 
customer, Persian Marine Industries Co., has made payment, 
however EMA has not yet received the money.  EMA requested 
guidance before it ships the product which it plans to do on 
or about 17 March.  The business development manager stressed 
that EMA wanted to be cautious, although EMA was hoping that 
its tracking device did not come under sanctions. He 
explained that its maritime tracker uses a modem that is made 
by an American company Iridium. 
 
¶3. (SBU) EMA suggested to Post that the equipment should be 
exempt from sanctions because it is compulsory equipment for 
ships registered with the International Maritime 
Organization, and because their competition, Inmarsat, is 
already supplying a different type of maritime tracking 
system to Iran that the equipment would be exempt from 
sanctions.  According to Post research, based on Iranian 
Transaction Regulations (ITR) section 560.511, any exception 
to the prohibition on the sale of U.S. goods and services 
would require that U.S. content be de minimis.  EMA has 
provided no information addressing this restriction. 
 
¶4. (SBU) Post requests guidance for response to EMA. 
FREDEN