VZCZCXYZ0000
RR RUEHWEB

DE RUEHC #9547 2111619
ZNY SSSSS ZZH
R 301602Z JUL 09
FM SECSTATE WASHDC
TO RUEHSI/AMEMBASSY TBILISI 0000
RUEHPL/AMEMBASSY PORT LOUIS 0000
INFO RUEHKV/AMEMBASSY KYIV 0000
RUEHSF/AMEMBASSY SOFIA 0000
RUETIAA/DIRNSA FT GEORGE G MEADE MD
RUEAIIA/CIA WASHINGTON DC
RHMCSUU/FBI WASHINGTON DC 0000
RUEKJCS/SECDEF WASHINGTON DC
RUCPDOC/USDOC WASHINGTON DC 0000

S E C R E T STATE 079547 
 
NOFORN 
SENSITIVE 
SIPDIS 
TBILISI FOR NICOLE O'BRIEN 
PORT LOUIS FOR QUENTIN BARBER 
 
E.O. 12958: DECL: 07/29/2034 
TAGS: ETTC KOMC GG SE UP BU
SUBJECT: BLUE LANTERN LEVEL 3: PRE-LICENSE END-USE CHECK 
ON LICENSE 050180371 
 
REF: A. IIR 7 100 0572 09 OF 1 JULY 2009 
     ¶B. TD-314/085344-08 OF 24 NOVEMBER 2008 
 
Classified By: Daniel J. Buzby, for reasons 1.4(a), (b), and (d) 
 
¶1. This is an Action Request. See paragraphs 2 - 5. 
 
¶2. (U) The Department's Office of Defense Trade Controls 
Compliance (PM/DTCC) requests Posts' assistance in conducting 
a pre-license check on license 050180371 for the export of 
rifles and grenade launchers to Georgia.  Posts are requested 
to complete this Blue Lantern check within 30 days.  Lack of 
response to a Blue Lantern check will affect pending and 
future licenses involving parties to this license. 
 
¶3. (S//NF) Reason for Request: According to REFTEL A, 
Seychelles-based company Bel Trading and Consulting has been 
working with Bulgaria-based company Bulgarian Industrial 
Engineering and Management (BIEM) to procure M4 rifles and 
M203 grenade launchers on behalf of the Ministry of Defence 
of Georgia  (NOTE: Bel Trading and Consulting is also 
reported to be doing business in Ukraine).  REFTEL A 
indicates that BIEM is receiving a commission for its 
services in this transaction despite the fact that the 
company is not/not listed on the export license request and 
is not/not registered as a broker with PM/DTCC as required by 
the International Traffic in Arms Regulation (ITAR).  In 
addition, REFTELs A and B highlight both companies' 
connection to organized crime and grey arms trafficking, and 
mentions that the Government of Seychelles has considered 
revoking Bel Trading and Consulting's license to operate in 
the past.  This request is to obtain more information about 
this transaction and the parties involved. 
 
¶4. (SBU) Action Request Tbilisi: Post is requested to 
establish the bona fides of this transaction by making 
inquiries to appropriate authorities in the Ministry of 
Defense of Georgia.  The following points are included for 
guidance: 
 
(To the Ministry of Defense of Georgia) 
 
--Can the MOD confirm the order of the rifles and grenade 
launchers listed on this license application? 
 
--MOD's Letter of Intent and End-Use Certificate date back to 
2007 and 2008, respectively.  Are these documents still 
considered valid by MOD?  Do these documents still reflect 
MOD's intention to continue with this transaction? 
 
--What role is Seychelles-based Bel Trading and Consulting 
playing in this transaction?  How were you first introduced 
to Bel Trading and Consulting?  What are the terms of the 
agreement between MOD and Bel Trading and Consulting in this 
transaction?  Is Bel Trading and Consulting receiving any 
commissions for its services in this transaction? 
 
--To your knowledge, are there any other companies involved 
in this transaction aside from Bel Trading and Consulting and 
the U.S. vendor?  Are any other parties receiving fees or 
commissions for services rendered in this transaction? 
 
In its reply, Post may also comment on any other information 
pertinent to these transactions such as security of 
facilities, end-use, and concerns about the entities involved. 
 
¶5. (SBU) Action Request Port Louis:  Post is requested to 
obtain further information on Bel Trading and Consulting and 
establish the bona fides of this transaction by making 
inquiries to representatives of the company and appropriate 
authorities in the Government of Seychelles. 
 
(To Bel Trading and Consulting) 
 
--Thank you for meeting with Embassy personnel.  This is a 
Blue Lantern end-use monitoring check and is not/not an 
investigation or law enforcement action.  The U.S. Department 
of State's Blue Lantern end-use monitoring program is the 
Department's means by which it establishes the bona fides of 
entities involved in the export and brokering of U.S. defense 
articles and services.  Any information you provide will 
assist the United States Government in monitoring U.S. 
defense articles and services and establishing trust in our 
trade relationships. 
 
--When was your company established and who are its 
principals?  Does your company or any of its principals do 
business under any other names?  Has your company or any of 
its principals done business under any other names in the 
past?  Does your company have offices in any other countries? 
 
 
--What products and services does your company provide?  Who 
are your regular business partners and where do they reside? 
Who are your regular customers and where do they reside? 
 
--Has your company been party to U.S. export licenses in the 
past? 
 
--What is your relationship with KNM Worldwide Services in 
the United States?  How were you first introduced to KNM 
Worldwide Services?  What are the terms of the agreement 
between your company and KNM Worldwide Services in this 
transaction? 
 
--What is your relationship with the Ministry of Defence in 
Georgia?  What are the terms of the agreement between your 
company and the Ministry of Defence in Georgia in this 
transaction?  Who is your point of contact in the Ministry of 
Defence in Georgia? 
 
--What role is your company playing in this transaction?  Is 
your company receiving any fees or commissions for its 
services in this transaction?  If so, please provide details 
and documentation. 
 
--Is your company paying any fees or commissions to any third 
parties for their services in this transaction?  If so, 
please provide details and documentation. 
 
--Will you ever have physical possession of the defense 
articles on this license?  If so, please describe your 
inventory and security procedures. 
 
--Are you familiar with the regulations governing the import 
and brokering of U.S.-origin defense articles, including 
restrictions on re-transfer or re-export? 
 
(To Import/Export Authorities of Seychelles) 
 
--Is Bel Trading and Consulting properly registered and/or 
authorized by the Government of Seychelles to broker, import, 
and/or sell defense articles in Seychelles and/or around the 
world? 
 
--Do you have any information on Bel Trading and Consulting 
or its principals that would question their reliability as a 
recipient or broker of U.S. defense articles? 
 
In its reply, Post may also comment on any other information 
pertinent to these transactions such as security of 
facilities, end-use, and concerns about the entities involved. 
 
¶6. (U) Details of license applications: 
 
DTC Case: 050180371 
 
QUANTITY/COMMODITY: 
 
7,000 M4A1-type Rifles, 5.56mm 
 
2,000 M203 40mm Under Barrel Launchers 
 
License Value: USD $6,600,000 
 
SELLER: 
 
KNM Worldwide Services 
3917 SE 40th Street 
Ocala, FL 34480 
Tel: 352-653-9551 
 
FOREIGN CONSIGNEE: 
 
BEL Trading and Consulting 
1st Floor, Allied Plaza, Francis Rachel 
Victoria, Mahe 
Seychelles 
Tel: 380445862302 
Mobile: 380674079984 
 
FOREIGN END-USER: 
 
Ministry of Defense of Georgia 
No 20 General G. Kvinitadze Street 0112 
Tbilisi, Georgia 
 
PURPOSE: 
 
For use by the Georgian military services. 
 
¶7. (U) Submitted in support of the license application were 
the following documents (PM/DTCC will fax documentation to 
Posts upon request): 
 
DSP-83 U.S. Nontransfer and Use Certificate signed by Chris 
Brown (KNM Worldwide) dated 29 June 2008, Mamuka Mujiri 
(GMOD) dated 11 Apr 2008, Zaza Gogava (GMOD) dated 11 Apr 
2008, and Almendieiev Arkadii (Bel Trading and Consulting) 
dated 11 Apr 2008; 
 
End-Use Certificate No. 4/41 issued by the Georgian Standing 
Commission on Military-Technical Issues, Ministry of Defence 
signed by Deputy Minister of Defence Mamuka Mujiri dated 06 
Feb 2008; 
 
Letter of Intent Document No. 4/419 signed by Deputy Minister 
of Defence Mamuka Mujiri dated 30 Nov 2007; 
 
Import Permit document number and date illegible (NOTE: 
Signature looks similar to that of Mamuka Mujiri on the 
End-Use Certificate). 
 
¶8. (U) Please slug reply for PM/DTCC - BLUE LANTERN 
COORDINATOR and include the words "Blue Lantern" and the case 
number in the subject line.  POC is Kyle M. Ballard, Phone: 
202-663-1929; Email: BallardKM@state.gov; SIPRNET: 
BallardKM@state.sgov.gov.  The Blue Lantern Guidebook (ref) 
is available as a PDF file on Intellipedia: 
http://www.intelink.gov/wiki/ 
Blue Lantern End-Use Monitoring Program; 
 
¶9. (U) Department is grateful for Post's assistance in this 
matter. 
CLINTON