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UNCLAS STATE 092825 
 
SIPDIS 
BUENES AIRES FOR BRIAN JENSEN 
 
E.O. 12958: N/A 
TAGS: ETTC KOMC AR
SUBJECT: BLUE LANTERN: VERIFYING BONA FIDES OF  REGISTERED 
BROKER  RENATA LUIS BUCELLO - CASE NO. K-2596 
 
REF: A. SECTION 38(B)(1)(A)(II) OF THE ARMS 
     ¶B. EXPORT CONTROL ACT (AECA)(22 U.S.C. 2778) 
 
¶1. This is an Action Request.  See paragraphs 3-4. 
 
¶2.  U.S. embassies have frequently inquired about 
the legitimacy of arms export transactions involving 
U.S. contractors and host-country partners in support 
of U.S. efforts in Iraq and Afghanistan, or other U.S. 
government programs.  The Department's Office of 
Defense Trade Controls Compliance (PM/DTCC) wishes 
to inform Post that U.S. or foreign persons who are 
involved in brokering U.S. defense articles or 
services, or any defense articles or services pursuant 
to U.S. procurement contracts for Iraq and Afghanistan 
or other destinations under USG auspices, must be 
registered with PM/DTCC and obtain Department's 
approval for their brokering activities. 
 
¶3.  ACTION:  PM/DTCC requests Post's assistance in 
conducting an inquiry into the brokering activities 
of the U.S. registered broker listed below to 
substantiate its bona fides.  Department requests that 
Post conduct a site visit to the company in order to 
assess its business operations, on-site security, 
and reliability as a broker/recipient of United States 
Munitions List (USML) items.  If a site visit is not 
possible, please inform the PM/DTCC case officer. 
Post is requested to complete this inquiry within 
60 days: 
 
RENATA LUIS BUCCELLO, MANAGER PARTNER 
BUCCELLO Y ASOCIADOS, SRL 
EDUARDO COSTA 2024, MARTINEZ 
PROVINCIA BUENOS AIRES 1640 
ARGENTINA 
TEL: 541147332022 
FAX: 541147938268 
 
¶4.  The following points are provided for 
guidance: 
 
-- Confirm that this entity is in the business of 
brokering defense articles and defense services 
at the location(s) indicated under its legal name(s); 
 
-- Determine whether this entity is authorized to 
conduct such activities in its home country, 
whether the entity has any criminal or other 
derogatory background, and whether Post has 
any information on its brokering or arms export 
activities that may involve proscribed entities 
such as countries under U.S. or international 
sanctions, or designated state sponsors of 
terrorism; 
 
-- Will the brokering firm be handling or storing 
USML items on behalf of its clients?  If so, does 
it have secure facilities and proper accounting 
and security procedures for handling sensitive 
USML items? 
 
-- When was the company established and who are 
its principals?  How many employees? 
 
-- What is the nature of its business and what 
other types of items does it handle? 
 
 -- What types of organizations are among its 
typical clients and in what countries are 
they located? 
 
-- Does the company understand the restrictions on 
USML items, especially the prohibition against 
unauthorized re-transfers and re-exports? 
 
END ACTION. 
 
--------------------------------------------- 
              BACKGROUND ON BROKERING 
REGISTRATION AND AUTHORIZATION 
--------------------------------------------- 
 
¶5. PM/DTCC provides the following background 
information on the requirements for registration 
and obtaining prior approvals for brokering 
activities: 
 
The requirements for Registration and Obtaining Prior 
Approvals for Brokering Activities are based in the 
Arms Export Control Act (AECA).  The Brokering 
Requirements are administered by PM/DTCC. 
 
Section 38(b)(1)(A)(II) of the AECA requires 
registration for any person "who engages in the 
business of brokering activities with respect 
to the manufacture, export, import, or transfer 
of any defense article or defense service". 
 
According to the International Traffic in Arms 
Regulations (ITAR) Section 129.2(a), a broker 
is defined as: 
 
"any agent for others in negotiating or arranging 
contracts, purchases, sales or transfers of 
defense articles or defense services in return 
for a fee, commission, or other consideration." 
 
Additionally, ITAR Section 129.2(b) states that 
"brokering activities means acting as a broker 
as defined (above), and includes financing, 
transportation, freight forwarding, or taking of 
any other action that facilitates the manufacture, 
export or import of a defense articles or defense 
service, irrespective of its origin." 
 
Authorization is typically required for brokering 
activity.  However, some activities are exempt from 
these requirements depending on the commodity, the 
countries involved, and the existence of previous 
authorization.  Any questions about specific cases 
may be directed to this office to the attention of 
Deborah Carroll, Chief, Compliance & Registration. 
Phone: 202-663-2809; SIPRNET: 
carrolld@state.sgov.gov. 
 
End background on brokering registration 
and authorization. 
 
¶6.  Please slug reply for PM/DTCC and include the 
words "Blue Lantern Broker Inquiry" and the case 
number in the Subject line.  POC is 
Rachael-Therese S. Joubert-Lin, Phone: 
202-663-2950; Email: JoubertLinRS@state.gov; 
SIPRNET:JoubertLinRS@state.sgov.gov. 
The Blue Lantern Guidebook is available as a PDF 
file at http://www.intelink.sgov.gov/wiki/Blue 
Lantern End-Use Monitoring Program. 
 
 
¶7.  Department is grateful for Post's assistance in this 
matter. 
CLINTON