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DE RUEHC #7709 0261724
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TO RUEHGB/AMEMBASSY BAGHDAD 0000
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UNCLAS STATE 007709 
 
SIPDIS 
BAGHDAD FOR SCOTT R. FAGAN 
POL-MIL 
 
E.O. 12958: N/A 
TAGS: ETTC KOMC IZ
SUBJECT: BLUE LANTERN LEVEL 3: BONA FIDES INQUIRY 
INVOLVING  PARTIES TO TECHNICAL ASSISTANCE AGREEMENT (TAA) 
0235-08F 
 
REF: BLUE LANTERN GUIDEBOOK 2006 
 
¶1. This is an Action Request. See paragraphs 2-4. 
 
¶2. Reason for request: The Department's Office of Defense 
Trade Controls Compliance (PM/DTCC) requests Post's 
assistance in conducting a bona fides check on The Olive 
Group, Al Mahoo for Telecom Services, and Al Wadi Al Kabeer 
Company Ltd.   Before approval of the proposed amendment to 
Technical Assistance Agreement TAA-0235-08F, which adds the 
sublicensees as parties, Post is requested to establish these 
companies' bona fides.  Post is requested to complete this 
Blue Lantern inquiry within 30 days. Lack of response to a 
Blue Lantern inquiry will affect pending and future 
applications involving parties to this Agreement. 
 
¶3. Action:  The Department requests that Post make inquiries 
with the Government of Iraq, Ministry of Defense (MOD) to 
confirm the bona fides of The Olive Group, Al Mahoo for 
Telecom Services, and Al Wadi Al Kabeer company Ltd. on the 
proposed amendment.  The following questions are provided as 
guidance: 
 
--Does the company have proper supporting documentation, 
including a contract with the Iraq MOD for 
inclusion on the proposed amendment? 
 
--Will the company be handling or storing United States 
Munitions List (USML) items listed in the agreement? 
If so, does it have secure facilities and proper accounting 
and security procedures for handling these 
sensitive USML items? 
 
--When was the company established and who are its 
principals? How many and what types of employees 
(program managers, service technicians, etc.) does the 
company have?  What process was used to vet them 
for these sensitive roles? 
 
--Does the company appear in Iraqi business directories? 
Does the company have a website? 
 
--What is the nature of its business -- what types of items 
does it handle, and does it serve as a broker? 
 
--What types of organizations are among its typical customers 
and where are the customers located? 
 
--Does the company understand the restrictions on USML items, 
especially the prohibition against 
unauthorized re-transfers and re-exports? 
 
Finally, Post is asked to assess whether each company appears 
to be a reliable recipient of USML items. 
 
End action. 
 
¶4. Background and Relevant Details Concerning TAA-0235-08F: 
 
The original agreement (TAA-0235-08) approved under 
"Operation Iraqi Freedom" on 6 February 2008, covers the 
permanent export of unclassified, Significant Military 
Equipment (SME) technical data, hardware, and defense 
services related to the AN/VRC-series SINCGARS Radio and 
associated equipment for the Iraq MOD. It was intended to 
permit the U.S. Applicant to collaborate with other parties 
to this agreement to provide the Iraq MOD with operation, 
installation, transportation, optimization, use, maintenance 
support and training related to the defense articles 
associated with the agreement. 
 
Pursuant to Section 36(c) of the Arms Export Control Act 
(AECA) and Section 123.15(a)(1) of the International Traffic 
in Arms Regulations (ITAR), certification was provided to the 
Congress prior to granting approval of the transaction since 
the export of SME sold under contract exceeded USD 
$50,000,000 to, Iraq, a country that is not a member country 
of the North Atlantic Treaty Organization (NATO), Australia, 
Japan or New Zealand.  Now, following Congressional approval 
of the original Agreement and five subsequent amendments, 
Amendment F, seeks to expand the scope of the Agreement and 
increase its value.  The amendment requests to add the Olive 
Group, an entity that is registered with PM/DTCC, as well as 
the two unfamiliar Iraqi parties, named above. 
 
 
U.S. APPLICANT: 
 
Randy N. Shelton 
International Trade Manager 
International Trade Group 
ITT Corporation 
1919 West Cook Road 
P.O. Box 3700 
Fort Wayne, IN  46801-3700 
Tel: (260) 451-7012 
Fax: (260) 451-6196 
Email: randy.shelton@itt.com 
 
 
FOREIGN LICENSEE: 
 
Gulf Supplies & Commercial Services (GSCS) 
Hamdan Street 
Al Fardan Building 
Floor #01 
Abu Dhabi 
United Arab Emirates 
 
FOREIGN SUBLICENSEES: 
 
The Olive Group 
PX Road Extension 
International Zone 
Baghdad 
Iraq 
 
Al Mahoo Co. for Telecom Services, Ltd. 
District 929, St. 15, Building 16 
Arrasat 
Baghdad 
Iraq 
 
Al Wadi Al Kabeer Company Ltd. 
14 of Ramadham 
Al-Mansour 
Baghdad 
Iraq 
 
FOREIGN END-USER: 
 
Iraqi Air Force 
TAJI Air Base Iraq 
Headquarters at Iraq 
Ministry of Defense 
Baghdad International Airport 
Baghdad 
Iraq 
 
¶5. Purpose: 
 
The Olive Group is a registered security protection agency 
that will provide security protection, 
translators and transportation to the ITT team in Iraq. 
These services will be provided in any 
areas where ITT personnel may need to operate in Iraq. 
 
Al-Mahoo Co. for Telecom Services, Ltd. will provide labor 
personnel for various tasks including 
equipment installation, interpreters and other skilled 
positions to assist the ITT team with 
operations in Iraq. 
 
Al-Wadi Al-Kabeer Company will also provide labor personnel 
for various tasks including equipment 
installation, interpreters, welders, and other skilled 
positions to assist the ITT team in Iraq. 
 
¶6. Submitted in support of the license application were the 
following documents (PM/DTCC will fax 
to Post upon request): 
 
-- Copy of original TAA and various letters between ITT and 
PM/DDTC concerning amendments 
between January 2008 and 28 July 2009. 
 
¶7. 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 
Rachael-Therese S. Joubert-Lin, 
Phone: 202-663-2950; Email: JoubertLinRS@state.gov; SIPRNET: 
JoubertLinRS@state.sgov.gov. 
The Blue Lantern Guidebook (ref) is available as a PDF file 
at 
http://www.intelink.sgov.gov/wiki/Blue Lantern End-Use 
Monitoring Program. 
 
¶8. Department is grateful for Post's assistance in this 
matter. 
CLINTON