The Bureau of Industry and Security (“BIS”) recently imposed a temporary denial order (“TDO”) on Singapore-based Anvik Technologies, and its owner Babak Jafarpour. The TDO is based on evidence that BIS alleges that it has demonstrating that Anvik and Jafarpour exported items from the United States to Iran by transshipment through third countries.

What’s interesting here is that the transshipment points were “virtual offices” that Anvik maintained in the United States, Hong Kong and Malaysia. Virtual offices are arrangements with companies that provide an address, a telephone number, answering services and other office services to individuals and companies that don’t have actual physical space at the location and may not ever be actually present in that office.

In one of the transactions described in the TDO an order was placed by Anvik with a U.S. company to ship items to Anvik’s virtual office located at 155 North Wacker Drive, 42nd Floor, Chicago, Illinois 60606. Anvik then instructed the personnel at the Chicago location to ship the items to Anvik’s virtual office in Kuala Lumpur. Anvik instructed the Malaysia virtual office to ship the items to Iran.

Two things are worth noting here. First, should shippers and exporters consider a request to ship items to a virtual office a red flag that the items may be diverted to an impermissible location or party? If you search for “155 North Wacker Drive, 42nd Floor” in Google, this is the first returned result:

So, it wouldn’t take a rocket scientist or back-breaking due diligence to discover that Anvik was using a virtual office and not a real one. This should trigger a further investigation by a shipper as to the identity of Anvik and why it was shipping merchandise to a virtual office in a Chicago high-rise.

Second, the Chicago address is soon going to be on the BIS Denied Parties list. And what is the first red flag on BIS’s list of Red Flags?

The customer or its address is similar to one of the parties found on the Commerce Department’s [BIS’s] list of denied persons.

As a result, other “tenants” at the same North Wacker Drive address may start to encounter difficulties in having packages shipped to that address as shippers and exporters encounter that red flag.

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