Back in April, I reported on a Bureau of Industry and Security (“BIS”) settlement with Aqua Loop Cooling Towers which arose out of the export of EAR99 items by Aqua Loop to a company in Iran by transshipment of those items through Dubai. Under the settlement agreement, Aqua Loop agreed to a ten-year denial order and a $100,000 suspended penalty.

Of particular interest, the original blog post noted that the Iranian recipient of the exported items, a company called Parto Abgardan, was oddly straight-forward on its website about it’s connection to Aqua Loop, calling Aqua Loop its “sister factory” in the United States. Such a relationship between Aqua Loop and the Iranian company would pose more problems, of course, than just the exports at issue in the Aqua Loop settlement agreement.

Although I know that some folks at BIS read these posts, I don’t know whether or not they were aware of the Patro Abgardan’s claims of a relationship with Aqua Loop before I pointed it out in my post on the settlement agreement. Whatever the case, about a month later, BIS sent a “Related Person’s Notice and Request” Letter to Parto Abgardan in Iran noting the website’s claim of having a “sister factory” in the United States at the same address as Aqua Loop.

Now comes the good part. Someone named Mahmoud Lazemizadeh responded to the letter, saying “”no connection of any kind between this company and Aqua-loop cooling towers Co. [sic].” Uh-huh. Just pay not attention to our website. Needless to say, it was everything BIS could do not to reply to Mr. Lazemizadeh with Judge Judy’s famous riposte: “Don’t p**s on my leg and tell me it’s raining. To make things worse, the the nephew of Mr. Lazemizadeh was transferred from Parto Abgardan in Iran to California in five years. No, there’s no connection of any kind.

As a result, BIS recently issued a new ten-year denial order against Parto Abgardan. The new denial order, except to the extent that it includes Parto Abgardan at Aqua Loop’s address in California, is somewhat superfluous. With or without that order, U.S. exports to Parto Abgardan at its various addresses in Iran are already forbidden. More interestingly, I have to wonder whether further action against Aqua Loop may be lurking in the background. Aqua Loop’s relationship with the Iranian company certainly poses problems under the Office of Foreign Assets Control’s Iranian Transaction Regulations which prohibits any U.S. person from providing services to Iranian companies (other than with respect to limited exceptions not applicable here.)

Permalink


Copyright © 2010 Clif Burns. All Rights Reserved.
(No republication, syndication or use permitted without my consent.)