Dec

11

BIS Announces New Designations to Entity List

Posted by at 12:16 am on December 11, 2008
Category: General

BIS SealLast week, the Bureau of Industry and Security (“BIS”) used section 744.11 of the Export Administration Regulations for a second time to designate sixteen more entities to the Entity List for activities by these entities that could be contrary to the national security or foreign policy interests of the United States. The first round of designations under the section occurred on September 22, 2008. The effect of the designations in this instance is to require a license for all exports to the designated entities and to adopt a policy of denial for all such license requests.

Nine of the newly-designated entities are located in Iran. Since exports to these entities in Iran are already prohibited these new designations are of limited utility except, I suppose, inasmuch as the designation would prohibit exports made to these entities when they are located outside Iran. Additionally, the designation order states that no license exceptions are available for exports to the newly-designated entities, which means that gifts and humanitarian donations to these entities that might otherwise be eligible for license exceptions are now not eligible for export under these exceptions.

The remaining designations are entities in Singapore and the United Kingdom, including Brian Douglas Woodford, a U.K citizen and his Singapore-based company, Monarch Aviation. Woodford’s wife Laura Wang-Woodford was arraigned in February in connection with aircraft parts allegedly exported by Monarch Aviation and the Woodfords to Iran. Brian Woodford is still at large although he does have a LinkedIn Profile up which indicates that he’s interested in “getting back in touch.” I suspect that the DOJ is also interested in getting in touch with him. In the meantime, he’s not getting any Christmas presents sent to him from the United States.

The final designation is as brief as it is vague and reads — in its entirety — as follows: “MCES, London, United Kingdom.” A Google search reveals three companies named MCES in London here, here, and here. So which one is it? Come on, guys, at least give us a hint.

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Copyright © 2008 Clif Burns. All Rights Reserved.
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One Comment:

A classic example for a “Due Diligence” class: 2 recognisably commercial addresses and one less so. http://maps.live.com/ put the postcode in under “Locations” and have a look at the “Birds Eye View” photograph then match up against the likely trade type. Your 1st selection shows what appears to be a residential “mews” address instead of a “road” address, the second shows a commercial premises on the correct road and the third post code shows a residential address completely different to the commercial address quoted, then the 1st selection is the only one registered at “Companies House” under the name given.

Then again if you look up the addresses alone for example you get:
Bee Craft
Shipping Companies (Head Office) based in the Second Way area of Wembley
Tel: 020 89009400
Address: Unit 6 Metro Trading Centre, Second Way Wembley Middlesex HA9 0YU
or
Purcells
4 Quex Road
London
NW6 4PJ
Where Purcells are a firm of accountants and most companies use their Accountants as their registered address.

This lack of clarity will potentially get some people a lot of unwanted and probably unwarranted problems.

Slightly better communications from BIS would be appreciated or at least a Reason For Concern so that reasonable due diligence can be performed by the exporter. i.e. is the subject matter IED support, Iranian Aircraft parts or what?

Or is BIS fishing after picking up some gossip from intelligence. If they know enough that they are happy to publish they should know enough to be able to publish accurately.

Comment by Hamish Jackson on December 11th, 2008 @ 4:21 am