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15 Added to Entity List for Sending IED Components to Iraq and Iran

Wednesday, October 26, 2011
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security announced Oct. 25 that it will add 15 parties located in China, Hong Kong, Iran and Singapore to the Entity List for acting contrary to U.S. national security or foreign policy interests.

Eight parties are being added based on evidence that they knowingly participated in a complex and layered network that engaged in complicated and long-term schemes to divert U.S.-origin items through deceptive actions, including shifting/circuitous routes and false or omitted information on shipping documentation. Among other activities, this procurement network arranged for the transshipment of controlled radio frequency modules from the U.S. through Singapore to Iran for use in improvised explosive devices found in Iraq; obtained controlled antennas designed for use in military radars and aircraft and exported them to Singapore and Hong Kong; and transshipped a range of U.S.-origin goods, including acrylic polymers and fiberglass tape, through Hong Kong to Iran.

The remaining seven parties are being added based on evidence that they are related to and aided and/or facilitated the activities of the procurement network, including by serving as front companies.

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