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Revised Effective Date for Nonproliferation Measures on Nearly 25 Entities

Tuesday, October 27, 2015
Sandler, Travis & Rosenberg Trade Report

The State Department has revised from Sept. 2 to Aug. 28 the effective date of nonproliferation measures imposed against certain foreign persons for the transfer to or acquisition from Iran, Syria or North Korea of goods, services or technology controlled under multilateral control lists or otherwise having the potential to make a material contribution to the development of weapons of mass destruction or cruise or ballistic missile systems. U.S. law provides that the application of such measures must be announced by notice published in the Federal Register but under certain circumstances such measures are effective on the date the report identifying the foreign person or persons is submitted to Congress (which, in this case, occurred on Aug. 28).

As a result, effective for two years as of Aug. 28, the following measures are imposed against the designated entities and any successors, sub-units or subsidiaries thereof: (1) no U.S. government department or agency may procure or enter into any contract for the procurement of any goods, technology or services from these foreign persons; (2) no U.S. government department or agency may provide any assistance to these persons and they will not be eligible to participate in any U.S. government assistance program; (3) no U.S. government sales to these foreign persons of any item on the U.S. Munitions List are permitted and all sales to these persons of any defense articles, defense services, or design and construction services under the Arms Export Control Act are terminated; and (4) no new individual licenses will be granted for the transfer to these persons of items the export of which is controlled under the Export Administration Act of 1979 or the Export Administration Regulations, and any existing such licenses are suspended.

The designated entities are as follows.

- BST Technology and Trade Company (China)

- Dalian Sunny Industries (China)

- Li Fang Wei (China)

- Tianjin Flourish Chemical Company (China)

- Qasem Soleimani (Iran)

- Iranian Revolutionary Guard Corps Qods Force

- Rock Chemie (Iran)

- Polestar Trading Company Ltd. (North Korean entity in China)

- RyonHap-2 (North Korea)

- Instrument Design Bureau Tula (Russia)

- Joint Stock Company Katod (Russia)

- JSC Mic NPO Mashinostroyenia

- Rosoboronexport (Russia)

- Russian Aircraft Corporation MiG (Russia)

- Sudanese Armed Forces (Sudan)

- Vega Aeronautics (Sudan)

- Yarmouk Complex (Sudan)

- Ayman al Shaher (Syria)

- Hizballah facilitators for logistics (Syria)

- Lebanese Hizballah (Syria)

- Syrian Air Force (Syria)

- Multimat Ic ve Dis Ticaret Pazarlama Limited (Turkey)

- Eliya General Trading (United Arab Emirates)

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