Cablegate: Blue Lantern Level 3: Bona Fides Inquiry

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RR RUEHWEB

DE RUEHC #7709 0261724
ZNR UUUUU ZZH
R 261718Z JAN 10
FM SECSTATE WASHDC
TO RUEHGB/AMEMBASSY BAGHDAD 0000
INFO RUEHAD/AMEMBASSY ABU DHABI 0000

UNCLAS STATE 007709

SIPDIS
BAGHDAD FOR SCOTT R. FAGAN
POL-MIL

E.O. 12958: N/A
TAGS: ETTC KOMC IZ
SUBJECT: BLUE LANTERN LEVEL 3: BONA FIDES INQUIRY
INVOLVING PARTIES TO TECHNICAL ASSISTANCE AGREEMENT (TAA)
0235-08F

REF: BLUE LANTERN GUIDEBOOK 2006

1. This is an Action Request. See paragraphs 2-4.

2. Reason for request: The Department's Office of Defense
Trade Controls Compliance (PM/DTCC) requests Post's
assistance in conducting a bona fides check on The Olive
Group, Al Mahoo for Telecom Services, and Al Wadi Al Kabeer
Company Ltd. Before approval of the proposed amendment to
Technical Assistance Agreement TAA-0235-08F, which adds the
sublicensees as parties, Post is requested to establish these
companies' bona fides. Post is requested to complete this
Blue Lantern inquiry within 30 days. Lack of response to a
Blue Lantern inquiry will affect pending and future
applications involving parties to this Agreement.

3. Action: The Department requests that Post make inquiries
with the Government of Iraq, Ministry of Defense (MOD) to
confirm the bona fides of The Olive Group, Al Mahoo for
Telecom Services, and Al Wadi Al Kabeer company Ltd. on the
proposed amendment. The following questions are provided as
guidance:

--Does the company have proper supporting documentation,
including a contract with the Iraq MOD for
inclusion on the proposed amendment?

--Will the company be handling or storing United States
Munitions List (USML) items listed in the agreement?
If so, does it have secure facilities and proper accounting
and security procedures for handling these
sensitive USML items?

--When was the company established and who are its
principals? How many and what types of employees
(program managers, service technicians, etc.) does the
company have? What process was used to vet them
for these sensitive roles?

--Does the company appear in Iraqi business directories?
Does the company have a website?

--What is the nature of its business -- what types of items
does it handle, and does it serve as a broker?

--What types of organizations are among its typical customers
and where are the customers located?

--Does the company understand the restrictions on USML items,
especially the prohibition against
unauthorized re-transfers and re-exports?

Finally, Post is asked to assess whether each company appears
to be a reliable recipient of USML items.

End action.

4. Background and Relevant Details Concerning TAA-0235-08F:

The original agreement (TAA-0235-08) approved under
"Operation Iraqi Freedom" on 6 February 2008, covers the
permanent export of unclassified, Significant Military
Equipment (SME) technical data, hardware, and defense
services related to the AN/VRC-series SINCGARS Radio and
associated equipment for the Iraq MOD. It was intended to
permit the U.S. Applicant to collaborate with other parties
to this agreement to provide the Iraq MOD with operation,
installation, transportation, optimization, use, maintenance
support and training related to the defense articles
associated with the agreement.

Pursuant to Section 36(c) of the Arms Export Control Act
(AECA) and Section 123.15(a)(1) of the International Traffic
in Arms Regulations (ITAR), certification was provided to the
Congress prior to granting approval of the transaction since
the export of SME sold under contract exceeded USD
$50,000,000 to, Iraq, a country that is not a member country
of the North Atlantic Treaty Organization (NATO), Australia,
Japan or New Zealand. Now, following Congressional approval
of the original Agreement and five subsequent amendments,
Amendment F, seeks to expand the scope of the Agreement and
increase its value. The amendment requests to add the Olive
Group, an entity that is registered with PM/DTCC, as well as
the two unfamiliar Iraqi parties, named above.

U.S. APPLICANT:

Randy N. Shelton
International Trade Manager
International Trade Group
ITT Corporation
1919 West Cook Road
P.O. Box 3700
Fort Wayne, IN 46801-3700
Tel: (260) 451-7012
Fax: (260) 451-6196
Email: randy.shelton@itt.com

FOREIGN LICENSEE:

Gulf Supplies & Commercial Services (GSCS)
Hamdan Street
Al Fardan Building
Floor #01
Abu Dhabi
United Arab Emirates

FOREIGN SUBLICENSEES:

The Olive Group
PX Road Extension
International Zone
Baghdad
Iraq

Al Mahoo Co. for Telecom Services, Ltd.
District 929, St. 15, Building 16
Arrasat
Baghdad
Iraq

Al Wadi Al Kabeer Company Ltd.
14 of Ramadham
Al-Mansour
Baghdad
Iraq

FOREIGN END-USER:

Iraqi Air Force
TAJI Air Base Iraq
Headquarters at Iraq
Ministry of Defense
Baghdad International Airport
Baghdad
Iraq

5. Purpose:

The Olive Group is a registered security protection agency
that will provide security protection,
translators and transportation to the ITT team in Iraq.
These services will be provided in any
areas where ITT personnel may need to operate in Iraq.

Al-Mahoo Co. for Telecom Services, Ltd. will provide labor
personnel for various tasks including
equipment installation, interpreters and other skilled
positions to assist the ITT team with
operations in Iraq.

Al-Wadi Al-Kabeer Company will also provide labor personnel
for various tasks including equipment
installation, interpreters, welders, and other skilled
positions to assist the ITT team in Iraq.

6. Submitted in support of the license application were the
following documents (PM/DTCC will fax
to Post upon request):

-- Copy of original TAA and various letters between ITT and
PM/DDTC concerning amendments
between January 2008 and 28 July 2009.

7. Please slug reply for PM/DTCC - BLUE LANTERN COORDINATOR
and include the words "Blue Lantern"
and the case number in the subject line. POC is
Rachael-Therese S. Joubert-Lin,
Phone: 202-663-2950; Email: JoubertLinRS@state.gov; SIPRNET:
JoubertLinRS@state.sgov.gov.
The Blue Lantern Guidebook (ref) is available as a PDF file
at
http://www.intelink.sgov.gov/wiki/Blue Lantern End-Use
Monitoring Program.

8. Department is grateful for Post's assistance in this
matter.
CLINTON

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