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December 18, 2011 

BIS Adds Two Parties in UAE to Entity List For Diverting Internet Proxy Devices to Syria

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule in the Federal Register on Friday, December 16, 2011, adding the following individual and company in United Arab Emirates to the BIS Entity List
  • Infotec, a.k.a., Info Tech, Ras Al Khaimah Free Trade Zone, U.A.E.
  • Waseem Jawad, Ras Al Khaimah Free Zone, U.A.E.; P.O. Box: 25123, Dubai U.A.E.
The BIS Entity List includes the names of businesses, research institutions, government organizations and individuals that have been identified as being involved in activities that merit additional scrutiny and licensing requirements. The entries on the Entity List specify the license requirements and license review policy that are applicable to shipments to each listed entity and in many cases the listed entities are prohibited from receiving items subject to U.S. jurisdiction.

In this case, the entries on the Entity List for Infotec and Mr. Jawad specify a license requirement for "all items subject to the EAR" and the license review policy is "presumption of denial."

BIS stated that the two parties in the U.A.E. are being added to the Entity List based on evidence that they purchased U.S.-origin internet filtering devices and transshipped the devices to Syria. Specifically, BIS’s Office of Export Enforcement allegedly obtained evidence that Mr. Jawad, using the company name Infotec, ordered multiple Blue Coat SG9000-20 Proxy devices in December 2010 from a Blue Coat authorized distributor in the U.A.E. That authorized distributor in turn placed an order for the devices with Blue Coat in the U.S. A December 2010 email notification identified the end-user of the Blue Coat products for this order as the Ministry of Communication in Baghdad, Iraq. In February 2011, the devices were shipped from the U.s. to the United Arab Emirates, and ownership was transferred to Mr. Jawad in the Ras Al Khaimah Free Trade Zone in the U.A.E. Approximately three days later, the devices departed the U.A.E. for delivery to Syria. According to BIS, several of the proxy devices were identified by serial number as devices being used by the Syrian Telecommunications Establishment in Damascus, Syria.

BIS's December 16, 2011 final rule also removed the following four entities from Entity List based on the results of the annual review of the Entity List:


(1) Strive Components, Block 10 Toa Payoh Industrial Park Lor 8 #01–1221, Singapore, 319062; and
(2) Synoptics Imaging Systems Pte Ltd., 12 Lor Bakar Batu #06–09, Singapore, 348745.


(1) Christine Sun, 7th Floor, Number 17, Zhonghua Rd., Sec 2, Xinzhuang City, Taipei, Taiwan; and
(2) In-Tech Company, a.k.a., In-Tech Telecom, Number 15, Lane 347, Jhongjheng Road, Sinjihuang City, Taipei, Taiwan, and 7th Floor, Number 17, Zhonghua Rd., Sec 2, Xinzhuang City, Taipei, Taiwan.

The removal of the four entities from the Entity List eliminates the existing BIS license requirements for exports, reexports and in-country transfers to the four entities. However, the removal of these four entities from the Entity List does not relieve persons of other obligations under part 744 of the EAR or under other parts of the EAR.

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