Imposition of Nonproliferation Sanctions Against Foreign Entities and Individuals
On February 11, 2013, the Department of State announced the imposition of nonproliferation sanctions on several foreign entities and individuals under multiple U.S. authorities.
Pursuant to the Iran, North Korea, and Syria Nonproliferation Act (INKSNA), a determination was made to impose sanctions on: two Belarusian entities [TM Services Limited (TMS) and Scientific and Industrial Republic Unitary Enterprise (aka DB Radar)]; four Chinese entities [BST Technology and Trade Company, China Precision Machinery Import and Export Corporation (CPMIEC), Dalian Sunny Industries, and Poly Technologies Incorporated] and one Chinese individual [Li Fangwei (aka Karl Lee)]; two Iranian entities [Iran Electronics Industries (IEI) and Marine Industries Organization (MIO)] and one Iranian individual [Milad Jafari]; two Sudanese entities [Al-Zargaa Engineering Complex (ZEC) and SMT Engineering]; one Syrian entity [Army Supply Bureau (ASB)]; and one Venezuelan entity [Venezuelan Military Industry Company (CAVIM)]. INKSNA sanctions were imposed on these entities and individuals because there was credible information indicating they had transferred to, or acquired from, Iran, North Korea, or Syria, equipment and technology listed on multilateral export control lists (Australia Group, Chemical Weapons Convention, Missile Technology Control Regime, Nuclear Suppliers Group, Wassenaar Arrangement), or items that are not listed, but nevertheless, could materially contribute to a weapons of mass destruction (WMD) or cruise or ballistic missile program.
A separate determination was made to impose missile proliferation sanctions under the Arms Export Control Act (AECA) and Export Administration Act (EAA) on the Chinese individual Li Fangwei (aka Karl Lee) and his company, Dalian Sunny Industries, for transferring equipment and technology controlled under the Missile Technology Control Regime (MTCR) Annex to MTCR-class (Category I) missiles in a non-MTCR country.
The United States also imposed sanctions pursuant to Executive Order (E.O.) 12938, as amended, on Li Fangwei (aka Karl Lee), Dalian Sunny Industry, and the Iranian entities Shahid Bakeri Industrial Group (SBIG), Shahid Sattari Ground Equipment Industries, and the Ministry of Defense and Armed Forces Logistics (MODAFL), because these entities contributed materially (or posed a risk of contributing materially) to the proliferation of WMD or their means of delivery (including missiles capable of delivering such weapons).
These sanctions (INKSNA, AECA/EAA, E.O.), and the specific penalties levied on the sanctioned entities, were announced in the Federal Register (Vol. 78 No. 28) on February 11, 2013. The sanctions were imposed for a period of two years and will expire in February 2015.