BLUE LANTERN LEVEL 3: PRE-LICENSE CHECK ON APPLICATION

UNCLAS DUBAI 006051

SIPDIS

SENSITIVE
SIPDIS

PM/DTCC - BLUE LANTERN COORDINATOR

E.O. 12958: N/A
TAGS: PK ETTC KOMC AE
SUBJECT: BLUE LANTERN LEVEL 3: PRE-LICENSE CHECK ON APPLICATION
05-050013357 AND 05-1000570

REF: STATE 139498

1.(SBU) Summary: On September 21, PolEconOff conducted reftel
pre-license check, after several attempts, on Al Burach Avio
Support Services (Al Burach). Arqam Iqbal, operating head of Al
Burach, confirmed pending sales to a Jeddah-based logistics
company -- Aircraft Accessories and Components Co. Ltd. (AACC)
-- which holds the Saudi Arabian end-user certificate for reftel
parts. Al Burach intends to send the goods to AACC for onward
delivery to the Saudi MoD. Al Burach consists of a small office
in the Ajman Free Zone with two full-time and two part-time
employees, and never receives shipment of goods, preferring to
send directly to the end-user. Al Burach does not appear to
fully comprehend US licensing regulations and restrictions.
Additionally, due the uncertain nature of AACC and Al Burach's
relationship with that company, Dubai is unable to assess this
pre-license check as favorable. End summary.

2.(SBU) On September 21, PolEconOff conducted reftel pre-license
check on Al Burach, located in the Ajman Free Zone, Building
B-1, Office 416. PolEconoff met Arqam Iqbal, operating head of
Al Burach, at the company's small office -- approximately 300 sq
ft with three desks and several chairs for visitors. Iqbal said
there is no formal structure but he is in charge of Al Burach --
founded and owned by his father, Mohammad Iqbal, who now works
part-time. Iqbal said the 8-year old company has one other
full-time employee, Asif Ebrahim, and another part-time
employee, Saeed Ahmed.

3.(SBU) Iqbal confirmed reftel pending sales to a Jeddah-based
logistics company -- Aircraft Accessories and Components Co.
Ltd. (AACC) -- which holds the Saudi Arabian end-user
certificate for the parts. Iqbal provided a partially legible
fax of the blanket end-user certificate from the Saudi Air Force
to AACC for "helicopter and simulator components." Iqbal
claimed AACC has sent out requirements to many companies,
including Al Burach, to fill out the order "which numbers in the
thousands of parts." Al Burach intends to send the goods to
AACC for onward delivery to the Saudi MoD.

4.(SBU) Iqbal claimed Al Burach never receives shipment of
goods, preferring to send directly to the end-user because it
does not have a warehouse or storage area. Iqbal said the
company does not have the finances to handle large quantity
orders or expensive components. He characterized the items in
reftel order as a typical Al Burach transaction -- low cost and
low quantity. Iqbal claimed most of the company's business is
with commercial carriers. He said "we are a small company and
do not have any 'regular customers'" but have conducted business
with entities in Israel, Saudi Arabia -- including the MoD --
Turkey and the UAE.

5.(SBU) Iqbal provided the following contact information for
AACC:
Mike Kontos, Director of Procurement
Aircraft Accessories and Components Co. Ltd
P.O. Box 126249, Jeddah 21352, Saudi Arabia
Phone: 966 2 669 4888
Fax: 966 2 660 4862

6.(SBU) This is the first pre-license check of Al Burach, and
the company was confused about the process, hoping it could be
avoided altogether. While Al Burach expressed willingness to
comply with US end-use regulations and licensing procedures, it
is clear they lack complete understanding, and given the small
orders they process would prefer not to do business with the US
in the future if "we have to go through all this every time."
Additionally, due to the uncertain nature of AACC and Al
Burach's relationship with that company, Dubai is unable to
assess this pre-license check as favorable.

SUTPHIN