S E C R E T STATE 111428


E.O. 12958: DECL: 10/08/2018
TAGS: MNUC PARM PREL XB ZP AE ZO

SUBJECT: PRE NOTIFICATION OF SANCTIONS AGAINST UAE ENTITY

Classified By: NEA Gene A. Cretz for reasons 1.4 b,c,d


1. (U) This is an action request. Please see paragraph three.

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SUMMARY
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2. (S) The United States will impose sanctions under the
Iran, North Korea, and Syria Nonproliferation Act (INKSNA) on
22 October. There are also other firms in other countries
that will be reported to Congress for INKSNA violations. One
UAE company - R and M International Free Zone Company (FZCO)
) will be among those sanctioned.

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ACTION REQUEST
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3. (S) Post is requested to pre-notify the UAE at least 24
hours in advance of the U.S. announcement of its decision to
sanction R and M International FZCO under INKSNA and explain
why we are taking this action. The Department will notify
Post via email as soon as a decision has been made to make
the sanctions public. Please draw from the talking points in
paragraph seven.

End action request.

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OBJECTIVES
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4. (S) Post should achieve the following objectives:

-- Given our close cooperation on counterproliferation, note
our desire to provide prior notification of a sanction
decision that will affect one UAE company - R and M
International FZCO.

-- Emphasize that sanctions are not directed at the UAE but
only at the company.

-- Encourage the UAE to investigate the company.

End objectives.

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BACKGROUND
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5. (S) The Iran, North Korea, and Syria Nonproliferation Act
(INKSNA) requires periodic reports to Congress identifying
foreign entities with respect to whom there is credible
information indicating that they have transferred to or
acquired from Iran, North Korea or Syria goods, services, or
technology on multilateral export control lists (Australia
Group (AG), Chemical Weapons Convention (CWC), Missile
Technology Control Regime (MTCR), Nuclear Suppliers Group
(NSG), and the Wassenaar Arrangement (WA) or certain other

items with the potential to make a material contribution to
the development of WMD or ballistic or cruise missile
systems. The U.S. has the discretion to impose sanctions on
such foreign entities.


6. (S) The USG has determined that R and M International FZCO
(located in the UAE) has engaged in activities, as noted
above, that warrant the imposition of sanctions under the
INKSNA. This case has not been raised previously with the UAE
Government. Penalties imposed by the sanction will take
effect shortly and remain in place for two years. This
sanctions determination and the name of the company will be
published in the Federal Register once a decision has been
made by the Department to notify Congress and the public.

End Background.

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TALKING POINTS
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7. (S/REL UAE) Suggested Talking Points:

-- The Iran, North Korea, and Syria Nonproliferation Act
(INKSNA) requires the USG to report transfers made by
foreign entities with respect to whom there is credible
information indicating that they have transferred to or
acquired from Iran, North Korea or Syria goods, service, or
technology on multilateral control lists (Australia Group
(AG), Chemical Weapons Convention (CWC), Missile Technology
Control Regime (MTCR), Nuclear Suppliers Group (NSG), and the
Wassenaar Arrangement (WA) or certain other items with the
potential to make a material contribution to the development
of WMD or ballistic or cruise missile systems.

-- The United States has determined that there was credible
information indicating that the UAE-based company, R and M
International FZCO transferred items listed under the
multilateral control list Wassenaar Arrangement to Syria - a
country named in INKSNA.

-- Syria,s Ministry of the Interior arranged for the
purchase of bullet proof vests worth nearly $700,000 (USD)
from the R and M International FZCO in July 2006. The vests
were to be used by the Ministry,s Internal Security Forces
at the Department of Administrative Affairs in Damascus.

-- These bullet proof vests are controlled under the
Wassenaar Arrangement and are therefore reportable under the
INKSNA.

-- We have information that R and M International FZCO is
located at the Jebel Ali Free Zone, P.O. Box 2619092, Dubai.

-- There are also other firms in other countries that will be
reported to Congress for INKSNA violations.

-- The imposition of this sanction is directed only at R and
M International FZCO and not at the UAE.

-- We will announce publicly in the Federal Register the
imposition of penalties against R and M International FZCO as
well as sanctions against other entities located in other
countries.

-- We encourage you to investigate R and M International
FZCO, its successors, subunits, and subsidiaries for possible
violations of your laws.

-- The following penalties, which will take effect shortly
and remain in place for two years, will be imposed on R and M
International FZCO, its successors, subunits, and
subsidiaries:

a. No department or agency of the United States
Government may procure, or enter into any contract for
the procurement of any goods, technology, or services
with R and M International FZCO, its successors, subunits,
and subsidiaries;

b. No department or agency of the United States
Government may provide any assistance to them, and they
shall not be eligible to participate in any assistance
program of the United States Government;

c. No United States Government sales to them of any
item on the United States Munitions List are permitted,
and all sales to them of any defense articles, defense
services, or design and construction services under the
Arms Export Control Act are terminated; and

d. No new individual licenses shall be granted for the
transfer to them of items controlled under the Export
Administration Act of 1979 or the Export Administration
Regulations, and existing such licenses are suspended.

-- We look forward to continued cooperation on this and other
related security matters.

End talking points.

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POINT OF CONTACT
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8. (U) Washington point of contact is Stephen Tomchik, VCI/FO
and Chris Herrington ISN/CPI. Please slug all responses for
VCI, ISN, NEA, and T. We appreciate Post,s assistance.
RICE


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