BLUE LANTERN LEVEL 3: PRE-LICENSE END-USE CHECK

UNCLAS STATE 130257

SIPDIS
SANTIAGO FOR JENNIFER SPANDE
POL

E.O. 12958: N/A
TAGS: ETTC KOMC CI
SUBJECT: BLUE LANTERN LEVEL 3: PRE-LICENSE END-USE CHECK
ON APPLICATION 050135240

REF: BLUE LANTERN GUIDEBOOK 2006


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


2. The Department's Office of Defense Trade Controls
Compliance (PM/DTCC) requests post's assistance in conducting
a pre-license check on application 050135240 for the export
of UH-1H helicopter parts to Chile. Post is requested to
complete this Blue Lantern check within 30 days. Lack of
response to a Blue Lantern check will affect pending and
future applications involving parties to this license.


3. Reason for request: unusual end-use by an unfamiliar
foreign end-user and an unfamiliar consignee, neither of whom
has appeared on any previous license applications. Post
should make appropriate inquiries to verify the bona fides of
private Chilean companies Flight Service, S.A., and JL
Commercial Services, to determine how one of the companies
came to be in possession of one or more UH-1H military
helicopters, and to confirm the legitimacy of the proposed
transaction. The following questions are provided as
suggested guidance:

--When was the company established and who are its principals?

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

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

--Do Flight Service and/or JL Commercial Services own and/or
operate UH-1H military helicopters? If so, how many UH-1H
helicopters does the company own? How and from whom did the
company acquire the helicopters? Does the company have
certification that the UH-1H helicopters were officially
de-militarized? (COMMENT: Judging from the company's
website, Flight Service appears to own at least four UH-1H
helicopters. END COMMENT.)

--Which entity is performing the forest fire fighting
services? On whose behalf are the services being performed?
For what other purposes does the company use the UH-1H
helicopters?

--Do the helicopters really require $3 million worth of spare
parts, or is a lesser amount more realistic?

--What is the relationship between the two companies, and
what exact roles will they play in the proposed transaction?
--Will the company be handling or storing the items listed on
the application? If so, does it have secure facilities and
proper accounting and security procedures for handling these
United States Munitions List (USML) items?

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


4. Department requests that post conduct a site visit to JL
Commercial Services -- and to Flight Service, if possible --
in order to provide Department with an assessment of its
business operations and on-site security. If a site visit is
not possible, please inform PM/DTCC case officer. Finally,
post is asked to assess whether the companies appear to be
reliable recipients of USML items. End action.


5. For background, the following details of the license in
question are provided:

DTC Case: 050135240

QUANTITY/COMMODITY:

1 Miscellaneous spare parts for the maintenance, repair
and/or overhaul of the T53L13B gas turbine engine for the
Bell Helicopter model UH-1H helicopter

License Value: USD 3,000,000.00

SELLER:

Transupport, Inc.
53 Turbine Way
Merrimack, NH 03054
Company contact: Jeffrey Foote, tel.: 603-424-3111

FOREIGN CONSIGNEE:

JL Commercial Services
Av. Fidias #769A
La Reina
Santiago de Chile 7870446
Chile
Telephone/fax: (56-2) 4151614
Mobile: 89709100
E-mail: jlcomser@vtr.net
Website: www.jlcomser.com
Company contact: Juan J. Loyola, Legal Representative

FOREIGN END-USER:

Flight Service, S.A.
Alonso Ovalle #237 L San Andres
Concepcion
Chile
Website: www.flightservice.cl

PURPOSE:

For the maintenance, repair and/or overhaul of the T53L13B
gas turbine engine used on the Bell model UH-1H helicopter by
the end-user...for fighting forest fires.


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

--Letter of intent from JL Commercial Service to Transupport
advising of the intent to purchase $3 million worth of
T53L13B gas turbine engine spare parts during fiscal years
2008-2001 and stating that the "the end user of these spare
parts will be the JL Commercial Services in Chile," signed by
Juan J. Loyola, Legal Representative, dated 11 November 2008.


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 Judd Stitziel, PM/DTCC, Phone:
202-663-3455; email: StitzielJD@state.gov; SIPRNET:
StitzielJD@state.sgov.gov. The Blue Lantern Guidebook (ref)
is available as a PDF file in the Bunche Library's Electronic
Library collection on the DOS Intranet:
http://virtuallibrary.state.gov/
BlueLanternGuidebook2006%2520 final .pdf


8. Department is grateful for post's assistance in this
matter.
RICE