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

UNCLAS STATE 133633

SIPDIS
ABUJA FOR GEOFFREY MARTINEAU AND ROME FOR CHRIS CURRAN

E.O. 12958: N/A
TAGS: ETTC KOMC NI IT
SUBJECT: BLUE LANTERN LEVEL 3: PRE-LICENSE END-USE CHECK
ON APPLICATION 050133135

REF: 2006 BLUE LANTERN GUIDEBOOK


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-shipment check on application 050133135 for the export
of NVD component parts to Nigeria. 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 licenses involving parties to this license.


3. Reason for request: Lack of documentation from foreign
end-user the Nigerian Navy and unfamiliar foreign consignee
AERA S.P.A. The company has not appeared on previous
licenses nor have the bona fides of the company been verified
by a Blue Lantern check.


4. ACTION ABUJA: Embassy is requested to make inquiries with
appropriate host government officials to determine if the
Nigerian Navy ordered the NVD component parts and if so, that
the articles will be used for the purpose stated on the
license. Post is requested to exercise its contacts within
the Nigerian MoD to verify this order.
END ACTION


5. ACTION ROME: Department requests that Embassy make
appropriate inquiries to verify the bona fides of foreign
consignee AERA S.P.A., and to confirm the legitimacy of this
transaction. PM/DTCC also requests that post conducts a site
visit to the company in order to provide Department with an
assessment of its business operations and on-site security.
Finally, post is asked to assess whether the company appears
to be a reliable recipient of USML items. If a site visit is
not possible, please inform the PM/DTCC officer (see para 8).
The following questions are provided as suggested guidance:

--Does the company have supporting documentation for this
proposed transaction?

--Does the company have secure facilities and proper
accounting and security procedures for handling sensitive
USML items?

--Will AERA S.P.A. retain positive control over the NVD
component parts at all times?

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

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

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

--Does the company understand the restrictions on United
States Munitions List (USML) items, especially the
prohibition against unauthorized re-transfers and re-exports?

END ACTION


6. Details of license application:

DTC Case: 050133135

QUANTITY/COMMODITY:

14 95-10-17-M6-70972 VIVISUN Illuminated Pushbutton Switch
Compatible with NVIS goggles and complies with NVIS color and
NVIS radiance requirements defined in MIL-L-85762A
8 95-10-17-P6-70973 VIVISUN Illuminated Pushbutton Switch
Compatible with NVIS goggles and complies with NVIS color and
NVIS radiance requirements defined in MIL-L-85762A

License Value: USD 10,736.00

SELLER:

Aerospace Optics, Inc.
3201 Sandy Lane
Fort Worth, TX 76112
POC is J M Davis, Tel. 817-451-1141 ext.236

FOREIGN CONSIGNEE:

AERA S.P.A.
Via Cefalonia 18
Milano 20156
Italy
POC is CEO, Pietro Mantovani, Tel. 39-02-33483-1

FOREIGN END-USER:

Nigerian Navy
Wilmont Point
Lagos
Nigeria
No POC provided

PURPOSE:

The equipment will be installed on A-109 Agusta Helicopters.
Two switches are commercial pushbutton switches with NVIS
compatible lighting options. They are installed on the
weapon control panels. The weapon control panels are
installed in the cockpits of the A-109 helicopters.


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

--Purchase Order No. 081764 submitted by AERA S.P.A. on 6
October 2008, illegible signature

--End-use Declaration submitted by AERA S.P.A., signed by
CEO, Pietro Mantovani on 6 October 2008


8. 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 Tim Mazzarelli, Phone:
202-663-3867; Email: MazzarelliTP@state.gov; SIPRNET:
MazzarelliTP@state.sgov.gov. The Blue Lantern Guidebook
(ref) is available as a PDF file in the Bunche Library's
E-Book Collection on the DOS Intranet:
http://buncheelectroniclibrary.state.gov/eboo ks/
BlueLanternGuidebook2006%20 final .pdf


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