EXTRANCHECK: PRE-LICENSE AND POST-SHIPMENT VERIFICATIONS:

UNCLAS ABU DHABI 000926

STATE FOR PM/DTCC FOR BLUE LANTERN COORDINATOR
USDOC FOR 532/BIS/OEA/TWILLIS/EHOLLAND/LHINES/WHIGGINS
DHS FOR ICE/STRATEGIC

SIPDIS

E.O. 12958: N/A
TAGS: BEXP ETRD ETTC AE

SUBJECT: EXTRANCHECK: PRE-LICENSE AND POST-SHIPMENT VERIFICATIONS:
110 VOLT TRADING LLC, DUBAI, UAE.

REF: USDOC OEA Email dated 9/18/09


1. Ref email requested that post conduct two pre-license checks and
one post shipment verification to determine the disposition of gas
turbine parts exported or due to be exported as No License Required
by Gas Turbine Parts and Service (GTPS),Clifton Park, New York.


2. On September 16, 2009, BIS Export Control Officer (ECO) Nasir
Khan and Immigration and Customs Enforcement (ICE) Special Agent
Romano Itani met with the Mr. Mohammad Shojaei, Managing Director of
both 110 Volt Trading and Keft Trading LLC. Shojaei was visibly
upset throughout the interview due to what he said was the financial
and emotional stress caused by the shipments detained in the US.
Shojaei, an Iranian national advised that through 110V he has done
no business in Iran due to what he claimed was limited profitability
due to government corruption in Iran involving high value industrial
equipment.


3. 110V Trading specializes in industrial electrical power
generation which include gas turbines for customers in Iraq and
former Soviet Central Asia (CIS) countries particularly Azerbaijan.
Regarding Keft Trading, Shojaei said that he manages Keft Trading's
operations which he admitted provides Chinese consumer products
(air-conditioners, auto parts, lighting, and household electrical
items) to the Iranian market where there is a better profit margin.
Shojaei reiterated that no items destined for 110 Volt Trading were
ever for the Iranian market and that Keft Trading is an entirely
different set up that shares the same Emirati business sponsor.
(Note: If a company is located outside of a UAE FreeZone that
company must have an Emirati national sponsor who shares in the
profit but likely does little else. ECO also notes that both 110V
and Keft Trading share the same office space in the Ghurair City
mall.)


3. Shojaei explained that he had originally met the U.S. Exporter,
Gas Turbine Parts and Service (GTPS) at a Power Generation
Exhibition in Germany approximately four years ago. In March/April
2009, a "Mr. Fernando" and a "Mr. Michael" (father and son) of GTPS
came to Dubai and met with Shojaei which is where the business
related to the shipments under scrutiny came about.


4. Regarding the transactions in question Shojaei provided the
following documents/information (all have been forward to OEE BOFO
via email):

a. (PSV) 4/21/09 shipment was sent to the Arkivan Company
located in Azerbijan. Shojaei provided commercial invoices, the GTPS
invoice and the Dubai Customs exit/entry certificate for this
shipment.

b. (PLC) 5/21/09 detained in US: was destined for TurboTim FZE
located in Jebel Ali FreeZone, Dubai, UAE. Shojaei provided
commercial invoices and related documentation for this order.

c. (PLC) 6/2/09 detained in US: was destined for TurboTim FZE
located in the Jebel Ali FreeZone, Dubai, UAE. Shojaei provided
commercial invoices and related documentation for this order.


5. On September 16, 2009 ECO conducted a follow on visit at TurboTim
FZE located in the Jebel Ali FreeZone to determine the end users for
the detained shipments. TurboTim is an Iraqi company that
specializes in gas turbine repair and refurbishment. ECO's
observations of the facility were consistent with such activities.
ECO met with Mr. Mustafa Al-Timimi, Sales Manager, TurboTim who
confirmed that they had in fact ordered the gas turbine items from
110V Trading and that these items were destined for Iraqi government
projects. ECO requested documentation relating to their suggested
end user and end use. Al-Timimi advised that since they could not
meet the Iraqi government customer timeframe (due to detention of
the shipment) their contract had been cancelled but he would try to
provide documentation. ECO received an email from Al-Timimi that
advised that TurboTim would not be able provide documentation since
the Iraqi government end user and TurboTim management did not want
to be bothered to provide the cancelled contract particularly since
the order was never fulfilled (the details of TurboTim's response
have also been sent via email to OEE BOFO).

OLSON