EXTRANCHECK: PRE-LICENSE CHECK: STREIT MIDDLE EAST FZCO,

UNCLAS ABU DHABI 000976

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

SIPDIS

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

SUBJECT: EXTRANCHECK: PRE-LICENSE CHECK: STREIT MIDDLE EAST FZCO,
DUBAI, UAE.

REF: A. USDOC OEA Email, dated 9/23/09

B. ABU DHABI 0897, dated 9/10/09



1. Ref A email requested that post conduct two additional
pre-license checks (previous checks were conducted per Ref B) to
determine the disposition of armored vehicles shipped by Streit USA
Armoring, North Charleston, SC to Streit Middle East FZCO located in
the Jebel Ali Freezone, Dubai, UAE. These vehicles are controlled
under ECCN 9A018.


2. On October 13, 2009, BIS Export Control Officer (ECO) Nasir Khan
and Immigration and Customs Enforcement (ICE) Special Agent Henry
Casillas met again with Mr. Dmitri Khazanski, Director of Sales and
Marketing for Streit Middle East FZCO. ECO requested additional
information regarding the structure, operations, financial dealings
and relationship between Streit USA and Streit Middle East. Streit
USA and Streit Middle East are separate companies that share the
same owner, a Canadian Citizen named Guerman Goutorov. Streit USA,
Streit Canada, and Streit Group UAE are all manufacturing companies
while Streit Middle East is involved only in sales. The newest
manufacturing plant is the Streit USA operation which is geared
towards meeting U.S. government armored vehicle orders worldwide.


3. Streit Middle East purchases its vehicles directly from Streit
USA and both companies have separate accounting structures. Since
it's a separate legal entity Streit Middle East does not share
profits for its sales with Streit USA. Khazanski stated that Streit
Middle East is like a dealership for Streit Group's manufacturing
arms. Streit Middle East orders these vehicles for inventory which
is why they are able to edge out their competitors who often can't
meet customer requirements in time. Customers for sales are either
often repeat customers or are developed through contacts and
business development visits throughout the region. Streit USA is
responsible for the export licenses but does not conduct regular
audits of Streit Middle East. Khazanski stated that since Streit USA
and Streit Middle East are "right and left pocket of the same pants"
they would do whatever might be required by Streit USA regarding
export requirements. Khazanski provided ECO with a business
prospectus booklet which provides a detailed overview of Streit
Group's structure and operations (these documents have been sent to
OEE WAFO via FEDEX).


4. Regarding the vehicle shipments in question for these PLCs the
following information was provided:

a. License D423875: Chevrolet Suburbans - these vehicles are
destined for ANHAM LLC which according to Khazanski is
procurement/contracting firm that supports the U.S. Department of
Defense's Kabul Regional Contracting Center for USG end users in
Afghanistan.

b. License D423789: Chevrolet Suburbans - vehicles are
destined for the exclusive use by the company, Auto Trend in the
Philippines. Khazanski provided end user statements attested to the
Dubai Police which indicate that these armored vehicles are
re-exported for the sole use by each customer (these documents have
been emailed to OEE WAFO).


5. Post is unable to make a definitive determination on the ultimate
end users for each vehicle beyond what has been provided in
documentation.

OLSON