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