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

UNCLAS STATE 011701

SIPDIS
PORT LOUIS FOR QUENTIN BARBER
LONDON FOR RAMON ESCOBAR

E.O. 12958: N/A
TAGS: ETTC KOMC MP
SUBJECT: BLUE LANTERN LEVEL 3: PRE-LICENSE END-USE CHECK
ON LICENSE 050211147


1. This is an Action Request. See paragraphs 4 - 5.


2. The Department's Office of Defense Trade Controls
Compliance (PM/DTCC) requests Post's assistance in conducting
a pre-license check on license 050211147 for the export of
rifles to Mauritius. 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: This license request is for the
export of fully automatic military rifles to the police of
Mauritius. London-based foreign consignee, M.I.A. Trading,
appears to be acting as a broker in this transaction despite
not being registered with the Department as a broker, as
required by the International Traffic in Arms Regulations
(ITAR). This request is to establish the bona fides of this
transaction and the parties involved. This request is also
to determine the role of M.I.A. Trading.


4. Action Request Port Louis: Post is requested to establish
the bona fides of this transaction by making inquiries with
appropriate authorities of the Government of Mauritius. The
following points are included for guidance:

(To Mauritius Police Department)

--Can you confirm the order of the rifles listed on this
license application?

--For what will these defense articles be used? With whom
did you place the order for these defense articles?

--What role is London-based M.I.A. Trading playing in this
transaction? What services did this company provide? How and
by whom will the company be compensated? Please describe how
M.I.A. Trading became involved in this transaction.

--Why didn't you purchase these items directly from the U.S.
vendors?

--Will M.I.A. Trading ever have physical possession of these
firearms?

In its reply, Post may also comment on any other information
pertinent to these transactions such as security of
facilities, end-use, and concerns about the entities involved.


5. Action Request London: Post is requested to establish the
bona fides of this transaction and M.I.A. Trading by making
inquiries with representatives of the company and appropriate
authorities of the U.K. Government. Post is also requested
to determine the company's role in this transaction. The
following points are included for guidance:

(To M.I.A. Trading)

--When was your company established and who are its
principals? Does your company or any of its principals do
business under any other names?

--What products and services does your company provide? Who
are your regular business partners and where do they reside?
Who are your regular customers and where do they reside?

--What role is your company playing in these transactions?
How and by whom is your company being compensated? Please
describe the structure of this transaction.

--Please describe how you became involved in this transaction.

--Do you represent Bushmaster Firearms in any official
capacity? If so, please describe this relationship (e.g.
distribution or sales territory, commission-based sales
contracts, etc).

--Will you ever have physical possession of the defense
articles on this license? If so, please describe your
inventory and security procedures.

--Are you familiar with the regulations governing the import
and brokering of U.S.-origin defense articles?

(To Appropriate Import/Export and/or Law Enforcement
Authorities)

--Is M.I.A. Trading properly authorized to import and broker
defense articles in the United Kingdom?

--Do you have any information on M.I.A. Trading that would
call in to question their reliability as a recipient of U.S.
defense articles?

In its reply, Post may also comment on any other information
pertinent to these transactions such as security of
facilities, end-use, and concerns about the entities
involved.


6. Details of license applications:

DTC Case: 050211147

QUANTITY/COMMODITY:

200 Bushmaster M16A2 -type Rifles

License Value: USD $185,000

SELLER:

Freedom Group
Bushmaster Firearms International
999 Roosevelt Trail
Windham, ME 04062

FOREIGN CONSIGNEE:

M.I.A. Trading Ltd
163 Lauderdale Mans
Lauderdale Road
PO Box 16156
London W9 1LY
United Kingdom
Tel: 07831 201023 / 020

FOREIGN END-USER:

Mauritius Police Department Commissioner of Police
Line Barracks
Port Louis, Mauritius
Tel: 230 2081204

PURPOSE:

For official use by the Mauritius Police Department


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

DSP-83 Nontransfer and Use Certificate signed by Shannon
Shuman (Bushmaster) dated 01/25/2010; Prem Gangoo (Mauritius
Police) dated 01/12/2010; and Gideon Sarig (M.I.A.) dated
01/14/2010

Letter Indent No. 19/2009 Confirming Order from the Office of
the Commissioner of Police signed by P. Gangoo dated
01/12/2010

End-use Certificate issued by the Office of the Commissioner
of Police, Police Procurement Division stamped by the
Mauritius Police Force (unsigned)

Purchase Order from M.I.A. Trading signed by Gideon Sarig
dated 12/30/2009


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 Kyle M. Ballard, Phone:
202-663-1929; Email: BallardKM@state.gov; SIPRNET:
BallardKM@state.sgov.gov. The Blue Lantern Guidebook (ref)
is available as a PDF file on Intellipedia:
http://www.intelink.gov/wiki/
Blue Lantern End-Use Monitoring Program


9. Department is grateful for Post's assistance in this
matter.
CLINTON