BLUE LANTERN LEVEL 2: PRE-LICENSE END-USE CHECK

UNCLAS STATE 002042 SIPDIS BRIDGETOWN FOR JAMAL AL-MUSSAWI E.O. 12958: N/A TAGS: ETTC KOMC ST BB SUBJECT: BLUE LANTERN LEVEL 2: PRE-LICENSE END-USE CHECK ON LICENSE 050208447 REF: 09 BRIDGETOWN 100 ¶1. This is an Action Request. See paragraph 4. ¶2. The Department's Office of Defense Trade Controls Compliance (PM/DTCC) requests Post's assistance in conducting a pre-license check on license 050208447 for the export of ammunition to St. Lucia. 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: A previous unfavorable Blue Lantern on foreign consignee Sportsimports discovered significant discrepancies between the firearms authorized for import and those actually being imported by the company. This led to the revocation of the company's import license by the Government of Barbados. A letter from Sportsimports in support of the current license describes an arrangement by which Gar Inc. of St. Lucia would import and sell ammunition for a commission on behalf of Sportsimports. If the revocation of Sportsimports' import license still stands, this transaction may represent an attempt by Sportsimports to circumvent the laws of Barbados by selling defense articles in a third country. In addition, this license represents the largest quantity of ammunition exported to Gar Inc. and the first license on which foreign intermediate consignee C & A Brokers of St. Lucia appears. This request is for Post to provide an update on the pending investigation in Barbados of Sportsimports. This request is also to establish the bona fides of this transaction and the parties involved. ¶4. Action Request: Post is requested to establish the bona fides of this transaction and the parties involved by making inquiries to representatives of the companies and appropriate authorities of the Governments of Barbados and St. Lucia. Post is also requested to comment on whether PM/DTCC should approve this license, considering any outstanding concerns with Sportsimports. The following points are included for guidance: (To C & A Brokers) --When was your company established and who are its principals? --What products and services does your company provide? --Who are your regular customers and where do they reside? Do you have customers that reside outside St. Lucia? If so, who are these customers and where do they reside? 
--What role is your company playing in this transaction? How are you being compensated for your role in this transaction and by whom are you being compensated? --What role is Sportsimports of Barbados playing in this transaction? Describe your relationship to Sportsimports. --Will you ever have physical possession of the defense articles listed below? If so, please describe the security measures and procedures your company has in place. --Are you familiar with the regulations governing U.S.-origin defense articles, including restrictions on unauthorized re-transfer or re-export and the requirement for brokers of U.S. defense articles to register with the U.S. Department of State? (To Sportsimports) --What role is your company playing in this transaction? How are you being compensated for your role in this transaction and by whom are you being compensated? --Aside from the U.S. vendor, are you compensating any companies in this transaction for their services? If so, please describe these services and the compensation. --Please provide the exact quantity and calibers of the ammunition being shipped to Gar Inc. in this transaction. Also, please provide any documentation you received and generated in support of this transaction (i.e. purchase orders, contracts, etc.). --What role is C & A Brokers of St. Lucia playing in this transaction? Describe your relationship to C & A Brokers. --What role is Gar Inc. of St. Lucia playing in this transaction? Describe your relationship to Gar Inc. --Will you ever have physical possession of the ammunition on this license? --Are you properly authorized to broker and/or sell defense articles in St. Lucia? Is your role in this transaction authorized by the Government of Barbados? --Are you familiar with the regulations governing the brokering of U.S.-origin defense articles, including the requirement for brokers of U.S. defense articles to register with the U.S. Department of State? (To Gar Inc.) --Please provide an estimate of your annual sales of U.S.-origin firearms and ammunition. What accounts for the significant increase in quantity for this order as compared to your orders in the past? --Please provide the exact quantity and calibers of the ammunition you will receive in this transaction. Please provide any documentation you received and generated in support of this transaction (i.e. purchase orders, contracts, etc.). --Do you sell defense articles to customers that reside outside St. Lucia? If so, who are these customers and where do they reside? --What role is Sportsimports of Barbados playing in this transaction? Describe your relationship to Sportsimports. Will you be compensated by this company and, if so, how and for what? --What role is C & A Brokers of St. Lucia playing in this transaction? Describe your relationship to C & A Brokers. Will you compensate this company and, if so, how? --Are you familiar with the regulations governing U.S.-origin defense articles, including restrictions on unauthorized re-transfer or re-export? (To Appropriate Import/Export and/or Law Enforcement Authorities of Barbados) --Please provide an update on your investigation into Sportsimports. Is this company authorized to import and/or broker defense articles in Barbados? --Does the Government of Barbados require specific authorizations for a company to use a foreign agent to sell ammunition in a third country? If so, is Sportsimports authorized to use a foreign agent to sell ammunition in St. Lucia? --Is Sportsimports' actions in this transaction within the laws of Barbados? Do you have any information on Sportsimports that questions its reliability as an importer and/or broker of U.S. defense articles? (To Appropriate Import/Export and/or Law Enforcement Authorities of St. Lucia) --Is Gar Inc. authorized to import and sell defense articles in St. Lucia? --A company in a third country may be using Gar Inc. as an agent through which the company will sell ammunition in St. Lucia. Does that company require authorization from the Government of St. Lucia to engage in this activity? --Do you have any derogatory information on Gar Inc. that questions its reliability as an importer of U.S. defense articles? --Is C & A Brokers authorized to import and/or broker defense articles in St. Lucia? --Do you have any derogatory information on C & A Brokers that questions its reliability as an importer and/or broker of U.S. defense articles? --Are there any legal restrictions on the specific quantities or calibers of ammunition a company can import into St. Lucia for commercial resale? 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. Details of license applications: DTC Case: 050208447 QUANTITY/COMMODITY: 800,000 Rounds of Ammunition, 9mm, .380, .40, and .45 Calibers 20,000 Rounds of Ammunition, .22 Caliber License Value: USD $128,800 SELLER: Federal Cartridge Co./Ammunition Accessories Inc. subsidiary of Alliant Techsystems Inc. 2299 Snake River Ave Lewiston, ID 83501 FOREIGN INTERMEDIATE CONSIGNEE: C & A Brokers 4 Mongiraud St. Castries St. Lucia FOREIGN CONSIGNEE: Sportsimports Hopewell Plantation St. Thomas, West Indies Barbados Tel: 246-425-4388 Email: greg@huzier.com Email: spencer@huzier.com FOREIGN END-USER: Gar Inc. Rodney Bay Castries St. Lucia PURPOSE: For commercial resale in St. Lucia ¶6. Submitted in support of the license application were the following documents (PM/DTCC will fax documentation to Posts upon request): DSP-83 signed by Patti Mann (Federal Cartridge/Alliant) dated 01/06/2010; Anthony Bristol (Gar Inc.) dated 10/28/2009; and Spencer Hutchinson (Sportsimports) dated 11/**/2009 (obscured) Import Authorization Nos. 20/09 and 21/09 issued by the Commissioner of Police of St. Lucia dated 09/24/2009 Purchase Order No. 252 from Sportsimports signed by Spencer Hutchins (Sportsimports) dated 11/04/2009 ¶7. 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 ¶8. Department is grateful for Post's assistance in this matter. CLINTON