BLUE LANTERN LEVEL 3: POST-LICENSE/PRE-SHIPMENT

UNCLAS STATE 005613 SENSITIVE SIPDIS LONDON FOR RAMON ESCOBAR E.O. 12958: N/A TAGS: ETTC KOMC UK SUBJECT: BLUE LANTERN LEVEL 3: POST-LICENSE/PRE-SHIPMENT END-USE CHECK ON LICENSE 050203970 REF: A. A. 2006 BLUE LANTERN GUIDEBOOK ¶B. B. IIR 7 114 1010 06 OF 31 MAY 2009 ¶1. (U) This is an Action Request. See paragraphs 2-4. ¶2. (U) The Department's Office of Defense Trade Controls Compliance (PM/DTCC) requests Post's assistance in conducting a post-license/pre-shipment check on license 050203970 for the export of International Traffic in Arms (ITAR)-controlled aircraft parts to the United Kingdom. Post is requested to complete this Blue Lantern inquiry within 45 days. Lack of response to a Blue Lantern inquiry will affect pending and future licenses involving parties to this license. ¶3. (SBU) Reason for request: Concerns about foreign consignee Aviation Trading Co. (a.k.a. Hayward and Green Aviation Ltd.) (see ref B). Additionally, the license request is only supported by a "blanket" Letter of Intent ($1 million request for various spare parts for multiple different aircraft). Aviation Trading's website describes itself as a leading stockist and distributor. This line of business, combined with the open-ended blanket license, is a scenario that suggests stockpiling of parts by Aviation Trading (stockpiling is forbidden under the ITAR without a specific agreement to do so). No firm purchase orders were submitted. ¶4. (U) ACTION: The Department requests that Post make inquiries to verify Aviation Trading is a bona fide supplier of aircraft parts to the foreign end-user, the UK Royal Air Force (RAF). Post is also requested to remind Aviation Trading officials of the restrictions on USML items, especially the prohibition against unauthorized re-transfer and re-export. The Department anticipates that a post-shipment end-use check may be necessary in the future to verify that all items have been received by the UK Royal Air Force. The following questions are provided for guidance: --Can Aviation Trading provide documentation that verifies the end-use of the aircraft parts, such as a contract or purchase order? -- Does Aviation Trading intend to re-export or retransfer any of these items to any user other than RAF? --Does Aviation Trading have system in place to ensure that USML items received under this license are only provided to the RAF, and not a different end-user? --Does Aviation Trading understand the restrictions on USML items, especially the prohibition against unauthorized re-transfer and re-export? END ACTION. ¶5. (U) Details of license application: DTC CASE: 050203970 QUANTITY/COMMODITY: Lot - Spare parts and components for multiple aircraft, ground support equipment, avionics, engine, and airframe in the UK Royal Air Force. License Value: 1,000,000.00 USD SELLER: Associated Aircraft Mfg. & Sales 2735 NW 63rd Ct. Fort Lauderdale, FL 33309 Tel: 954-772-6606 ext. 333 POC: Mimi Bergevin FOREIGN CONSIGNEE: Aviation Trading Unit 1 & 2 Terry's Cross Farm Horn Lane Woodmancote W. Sussex BN59SA United Kingdom Tel: 44 (0) 1273 494216 POC: Jeremy Green, Sales Director FOREIGN END-USER: UK Ministry of Defence Main Building, Whitehall London, SW1A 2HB United Kingdom PURPOSE: For maintenance and repair of the following aircraft in the UK MOD inventory: BAE Hawk T1, T1A, T2; Tornado GR4.F3; Harrier GR-7, GR7A, GR9, T10, T12; Eurofighter Typhoon T1, F2, FGR4; Westland Sea King HAR3A, Eurocopter Puma HC1; Nimrod R1; Boeing Chinook HC2, HC2A; Boeing C17A Globemaster III; Lockheed C-130, C1, C3, C3A, C4, C5. ¶6. (U) Submitted in support of the license application were the following documents (PM/DTCC will fax documentation to Post upon request): --Letter of Intent signed by Mr. Jeremy Green, dated 5 November 2009. --Department of State License for Permanent Export of Unclassified Defense Articles and Related Unclassified Technical Data, signed 7 December 2007, approved 18 December ¶2009. ¶7. (U) 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 Meredith Sundlof. Phone: 202-663-3455; Email: SundlofME@state.gov; SIPRNET: SundlofME@state.sgov.gov. The Blue Lantern Guidebook (ref) is available as a PDF file at http://www.intelink.sgov.gov/wiki/Blue Lantern End-Use Monitoring Program. ¶8. Department is grateful for Post's assistance in this matter. CLINTON