Action Affecting Export Privileges; Parto Abgardan Cooling Towers Co., 63802-63804 [2010-26117]
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63802
Federal Register / Vol. 75, No. 200 / Monday, October 18, 2010 / Notices
34986, has been determined to be
related to Piquet by affiliation,
ownership, control, or position of
responsibility in the conduct of trade or
related services, and it has been deemed
necessary to make the Order denying
the export privileges of Piquet
applicable to Alphatronx in order to
prevent evasion of the Piquet Denial
Order.
Second, that the denial of export
privileges described in the Piquet Denial
Order, which was published in the
Federal Register on June 9, 2010 at 75
FR 32742, shall be made applicable to
Alphatronx until its expiration on May
14, 2019, as follows:
I. Alphatronx, with a last known
address at 1258 SW. Maplewood Dr.,
Port St. Lucie, FL, 34986, and when
acting for or on behalf of Alphatronx, its
successors or assigns, employees or
agents (collectively, ‘‘Related Person’’)
may not participate, directly or
indirectly, in any way in any transaction
involving any commodity, software or
technology (hereinafter collectively
referred to as ‘‘item’’) exported or to be
exported from the United States that is
subject to the Regulations, or in any
other activity subject to the Regulations,
including, but not limited to:
A. Applying for, obtaining, or using
any license, License Exception, or
export control document;
B. Carrying on negotiations
concerning, or ordering, buying,
receiving, using, selling, delivering,
storing, disposing of, forwarding,
transporting, financing, or otherwise
servicing in any way, any transaction
involving any item exported or to be
exported from the United States that is
subject to the Regulations, or in any
other activity subject to the Regulations;
or
C. Benefiting in any way from any
transaction involving any item exported
or to be exported from the United States
that is subject to the Regulations, or in
any other activity subject to the
Regulations.
II. No person may, directly or
indirectly, do any of the following:
A. Export or reexport to or on behalf
of the Related Person any item subject
to the Regulations;
B. Take any action that facilitates the
acquisition or attempted acquisition by
the Related Person of the ownership,
possession, or control of any item
subject to the Regulations that has been
or will be exported from the United
States, including financing or other
support activities related to a
transaction whereby the Related Person
acquires or attempts to acquire such
ownership, possession or control;
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C. Take any action to acquire from or
to facilitate the acquisition or attempted
acquisition from the Related Person of
any item subject to the Regulations that
has been exported from the United
States;
D. Obtain from the Related Person in
the United States any item subject to the
Regulations with knowledge or reason
to know that the item will be, or is
intended to be, exported from the
United States; or
E. Engage in any transaction to service
any item subject to the Regulations that
has been or will be exported from the
United States and which is owned,
possessed or controlled by the Related
Person, or service any item, of whatever
origin, that is owned, possessed or
controlled by the Related Person if such
service involves the use of any item
subject to the Regulations that has been
or will be exported from the United
States. For purposes of this paragraph,
servicing means installation,
maintenance, repair, modification or
testing.
Third, that in accordance with the
provisions of Section 766.23(c) of the
Regulations, the Related Person may, at
any time, make an appeal related to this
Order by filing a full written statement
in support of the appeal with the Office
of the Administrative Law Judge, U.S.
Coast Guard ALJ Docketing Center, 40
South Gay Street, Baltimore, Maryland
21202–4022.
Fourth, that this Order does not
prohibit any export, reexport, or other
transaction subject to the Regulations
where the only items involved that are
subject to the Regulations are the
foreign-produced direct product of U.S.origin technology.
Fifth, that this Order is effective
immediately and shall remain in effect
until May 14, 2019.
Sixth, that this Order shall be
published in the Federal Register and a
copy served on the Related Person.
Issued this 7th day of October 2010.
Bernard Kritzer,
Director, Office of Exporter Services.
[FR Doc. 2010–26118 Filed 10–15–10; 8:45 am]
BILLING CODE 3510–DT–P
DEPARTMENT OF COMMERCE
Bureau of Industry and Security
Action Affecting Export Privileges;
Parto Abgardan Cooling Towers Co.
Parto Abgardan Cooling Towers Co., P.O. Box
966, Folsom, CA 95763; and
P.O. Box 19395/5478, Tehran, Iran; and
No. 56 Shaydaee St., Yakhchal St., Shariati
Ave., Tehran 19497, Iran; and
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No. 56 Sheidaei St., Yakhchal St., Dr. Shariati
Ave., Tehran 19497, Iran; and
No. 56 Corner of Noushin Blind Alley,
Sheidaei St., Yakhchal St., Dr. Shariati
Ave., Tehran (19497), Iran; and
No. 56 Next to Noushin Blind Alley, Sheidaei
St., Yakhchal St., Dr. Shariati Ave., Tehran
(19497), Iran; and
No. 56, Corner of Noushin Dd. End, Sheidaie
St., Yakhchal St., Shariati St., 19497,
Tehran, Iran.
Order Making Denial of Export
Privileges of Aqua-Loop Cooling
Towers, Co. Applicable to Parto
Abgardan Cooling Towers Co.
Pursuant to Section 766.23 of the
Export Administration Regulations
(‘‘EAR’’ or ‘‘Regulations’’), the Bureau of
Industry and Security (‘‘BIS’’), U.S.
Department of Commerce, through its
Office of Export Enforcement (‘‘OEE’’),
has requested that I make the denial
order that was issued against Aqua-Loop
Cooling Towers, Co. (‘‘Aqua-Loop’’) on
March 25, 2010 (‘‘Denial Order’’),
applicable to the following entity, as a
person related to Aqua-Loop:
Parto Abgardan Cooling Towers Co.,
P.O. Box 966, Folsom, CA 95763; and
P.O. Box 19395/5478, Tehran, Iran; and
No. 56 Shaydaee St., Yakhchal St.,
Shariati Ave., Tehran 19497, Iran; and
No. 56 Sheidaei St., Yakhchal St., Dr.
Shariati Ave., Tehran 19497, Iran; and
No. 56 Corner of Noushin Blind Alley,
Sheidaei St., Yakhchal St., Dr.
Shariati Ave., Tehran (19497), Iran;
and
No. 56 Next to Noushin Blind Alley,
Sheidaei St., Yakhchal St., Dr.
Shariati Ave., Tehran (19497), Iran;
and
No. 56, Corner of Noushin Dd. End,
Sheidaie St., Yakhchal St., Shariati
St., 19497, Tehran, Iran.
The Denial Order was effective upon
issuance, was published in the Federal
Register on April 2, 2010 (see 75 FR
16732 (April 2, 2010)), and will remain
in effect until March 25, 2020.
I. Background
A. The Denial Order
The Denial Order denies the export
privileges of Aqua-Loop until March 25,
2020, pursuant to Section 764.3(a)(2) of
the Regulations, and was issued based
upon my approval of a settlement
agreement entered into by BIS and
Aqua-Loop. Specifically, in July 2009,
BIS filed a Charging Letter against AquaLoop for violating the Regulations by
causing unlicensed exports to Parto
Abgardan in Iran of items subject to the
Regulations, knowingly violating the
Regulations in connection with the
export of those items, and conspiring
with Parto Abgardan and others, known
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and unknown, to violate the Regulations
in connection with the export of those
items and other items that Aqua-Loop,
Parto Abgardan and their coconspirators sought to export to Iran
without the required U.S. Government
authorization.
BIS alleged, inter alia, that in
furtherance of the conspiracy, AquaLoop and Parto Abgardan participated
in a scheme to have Aqua-Loop source
or obtain items from U.S. distributors
and then have the items exported to
Parto Abgardan in Iran, via a United
Arab Emirates (‘‘U.A.E.’’) entity
identified by Parto Abgardan. The
charges referenced, inter alia,
documentary evidence in which Parto
Abgardan told Aqua-Loop: ‘‘Since [the
U.S. company] can’t sell directly to Iran,
they are OK with selling it domestically
and then we can transfer it from US to
Dubai and then to Iran. With your
permission, we are going to give AquaLoop’s information to them so they can
send you their offer’’ based on the
technical information provided to the
U.S. company by Parto Abgardan. The
charging letter provided additional
details concerning the long-running
conspiracy between Aqua-Loop and
Parto Abgardan, which continued from
at least in or about June 2004, through
at least in or about April 2005.1
Aqua-Loop settled these charges with
BIS in March 2010, agreeing to the
imposition of the Denial Order and to a
$100,000 monetary penalty, with the
monetary penalty suspended for a
period of ten years. At the same time,
Aqua-Loop’s co-owner and president,
Bob Rahimzadeh, settled with BIS on
the same terms regarding charges that he
caused unlicensed exports and
committed knowing violations of the
Regulations relating to the same
transactions.2
B. BIS’s Related Person’s Notice Letter
and Request
On May 21, 2010, pursuant to Section
766.23 of the Regulations, BIS notified
Parto Abgardan of its intent to add the
company as a person related to AquaLoop by ownership, control, position of
responsibility, affiliation, or other
connection in the conduct of trade or
business, by letter sent in accordance
with Sections 766.5(b) and 766.23(b).
The letter also requested that Parto
Abgardan provide additional
1 The charges filed against Aqua-Loop are
contained in the Order issued upon settlement,
which was subsequently published in the Federal
Register. 75 FR 16,732 (April 2, 2010).
2 The charges filed against Bob Rahimzadeh are
contained in the Order issued upon settlement,
which was subsequently published in the Federal
Register. 75 FR 16,735 (April 2, 2010).
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information to BIS concerning the
company’s structure, affiliates and
major shareholder(s).
As part of its request, BIS presented
evidence of conspiracy between AquaLoop and Parto Abgardan to violate the
Regulations. BIS also has evidence
indicating, inter alia, that Parto
Abgardan’s Web site identifies a ‘‘sister
factory’’ in the United States. For
contacts relating to the United States,
Parto Abgardan’s Web site provides
contact information that includes AquaLoop’s California mailing address,
phone number, and fax number, without
identifying Aqua-Loop separately by
name. In contrast, Parto Abgardan’s Web
site provides Iranian mailing address,
phone number, and fax number as
contact information for ‘‘all countries
except U.S.’’
BIS’s submission also included
evidence that the owner and managing
director of Parto Abgardan in Iran,
Mahmoud Lazemizadeh, also is a coowner of Aqua-Loop.3 Moreover,
Mahmoud Lazemizadeh’s nephew,
Behzad Lazemizadeh, was a mechanical
engineer and manager of Parto
Abgardan’s technical office before he
was transferred to Aqua-Loop in
California for five years.
C. Parto Abgardan’s Response
Mahmoud Lazemizadeh responded by
email on Parto Abgardan’s behalf on
June 14, 2010. He asserted that Parto
Abgardan is an Iranian company and
that there was ‘‘no connection of any
kind between this company and AquaLoop cooling towers Co. [sic].’’ He also
asserted that Parto Abgardan and AquaLoop had the same dealings with each
other as between Parto Abgardan and
any ‘‘other representative of other
European or Asian companies * * *.’’
II. Related Persons Under Section
766.23
Section 766.23(a) of the Regulations
provides that:
In order to prevent evasion, certain types
of orders under [Part 766] may be made
applicable not only to the respondent, but
also to other persons then or thereafter
related to the respondent by ownership,
control, position of responsibility, affiliation,
or other connection in the conduct of trade
or business. Orders that may be made
applicable to related persons include those
that deny or affect export privileges,
including temporary denial orders, and those
that exclude a respondent from practice
before BIS.
15 CFR 766.23(a).
Section 766.23(b) provides, in
pertinent part, that upon a finding by
3 Mahmoud Lazemizadeh is a U.S. citizen who
resides in Iran.
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63803
the Assistant Secretary for Export
Enforcement that a denial order should
be made applicable to a related person
or persons in order to prevent evasion
of that denial order, the Assistant
Secretary shall issue or amend the order
accordingly. 15 CFR 766.23(b).
III. Findings
BIS notified Parto Abgardan of its
intent to add the company as a related
person in accordance with Section
766.23(b) of the Regulations. As
indicated by BIS, with regard to the
United States market, Parto Abgardan’s
Web site directs its (potential)
customers and others to make U.S.related contacts using Aqua-Loop’s
address in Folsom, California, and
Aqua-Loop’s phone number and fax
number there, whereas all contacts
elsewhere in the world are to be made
directly to Parto Abgardan in Iran. Parto
Abgardan’s Web site also discusses a
‘‘sister factory’’ in the United States, in
further apparent reference to AquaLoop. Moreover, the record also shows
that Parto Abgardan’s owner and
managing director, Mahmoud
Lazemizadeh, is a co-owner of AquaLoop, while his nephew, Behzad
Lazemizadeh, is an employee of Parto
Abgardan and a former employee of
Aqua-Loop. The record thus amply
shows that Parto Abgardan is related to
Aqua-Loop.
The record similarly demonstrates
that adding Parto Abgardan to the
Denial Order is justified in order to
prevent evasion of that Order. I find that
BIS has presented evidence showing
that Parto Abgardan and Aqua-Loop
participated in a long-running
conspiracy to violate the Regulations.
That evidence shows, inter alia, that
acting in concert with Parto Abgardan,
Aqua-Loop sourced or obtained items in
the United States and then exported
them or caused their export to Parto
Abgardan in Iran, via a U.A.E.
middleman identified by Parto
Abgardan, without the required U.S.
Government licenses. These actions
included Parto Abgardan’s efforts to
obtain a filament winding machine from
a U.S. supplier, during which Parto
Abgardan told Aqua-Loop: ‘‘Since they
[the U.S. supplier] can’t sell directly to
Iran, they are OK with selling it
domestically and then we can transfer it
from U.S. to Dubai and then to Iran.
With your permission we are going to
give Aqua-Loop’s information to them
so they can send you their offer’’ based
on the technical information provided
to the U.S. company by Parto Abgardan.
This long-running collaboration
points to a substantial continued risk of
diversion and evasion presented by the
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mstockstill on DSKH9S0YB1PROD with NOTICES
ongoing business relationship between
Parto Abgardan and Aqua-Loop, which
is highlighted by Parto Abgardan’s own
Web site, and Mahmoud Lazemizadeh’s
control of Parto Abgardan and his
ownership interest in Aqua-Loop. These
concerns are only heightened by Parto
Abgardan’s assertions that there is no
connection between the two entities,
when, in fact, its owner is a co-owner
of Aqua-Loop and its Web site,
references a ‘‘sister factory’’ in the
United States and lists Aqua-Loop’s
mailing address and contact information
in California.
Based on the foregoing and the record
as a whole, I find that Parto Abgardan
is a person related to Aqua-Loop by
‘‘ownership, control, position of
responsibility, affiliation, or other
connection in the conduct of trade or
business’’ pursuant to Section 766.23 of
the Regulations, and that the Denial
Order issued against Aqua-Loop should
be made applicable to Parto Abgardan in
order to prevent evasion of that Order.
IV. Order
It is therefore ordered:
First, that Parto Abgardan Cooling
Towers Co. (‘‘Parto Abgardan’’), located
at the following addresses: P.O. Box
966, Folsom, CA 95763; and P.O. Box
19395/5478, Tehran, Iran; and No. 56
Shaydaee St., Yakhchal St., Shariati
Ave., Tehran (19497), Iran; and No. 56
Sheidaei St., Yakhchal St., Dr. Shariati
Ave., Tehran (19497), Iran; and No. 56
Corner of Noushin Blind Alley, Sheidaei
St., Yakhchal St., Dr. Shariati Ave.,
Tehran (19497), Iran; and No. 56 Next
to Noushin Blind Alley, Sheidaei St.,
Yakhchal St., Dr. Shariati Ave., Tehran
(19497), Iran; and No. 56, Corner of
Noushin Dd. End, Sheidaie St.,
Yakhchal St., Shariati St., (19497),
Tehran, Iran, and Parto Abgardan’s
successors or assigns and, when acting
for or on behalf of the Parto Abgardan,
its officers, representatives, agents, or
employees (Parto Abgardan and each of
the foregoing as stated, a ‘‘Denied
Person’’), may not, directly or indirectly,
participate in any way in any
transaction involving any commodity,
software or technology (hereinafter
collectively referred to as ‘‘item’’)
exported or to be exported from the
United States that is subject to the
Regulations, or in any other activity
subject to the Regulations, including,
but not limited to:
A. Applying for, obtaining, or using
any license, License Exception, or
export control document;
B. Carrying on negotiations
concerning, or ordering, buying,
receiving, using, selling, delivering,
storing, disposing of, forwarding,
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16:48 Oct 15, 2010
Jkt 223001
transporting, financing, or otherwise
servicing in any way, any transaction
involving any item exported or to be
exported from the United States that is
subject to the Regulations, or in any
other activity subject to the Regulations;
or
C. Benefiting in any way from any
transaction involving any item exported
or to be exported from the United States
that is subject to the Regulations, or in
any other activity subject to the
Regulations.
Second, no person may, directly or
indirectly, do any of the following:
A. Export or reexport to or on behalf
of the Denied Person any item subject to
the Regulations;
B. Take any action that facilitates the
acquisition or attempted acquisition by
the Denied Person of the ownership,
possession, or control of any item
subject to the Regulations that has been
or will be exported from the United
States, including financing or other
support activities related to a
transaction whereby the Denied Person
acquires or attempts to acquire such
ownership, possession or control;
C. Take any action to acquire from or
to facilitate the acquisition or attempted
acquisition from the Denied Person of
any item subject to the Regulations that
has been exported from the United
States;
D. Obtain from the Denied Person in
the United States any item subject to the
Regulations with knowledge or reason
to know that the item will be, or is
intended to be, exported from the
United States; or
E. Engage in any transaction to service
any item subject to the Regulations that
has been or will be exported from the
United States and which is owned,
possessed or controlled by the Denied
Person, or service any item, of whatever
origin, that is owned, possessed or
controlled by the Denied Person if such
service involves the use of any item
subject to the Regulations that has been
or will be exported from the United
States. For purposes of this paragraph,
servicing means installation,
maintenance, repair, modification or
testing.
Third, that in accordance with the
provisions of Section 766.23(c) of the
Regulations, the Denied Person may, at
any time, make an appeal related to this
Order by filing a full written statement
in support of the appeal with the Office
of the Administrative Law Judge, U.S.
Coast Guard ALJ Docketing Center, 40
South Gay Street, Baltimore, Maryland
21202–4022.
This Order shall be published in the
Federal Register and a copy provided to
the denied person.
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This Order is effective upon issuance
and shall remain in effect until March
25, 2020.
Entered this 6th day of October 2010.
David W. Mills,
Assistant Secretary of Commerce for Export
Enforcement.
[FR Doc. 2010–26117 Filed 10–15–10; 8:45 am]
BILLING CODE 3510–DT–P
DEPARTMENT OF COMMERCE
Bureau of the Census
[Docket Number 100921463–0460–01]
Annual Retail Trade Survey
Bureau of the Census,
Department of Commerce.
ACTION: Notice of determination.
AGENCY:
The United States Department
of Commerce’s Bureau of the Census
(Census Bureau) publishes this notice to
announce that the Director of the
Census Bureau has determined the need
to conduct the 2010 Annual Retail
Trade Survey (ARTS). ARTS covers
employer firms with establishments
located in the United States and
classified in the Retail Trade and/or
Accommodation and Food Services
sectors as defined by the 2002 North
American Industry Classification
System (NAICS). Through this survey,
the Census Bureau will collect data
covering annual sales, annual ecommerce sales, year-end inventories
held inside and outside the United
States, total operating expenses,
purchases, accounts receivables, and,
for selected industries, merchandise line
sales, percent of sales by class of
customer, and percent of e-commerce
sales to customers located outside the
United States. These data are collected
to provide a sound statistical basis for
the formation of policy by various
government agencies. Results will be
available for use for a variety of public
and business needs such as economic
and market analysis, company
performance, and forecasting future
demand.
ADDRESSES: The Census Bureau will
provide report forms to businesses
included in the survey. Additional
copies are available upon written
request to the Director, U.S. Census
Bureau, Washington, DC 20233–0101.
FOR FURTHER INFORMATION CONTACT:
Aneta Erdie, Service Sector Statistics
Division, at (301) 763–4841 or by e-mail
at aneta.erdie@census.gov.
SUPPLEMENTARY INFORMATION: Sections
182, 224, and 225 of Title 13 of the
United States Code authorize the Census
SUMMARY:
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Agencies
[Federal Register Volume 75, Number 200 (Monday, October 18, 2010)]
[Notices]
[Pages 63802-63804]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-26117]
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DEPARTMENT OF COMMERCE
Bureau of Industry and Security
Action Affecting Export Privileges; Parto Abgardan Cooling Towers
Co.
Parto Abgardan Cooling Towers Co., P.O. Box 966, Folsom, CA 95763;
and
P.O. Box 19395/5478, Tehran, Iran; and
No. 56 Shaydaee St., Yakhchal St., Shariati Ave., Tehran 19497,
Iran; and
No. 56 Sheidaei St., Yakhchal St., Dr. Shariati Ave., Tehran 19497,
Iran; and
No. 56 Corner of Noushin Blind Alley, Sheidaei St., Yakhchal St.,
Dr. Shariati Ave., Tehran (19497), Iran; and
No. 56 Next to Noushin Blind Alley, Sheidaei St., Yakhchal St., Dr.
Shariati Ave., Tehran (19497), Iran; and
No. 56, Corner of Noushin Dd. End, Sheidaie St., Yakhchal St.,
Shariati St., 19497, Tehran, Iran.
Order Making Denial of Export Privileges of Aqua-Loop Cooling Towers,
Co. Applicable to Parto Abgardan Cooling Towers Co.
Pursuant to Section 766.23 of the Export Administration Regulations
(``EAR'' or ``Regulations''), the Bureau of Industry and Security
(``BIS''), U.S. Department of Commerce, through its Office of Export
Enforcement (``OEE''), has requested that I make the denial order that
was issued against Aqua-Loop Cooling Towers, Co. (``Aqua-Loop'') on
March 25, 2010 (``Denial Order''), applicable to the following entity,
as a person related to Aqua-Loop:
Parto Abgardan Cooling Towers Co., P.O. Box 966, Folsom, CA 95763; and
P.O. Box 19395/5478, Tehran, Iran; and
No. 56 Shaydaee St., Yakhchal St., Shariati Ave., Tehran 19497, Iran;
and
No. 56 Sheidaei St., Yakhchal St., Dr. Shariati Ave., Tehran 19497,
Iran; and
No. 56 Corner of Noushin Blind Alley, Sheidaei St., Yakhchal St., Dr.
Shariati Ave., Tehran (19497), Iran; and
No. 56 Next to Noushin Blind Alley, Sheidaei St., Yakhchal St., Dr.
Shariati Ave., Tehran (19497), Iran; and
No. 56, Corner of Noushin Dd. End, Sheidaie St., Yakhchal St., Shariati
St., 19497, Tehran, Iran.
The Denial Order was effective upon issuance, was published in the
Federal Register on April 2, 2010 (see 75 FR 16732 (April 2, 2010)),
and will remain in effect until March 25, 2020.
I. Background
A. The Denial Order
The Denial Order denies the export privileges of Aqua-Loop until
March 25, 2020, pursuant to Section 764.3(a)(2) of the Regulations, and
was issued based upon my approval of a settlement agreement entered
into by BIS and Aqua-Loop. Specifically, in July 2009, BIS filed a
Charging Letter against Aqua-Loop for violating the Regulations by
causing unlicensed exports to Parto Abgardan in Iran of items subject
to the Regulations, knowingly violating the Regulations in connection
with the export of those items, and conspiring with Parto Abgardan and
others, known
[[Page 63803]]
and unknown, to violate the Regulations in connection with the export
of those items and other items that Aqua-Loop, Parto Abgardan and their
co-conspirators sought to export to Iran without the required U.S.
Government authorization.
BIS alleged, inter alia, that in furtherance of the conspiracy,
Aqua-Loop and Parto Abgardan participated in a scheme to have Aqua-Loop
source or obtain items from U.S. distributors and then have the items
exported to Parto Abgardan in Iran, via a United Arab Emirates
(``U.A.E.'') entity identified by Parto Abgardan. The charges
referenced, inter alia, documentary evidence in which Parto Abgardan
told Aqua-Loop: ``Since [the U.S. company] can't sell directly to Iran,
they are OK with selling it domestically and then we can transfer it
from US to Dubai and then to Iran. With your permission, we are going
to give Aqua-Loop's information to them so they can send you their
offer'' based on the technical information provided to the U.S. company
by Parto Abgardan. The charging letter provided additional details
concerning the long-running conspiracy between Aqua-Loop and Parto
Abgardan, which continued from at least in or about June 2004, through
at least in or about April 2005.\1\
---------------------------------------------------------------------------
\1\ The charges filed against Aqua-Loop are contained in the
Order issued upon settlement, which was subsequently published in
the Federal Register. 75 FR 16,732 (April 2, 2010).
---------------------------------------------------------------------------
Aqua-Loop settled these charges with BIS in March 2010, agreeing to
the imposition of the Denial Order and to a $100,000 monetary penalty,
with the monetary penalty suspended for a period of ten years. At the
same time, Aqua-Loop's co-owner and president, Bob Rahimzadeh, settled
with BIS on the same terms regarding charges that he caused unlicensed
exports and committed knowing violations of the Regulations relating to
the same transactions.\2\
---------------------------------------------------------------------------
\2\ The charges filed against Bob Rahimzadeh are contained in
the Order issued upon settlement, which was subsequently published
in the Federal Register. 75 FR 16,735 (April 2, 2010).
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B. BIS's Related Person's Notice Letter and Request
On May 21, 2010, pursuant to Section 766.23 of the Regulations, BIS
notified Parto Abgardan of its intent to add the company as a person
related to Aqua-Loop by ownership, control, position of responsibility,
affiliation, or other connection in the conduct of trade or business,
by letter sent in accordance with Sections 766.5(b) and 766.23(b). The
letter also requested that Parto Abgardan provide additional
information to BIS concerning the company's structure, affiliates and
major shareholder(s).
As part of its request, BIS presented evidence of conspiracy
between Aqua-Loop and Parto Abgardan to violate the Regulations. BIS
also has evidence indicating, inter alia, that Parto Abgardan's Web
site identifies a ``sister factory'' in the United States. For contacts
relating to the United States, Parto Abgardan's Web site provides
contact information that includes Aqua-Loop's California mailing
address, phone number, and fax number, without identifying Aqua-Loop
separately by name. In contrast, Parto Abgardan's Web site provides
Iranian mailing address, phone number, and fax number as contact
information for ``all countries except U.S.''
BIS's submission also included evidence that the owner and managing
director of Parto Abgardan in Iran, Mahmoud Lazemizadeh, also is a co-
owner of Aqua-Loop.\3\ Moreover, Mahmoud Lazemizadeh's nephew, Behzad
Lazemizadeh, was a mechanical engineer and manager of Parto Abgardan's
technical office before he was transferred to Aqua-Loop in California
for five years.
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\3\ Mahmoud Lazemizadeh is a U.S. citizen who resides in Iran.
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C. Parto Abgardan's Response
Mahmoud Lazemizadeh responded by email on Parto Abgardan's behalf
on June 14, 2010. He asserted that Parto Abgardan is an Iranian company
and that there was ``no connection of any kind between this company and
Aqua-Loop cooling towers Co. [sic].'' He also asserted that Parto
Abgardan and Aqua-Loop had the same dealings with each other as between
Parto Abgardan and any ``other representative of other European or
Asian companies * * *.''
II. Related Persons Under Section 766.23
Section 766.23(a) of the Regulations provides that:
In order to prevent evasion, certain types of orders under [Part
766] may be made applicable not only to the respondent, but also to
other persons then or thereafter related to the respondent by
ownership, control, position of responsibility, affiliation, or
other connection in the conduct of trade or business. Orders that
may be made applicable to related persons include those that deny or
affect export privileges, including temporary denial orders, and
those that exclude a respondent from practice before BIS.
15 CFR 766.23(a).
Section 766.23(b) provides, in pertinent part, that upon a finding
by the Assistant Secretary for Export Enforcement that a denial order
should be made applicable to a related person or persons in order to
prevent evasion of that denial order, the Assistant Secretary shall
issue or amend the order accordingly. 15 CFR 766.23(b).
III. Findings
BIS notified Parto Abgardan of its intent to add the company as a
related person in accordance with Section 766.23(b) of the Regulations.
As indicated by BIS, with regard to the United States market, Parto
Abgardan's Web site directs its (potential) customers and others to
make U.S.-related contacts using Aqua-Loop's address in Folsom,
California, and Aqua-Loop's phone number and fax number there, whereas
all contacts elsewhere in the world are to be made directly to Parto
Abgardan in Iran. Parto Abgardan's Web site also discusses a ``sister
factory'' in the United States, in further apparent reference to Aqua-
Loop. Moreover, the record also shows that Parto Abgardan's owner and
managing director, Mahmoud Lazemizadeh, is a co-owner of Aqua-Loop,
while his nephew, Behzad Lazemizadeh, is an employee of Parto Abgardan
and a former employee of Aqua-Loop. The record thus amply shows that
Parto Abgardan is related to Aqua-Loop.
The record similarly demonstrates that adding Parto Abgardan to the
Denial Order is justified in order to prevent evasion of that Order. I
find that BIS has presented evidence showing that Parto Abgardan and
Aqua-Loop participated in a long-running conspiracy to violate the
Regulations. That evidence shows, inter alia, that acting in concert
with Parto Abgardan, Aqua-Loop sourced or obtained items in the United
States and then exported them or caused their export to Parto Abgardan
in Iran, via a U.A.E. middleman identified by Parto Abgardan, without
the required U.S. Government licenses. These actions included Parto
Abgardan's efforts to obtain a filament winding machine from a U.S.
supplier, during which Parto Abgardan told Aqua-Loop: ``Since they [the
U.S. supplier] can't sell directly to Iran, they are OK with selling it
domestically and then we can transfer it from U.S. to Dubai and then to
Iran. With your permission we are going to give Aqua-Loop's information
to them so they can send you their offer'' based on the technical
information provided to the U.S. company by Parto Abgardan.
This long-running collaboration points to a substantial continued
risk of diversion and evasion presented by the
[[Page 63804]]
ongoing business relationship between Parto Abgardan and Aqua-Loop,
which is highlighted by Parto Abgardan's own Web site, and Mahmoud
Lazemizadeh's control of Parto Abgardan and his ownership interest in
Aqua-Loop. These concerns are only heightened by Parto Abgardan's
assertions that there is no connection between the two entities, when,
in fact, its owner is a co-owner of Aqua-Loop and its Web site,
references a ``sister factory'' in the United States and lists Aqua-
Loop's mailing address and contact information in California.
Based on the foregoing and the record as a whole, I find that Parto
Abgardan is a person related to Aqua-Loop by ``ownership, control,
position of responsibility, affiliation, or other connection in the
conduct of trade or business'' pursuant to Section 766.23 of the
Regulations, and that the Denial Order issued against Aqua-Loop should
be made applicable to Parto Abgardan in order to prevent evasion of
that Order.
IV. Order
It is therefore ordered:
First, that Parto Abgardan Cooling Towers Co. (``Parto Abgardan''),
located at the following addresses: P.O. Box 966, Folsom, CA 95763; and
P.O. Box 19395/5478, Tehran, Iran; and No. 56 Shaydaee St., Yakhchal
St., Shariati Ave., Tehran (19497), Iran; and No. 56 Sheidaei St.,
Yakhchal St., Dr. Shariati Ave., Tehran (19497), Iran; and No. 56
Corner of Noushin Blind Alley, Sheidaei St., Yakhchal St., Dr. Shariati
Ave., Tehran (19497), Iran; and No. 56 Next to Noushin Blind Alley,
Sheidaei St., Yakhchal St., Dr. Shariati Ave., Tehran (19497), Iran;
and No. 56, Corner of Noushin Dd. End, Sheidaie St., Yakhchal St.,
Shariati St., (19497), Tehran, Iran, and Parto Abgardan's successors or
assigns and, when acting for or on behalf of the Parto Abgardan, its
officers, representatives, agents, or employees (Parto Abgardan and
each of the foregoing as stated, a ``Denied Person''), may not,
directly or indirectly, participate in any way in any transaction
involving any commodity, software or technology (hereinafter
collectively referred to as ``item'') exported or to be exported from
the United States that is subject to the Regulations, or in any other
activity subject to the Regulations, including, but not limited to:
A. Applying for, obtaining, or using any license, License
Exception, or export control document;
B. Carrying on negotiations concerning, or ordering, buying,
receiving, using, selling, delivering, storing, disposing of,
forwarding, transporting, financing, or otherwise servicing in any way,
any transaction involving any item exported or to be exported from the
United States that is subject to the Regulations, or in any other
activity subject to the Regulations; or
C. Benefiting in any way from any transaction involving any item
exported or to be exported from the United States that is subject to
the Regulations, or in any other activity subject to the Regulations.
Second, no person may, directly or indirectly, do any of the
following:
A. Export or reexport to or on behalf of the Denied Person any item
subject to the Regulations;
B. Take any action that facilitates the acquisition or attempted
acquisition by the Denied Person of the ownership, possession, or
control of any item subject to the Regulations that has been or will be
exported from the United States, including financing or other support
activities related to a transaction whereby the Denied Person acquires
or attempts to acquire such ownership, possession or control;
C. Take any action to acquire from or to facilitate the acquisition
or attempted acquisition from the Denied Person of any item subject to
the Regulations that has been exported from the United States;
D. Obtain from the Denied Person in the United States any item
subject to the Regulations with knowledge or reason to know that the
item will be, or is intended to be, exported from the United States; or
E. Engage in any transaction to service any item subject to the
Regulations that has been or will be exported from the United States
and which is owned, possessed or controlled by the Denied Person, or
service any item, of whatever origin, that is owned, possessed or
controlled by the Denied Person if such service involves the use of any
item subject to the Regulations that has been or will be exported from
the United States. For purposes of this paragraph, servicing means
installation, maintenance, repair, modification or testing.
Third, that in accordance with the provisions of Section 766.23(c)
of the Regulations, the Denied Person may, at any time, make an appeal
related to this Order by filing a full written statement in support of
the appeal with the Office of the Administrative Law Judge, U.S. Coast
Guard ALJ Docketing Center, 40 South Gay Street, Baltimore, Maryland
21202-4022.
This Order shall be published in the Federal Register and a copy
provided to the denied person.
This Order is effective upon issuance and shall remain in effect
until March 25, 2020.
Entered this 6th day of October 2010.
David W. Mills,
Assistant Secretary of Commerce for Export Enforcement.
[FR Doc. 2010-26117 Filed 10-15-10; 8:45 am]
BILLING CODE 3510-DT-P