Order Temporarily Denying Export Privileges, 49540-49543 [2018-21446]
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Federal Register / Vol. 83, No. 191 / Tuesday, October 2, 2018 / Notices
authority on other performance
management issues, such as pay
adjustments, bonuses and Presidential
Rank Awards. The appointment of these
members to the Performance Review
Board will be for a period of twenty-four
(24) months.
Dates: The name, position title, and
type of appointment of each member of
the Performance Review Board are set
forth below:
1. Brian DiGiacomo, Assistant General
Counsel for Employment, Litigation,
and Information Law, Career SES.
2. John Cobau, Chief Counsel for
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3. Kurt Bersani, Chief Financial
Officer and Director of Administration,
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4. Catrina Purvis, Senior Agency
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Privacy Officer (CPO) & Director of
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5. Sivaraj Shyam-Sunder, Senior
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Dated: September 27, 2018.
Joan M. Nagielski,
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Employment and Compensation, Department
of Commerce Human Resources Operations
Center, Office of Human Resources
Management, Office of the Secretary,
Department of Commerce.
[FR Doc. 2018–21430 Filed 10–1–18; 8:45 am]
BILLING CODE 3510–25–P
DEPARTMENT OF COMMERCE
Bureau of Industry and Security
Order Temporarily Denying Export
Privileges
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Eastline Technologies OU, Akadeemia tee 21,
12618 Tallinn, Estonia; and Peterburi tee
47–210, 11415 Tallinn, Estonia
Adimir OU, Akadeemia tee 21, 12618
Tallinn, Estonia; and Peterburi tee 47–210,
11415 Tallinn, Estonia
Valery Kosmachov, a/k/a Valeri Kosmachov,
a/k/a Valery Kosmatsov, a/k/a Valery
Kosmatshov, a/k/a Valery Kosmachev,
Vabao˜hukooli tee 76–A9, 12015 Tallinn,
Estonia
Sergey Vetrov, a/k/a Sergei Vetrov, 6–39 Karl
Marx Str., Ramenskoye, Moscow, Russia
140100
Real Components Ltd., 8–1 Aviamotornaya
Str., Moscow, Russia 111024
I. Introduction and Background of the
Parties at Issue
Pursuant to Section 766.24 of the
Export Administration Regulations (the
‘‘Regulations’’ or ‘‘EAR’’),1 the Bureau of
1 The Regulations are currently codified in the
Code of Federal Regulations at 15 CFR Parts 730–
774 (2018). The Regulations originally issued under
the Export Administration Act of 1979, as amended,
50 U.S.C. 4601–4623 (Supp. III 2015) (‘‘the EAA’’),
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Industry and Security (‘‘BIS’’), U.S.
Department of Commerce, through its
Office of Export Enforcement (‘‘OEE’’),
has requested that I issue an order
temporarily denying, for a period of 180
days, the export privileges of Eastline
Technologies OU (‘‘Eastline’’), Adimir
OU (‘‘Adimir’’), Valery Kosmachov a/k/
a Valeri Kosmachov, a/k/a Valery
Kosmatsov, a/k/a Valery Kosmatshov, a/
k/a Valery Kosmachev (‘‘Kosmachov’’),
and Sergey Vetrov a/k/a Sergei Vetrov
(‘‘Vetrov’’) (collectively,
‘‘Respondents’’). OEE also has
requested, pursuant to Sections 766.23
and 766.24 of the Regulations, that this
order (‘‘the TDO’’) be applied to Real
Components, Ltd. (‘‘Real Components’’)
as a related person.
Eastline is located in Tallinn, Estonia,
and describes itself as a distributor of
electronic parts and components,
computer-related products, industrial
personal computers and embedded
systems, equipment for industrial
automation, and other state-of-the-art
solutions. The company holds an
Estonian business license and has two
addresses in Tallinn identified in
registration documents. Eastline is
operated primarily for the purpose of
procuring electronic components,
including those of U.S. origin.
Kosmachov and Vetrov were listed as
co-owners of Eastline until late 2016.
The company is currently listed as being
solely owned by Valeria Mihhailova,
whom OEE has reason to believe is
Kosmachov’s daughter. Evidence
presented by OEE indicates that both
Kosmachov and Vetrov remain active in
the business, as well as that Kosmachov
also has previously represented that
Eastline partners with Real
Components, which is located in
Moscow, Russia, is owned by Vetrov,
and is Eastline’s primary customer in
Russia.
which lapsed on August 21, 2001. The President,
through Executive Order 13222 of August 17, 2001
(3 CFR, 2001 Comp. 783 (2002)), which has been
extended by successive Presidential Notices, the
most recent being that of August 8, 2018 (83 FR
39871 (Aug. 13, 2018)), continued the Regulations
in full force and effect under the International
Emergency Economic Powers Act, 50 U.S.C. 1701,
et seq. (2012) (‘‘IEEPA’’). On August 13, 2018, the
President signed into law the John S. McCain
National Defense Authorization Act for Fiscal Year
2019, which includes the Export Control Reform
Act of 2018, Title XVII, Subtitle B of Public Law
115–232 (‘‘ECRA’’). While Section 1766 of ECRA
repeals the provisions of the EAA (except for three
sections which are inapplicable here), Section 1768
of ECRA provides, in pertinent part, that all rules
and regulations that were made or issued under the
EAA, including as continued in effect pursuant to
IEEPA, and were in effect as of ECRA’s date of
enactment (August 13, 2018), shall continue in
effect according to their terms until modified,
superseded, set aside, or revoked through action
undertaken pursuant to the authority provided
under ECRA.
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Kosmachov also has previously
identified himself as being the sole
owner of Adimir, an Estonian company.
Adimir shares the same business
addresses as Eastline. Adimir is known
to have previously been involved in the
transshipment and attempted
transshipment of U.S.-origin items to
Russia in apparent violation of the
Regulations, as described in a TDO
issued by BIS on March 19, 2015, as
amended on March 23, 2015 (the
‘‘March 2015 TDO’’). See 80 FR 15979
(March 26, 2015); 80 FR 16632 (March
30, 2015).2 During the investigation
leading up to the issuance of the March
2015 TDO, Adimir admitted to
transshipping U.S.-origin items to
Russia, but was not named as a
respondent, as Adimir was believed to
have ceased operating. See id.; see also
Section III., infra. However, as
discussed in Section IV., infra, recentlyobtained evidence indicates that Adimir
appears to have resumed operating, and
to again be involved in the procurement
of U.S.-origin items for transshipment to
Russian customers, primarily including
Real Components.
II. Legal Standard
Pursuant to Section 766.24 of the
Regulations, BIS may issue, on an ex
parte basis, an order temporarily
denying a respondent’s export privileges
upon a showing that the order is
necessary in the public interest to
prevent an ‘‘imminent violation’’ of the
Regulations. 15 CFR 766.24(a)–(b). ‘‘A
violation may be ‘imminent’ either in
time or degree of likelihood.’’ 15 CFR
766.24(b)(3). BIS may show ‘‘either that
a violation is about to occur, or that the
general circumstances of the matter
under investigation or case under
criminal or administrative charges
demonstrate a likelihood of future
violations.’’ Id. As to the likelihood of
future violations, BIS may show that the
violation under investigation or charge
‘‘is significant, deliberate, covert and/or
likely to occur again, rather than
technical or negligent[.]’’ Id. A ‘‘[l]ack of
information establishing the precise
time a violation may occur does not
preclude a finding that a violation is
imminent, so long as there is sufficient
reason to believe the likelihood of a
violation.’’ Id.
Pursuant to Sections 766.23 and
766.24, a TDO also may be made
applicable to other persons if BIS has
reason to believe that they are related to
a respondent and that applying the
2 The limited amendment on March 23, 2015, did
not relate to the discussion of Adimir. See 80 FR
16632, at note 2. The March 2015 TDO was
renewed for an additional 180 days on September
14, 2015. 80 FR 56439 (Sept. 18, 2015).
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order to them is necessary to prevent its
evasion. 15 CFR 766.23(a)–(b) and
766.24(c). A ‘‘related person’’ is a
person, either at the time of the TDO’s
issuance or thereafter, who is related to
a respondent ‘‘by ownership, control,
position of responsibility, affiliation, or
other connection in the conduct of trade
or business.’’ 15 CFR 766.23(a).
III. The March 2015 TDO and Adimir
OU’S Admitted Transshipment
Activities
The March 2015 TDO issued against
Flider Electronics, LLC d/b/a Trident
International Corporation (‘‘Trident’’),
Pavel Semenovich Flider (Trident’s
president and owner), and Gennadiy
Semenovich Flider (Trident’s office
manager) for engaging in conduct
prohibited by the Regulations by
exporting items subject to the EAR to
Russia via transshipment through third
countries, including Estonia and
Finland. Contemporaneous to these
events, in or about March 2015, in an
indictment unsealed in the United
States District Court for the Northern
District of California, Pavel Flider was
charged with fifteen counts of
smuggling goods, one count of
conspiracy to commit international
money laundering, and ten counts of
money laundering, and Trident was
charged with all the same counts, except
conspiracy. On August 16, 2016, Pavel
Flider pled guilty to two counts of
felony smuggling, and Trident pled
guilty to two counts of money
laundering involving the transshipment
of U.S.-origin electronic components
through Estonia and Finland to Russia.
During the investigation, U.S.
authorities identified other companies
and individuals involved in the
transshipment of U.S.-origin electronic
components to Russia.
Specifically, for example, Trident’s
president and owner, Pavel Flider,
identified Adimir in Estonia as the
ultimate consignee in a shipment of
Xilinix field programmable gate array
circuits that were controlled under
Export Control Classification Number
3A001.a.2.c for national security reasons
and required a license for export to
Russia. OEE presented evidence that
indicated that Adimir was not the end
user of the items. In addition,
Kosmachov, an Adimir corporate officer
and its owner, admitted that Adimir had
transshipped U.S.-origin items to Russia
for Trident and Pavel Flider. In an
interview with OEE, Trident office
manager Gennadiy Flider stated that
Trident had been doing business with
Adimir for many years and that it was
the only customer Trident had.
Similarly, Pavel Flider stated in an
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interview that Adimir was Trident’s one
and only customer, and that at times
Adimir requested that items be shipped
to a freight forwarder in Finland, rather
than to Adimir in Estonia.
In sum, the March 2015 TDO
described a procurement scheme that
featured exports of U.S.-origin items
structured as transshipments to
camouflage the actual destination, end
users and/or end uses of the items. As
noted above, while Adimir had been
involved in transshipping the items to
Russia, Adimir was not made a party to
the March 2015 TDO, as it was believed
to have already ceased operating. The
March 2015 TDO and related
investigation appears to have for a time
deterred Adimir and those affiliated or
associated with it from engaging in
similar activities. However, OEE has
presented evidence as part of its current
TDO request indicating that by at least
May 2017, Kosmachov and Vetrov were
using a revised scheme with Eastline
identified falsely as the ultimate
consignee and have expanded their
activities to include the procurement of
U.S.-origin items by both Eastline and
Adimir, including as recently as August
and September 2018.
IV. Subsequent Interviews With
Kosmachov About Eastline, the
Detention of an Attempted
Transshipment in May 2017, and More
Recent Procurement and
Transshipment Activities Involving
Eastline and Adimir
OEE’s current request for a TDO
includes evidence that an ongoing
procurement scheme involves Eastline
and Adimir in Estonia and Eastline’s
customer and partner Real Components
Ltd. in Russia, all of whom share or
have shared a common web of
ownership or control involving
Kosmachov and Vetrov. For example,
Adimir and Eastline not only share a
common address but also have shared a
common owner in Kosmachov, who, as
discussed supra, previously admitted to
using Adimir to transship U.S.-origin
items to Russia. Kosmachov remains
active in Eastline’s procurement
operations, though company registration
documents do not currently list him as
a shareholder. Furthermore, Eastline
and Real Components both have ties to
Vetrov, with his continuing
involvement in Eastline procurement
activities and ownership of Real
Components. As set forth below, OEE
has presented evidence of these
relationships based on interviews with
Eastline in 2015–2016, a detained
shipment in May 2017 and information
related to recent export activities.
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In July 2015, Kosmachov, who was
Eastline’s acknowledged co-owner at the
time (and until late November 2016),
told the U.S. Government that Eastline
started in 2005 as an independent
distributor of electronic parts and
components, among other items.
Kosmachov stated that 99% of Eastline’s
business was in electronic components
and that its primary customers are in
Russia. According to Kosmachov, he
chose to do business in Estonia because
‘‘it was easier to get electronics into
Estonia than it was into Russia.’’ He also
stated that U.S. companies were ‘‘easier
to deal with as a European company,
rather than as a Russian company.’’
Kosmachov indicated that ‘‘all Eastline’s
shipments to Russia go across the
Tallinn-Helsinki Ferry to Helsinki and
then across the Finnish-Russian border’’
because it was ‘‘cheaper’’ and took ‘‘less
time’’ than shipping directly from
Estonia to Russia. Also present at this
meeting was another individual
identified as a purchasing manager for
both Eastline and Real Components.
Kosmachov indicated that Eastline
partners with Real Components, which
is owned by Vetrov.
In a subsequent meeting in March
2016, Kosmachov confirmed that
nothing had changed in relation to
Eastline since the May 2015 meeting
and that he continued to own Adimir,
which shares business addresses with
Eastline. He noted again that Eastline
primarily exports to Real Components
in Russia. The purchasing manager for
both Eastline and Real Components was
again present at this meeting.
OEE has presented evidence that
Kosmachov and Vetrov remained the
acknowledged shareholders in Eastline
until November 29, 2016, at which time
Valeria Mihhailova, who is believed to
be Kosmachov’s daughter, became listed
as the sole shareholder. Information
obtained from a May 2017 detention by
the Department of Homeland Security
indicates, moreover, that Kosmachov
and Vetrov continue to be active in
Eastline’s business operations by having
items from the United States procured
under their names for Eastline and
delivered on Eastline’s behalf to a
package forwarder’s address in the
United States. The package forwarder
then consolidated multiple Eastline
shipments into one export and, based on
information provided by Eastline,
created a commercial invoice and made
an Electronic Export Information
(‘‘EEI’’) filing in the Automated Export
System (‘‘AES’’) 3 listing Estonia as the
3 The AES system is used by BIS (and U.S.
Customs and Border Protection) for export control
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ultimate destination and Eastline as the
ultimate consignee, even though
Eastline has admitted that it is not an
end user and that its primary customers
are in Russia. The related export
documents listed the ‘‘bill to’’ party as
‘‘Eastline Technologies OU, Attn: Valery
Kosmachov’’ in Estonia, and the ‘‘ship
to’’ as ‘‘Eastline Technologies OU, Attn:
Sergey Vetrov’’ at the package
forwarder’s address in the United States.
Furthermore, OEE has presented
evidence that Kosmachov and Vetrov
currently have access to Eastline bank
accounts.
Based on a review of EEI filings in
AES for 2018, Eastline continued to
order U.S.-origin items and have them
delivered to its package forwarder in the
U.S., for consolidation and export from
the United States, with Eastline listed as
the ultimate consignee at its address in
Estonia, including as recently as June
2018. Based on the transshipment
activities described in the March 2015
TDO, the May 2017 detention, and its
ongoing investigation, OEE has reason
to believe these items were actually
intended for Real Components or
another Russian customer and thus were
transshipped to Russia. In addition,
Eastline represents itself on its website
as an independent ‘‘distributor’’ of
electronic computers for such locations
as Russia, lending additional support to
OEE’s contention that Eastline is not an
end user of the items it procures.
Moreover, OEE is concerned that
Respondents’ strategy of using a package
forwarder in the United States to
consolidate orders placed with multiple
U.S. manufacturers or suppliers, rather
than having the items exported directly
by the manufacturers or suppliers
themselves, may be part of a concerted
effort to conceal their activities.
Further, OEE has presented evidence
indicating that both Eastline and Adimir
have received shipments of U.S.-origin
items as recently as August and
September 2018, including shipments
directly to Eastline and Adimir and
shipments to Eastline through its
package forwarder in the United States.
Kosmachov’s involvement in both
Eastline and Adimir, Adimir’s prior
involvement with transshipment of
controlled U.S.-origin items to Russia,
and Adimir’s continued receipt of U.S.origin items, taken together, indicate
that Adimir as well as Eastline presents
an imminent threat of a violation of the
Regulations and thus a temporary denial
order is appropriate.
and clearance purposes and used by the U.S.
Census Bureau to, inter alia, collect export
statistics.
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V. Findings
I find that the evidence presented by
BIS demonstrates that a violation of the
Regulations is imminent in both time
and degree of likelihood. Eastline,
Adimir, Kosmachov, and Vetrov have
engaged in knowing violations of the
Regulations relating to the procurement
of U.S.-origin items subject to the
Regulations for export to Russia, via
transshipment through Estonia and
Finland, while providing false or
misleading information regarding the
ultimate consignee and final destination
of the items to U.S. suppliers and/or the
U.S. Government. The ways in which
their export transactions have been
structured and routed appear designed
to conceal or obscure the destinations,
end users, and/or end uses of the U.S.origin items they procure, including
items on the Commerce Control List,
thereby attempting to avoid export
control scrutiny and possible detection
by U.S. law enforcement.
In sum, the facts and circumstances
taken together, including the
transshipment of U.S.-origin items,
misrepresentations made in AES filings,
and concerted actions of the
Respondents, provide strong indicators
that future violations are likely absent
the issuance of a TDO. As such, a TDO
is needed to give notice to persons and
companies in the United States and
abroad that they should cease dealing
with Eastline, Adimir, Kosmachov, and
Vetrov in export transactions involving
items subject to the EAR. Accordingly,
I find that an order denying the export
privileges of Eastline, Adimir,
Kosmachov, and Vetrov is necessary, in
the public interest, to prevent an
imminent violation of the EAR.
Additionally, Section 766.23 of the
Regulations provides that in order to
prevent evasion, TDOs ‘‘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.’’ 15 CFR 766.23(a). Eastline
and Real Components are intertwined in
ownership and control and in their
conduct of business. As noted above,
Vetrov owns Real Components,
Eastline’s primary customer in Russia,
and also remains active in Eastline,
including apparently receiving
shipments on behalf of the company
and also holding a bank card in
Eastline’s name. The two companies
also share a purchasing manager, further
suggesting that Eastline serves as a
procurement and transshipment agent
for Real Components. Accordingly, I
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find that Real Components meets the
criteria set out in Section 776.23 and
should be added to the TDO as a related
person in order to prevent evasion.
This Order is being issued on an ex
parte basis without a hearing based
upon BIS’s showing of an imminent
violation in accordance with Section
766.24 of the Regulations.
It is therefore ordered:
First, that EASTLINE
TECHNOLOGIES OU, with last known
addresses at Akadeemia tee 21, 12618
Tallinn, Estonia, and Peterburi tee 47–
210, 11415 Tallinn, Estonia, ADIMIR
OU, with last known addresses at
Akadeemia tee 21, 12618 Tallinn,
Estonia, and Peterburi tee 47–210,
11415 Tallinn, Estonia, VALERY
KOSMACHOV, a/k/a VALERI
KOSMACHOV, a/k/a VALERY
KOSMATSOV, a/k/a VALERY
KOSMATSHOV, a/k/a VALERY
KOSMACHEV, with a last known
address at Vabao˜hukooli tee 76–A9,
12015 Tallinn, Estonia, SERGEY
VETROV, a/k/a SERGEI VETROV, with
a last known address at 6–39 Karl Marx
Str., Ramenskoye, Moscow, Russia,
140100, and REAL COMPONENTS
LTD., with a last known address at 8–
1 Aviamotornaya Str., Moscow, Russia,
111024, and when acting for or on their
behalf, any successors, assigns,
directors, officers, employees, or agents
(each a ‘‘Denied Person’’ and
collectively the ‘‘Denied Persons’’) 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
Export Administration Regulations
(‘‘EAR’’), or in any other activity subject
to the EAR 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 EAR, or engaging in any
other activity subject to the EAR; or
C. Benefitting in any way from any
transaction involving any item exported
or to be exported from the United States
that is subject to the EAR, or from any
other activity subject to the EAR.
Second, that no person may, directly
or indirectly, do any of the following:
A. Export or reexport to or on behalf
of a Denied Person any item subject to
the EAR;
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B. Take any action that facilitates the
acquisition or attempted acquisition by
a Denied Person of the ownership,
possession, or control of any item
subject to the EAR that has been or will
be exported from the United States,
including financing or other support
activities related to a transaction
whereby a 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 a Denied Person of any
item subject to the EAR that has been
exported from the United States;
D. Obtain from a Denied Person in the
United States any item subject to the
EAR 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 EAR that has
been or will be exported from the
United States and which is owned,
possessed or controlled by a Denied
Person, or service any item, of whatever
origin, that is owned, possessed or
controlled by a Denied Person if such
service involves the use of any item
subject to the EAR 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, after notice and
opportunity for comment as provided in
Section 766.23 of the EAR, any other
person, firm, corporation, or business
organization or entity related to Eastline
Technologies OU, Adimir OU, Valery
Kosmachov, or Sergey Vetrov by
ownership, control, position of
responsibility, affiliation, or other
connection in the conduct of trade or
business may also be made subject to
the provisions of this Order.
In accordance with the provisions of
Section 766.24(e) of the EAR, Eastline
Technologies OU, Adimir OU, Valery
Kosmachov, and Sergey Vetrov may, at
any time, appeal 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.
In accordance with the provisions of
Sections 766.23(c)(2) and 766.24(e)(3) of
the EAR, Real Components Ltd. may, at
any time, appeal its inclusion as a
related person 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.
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In accordance with the provisions of
Section 766.24(d) of the EAR, BIS may
seek renewal of this Order by filing a
written request not later than 20 days
before the expiration date. Eastline
Technologies OU, Adimir OU, Valery
Kosmachov, and Sergey Vetrov may
oppose a request to renew this Order by
filing a written submission with the
Assistant Secretary for Export
Enforcement, which must be received
not later than seven days before the
expiration date of the Order.
A copy of this Order shall be sent to
Eastline Technologies OU, Adimir OU,
Valery Kosmachov, Sergey Vetrov, and
Real Components Ltd., and shall be
published in the Federal Register.
This Order is effective upon issuance
and shall remain in effect for 180 days.
Douglas Hassebrock,
Director, Office of Export Enforcement,
performing the non-exclusive functions and
duties of the Assistant Secretary of Commerce
for Export Enforcement.
[FR Doc. 2018–21446 Filed 10–1–18; 8:45 am]
BILLING CODE P
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International Trade Administration
[A–433–813 and A–427–830]
Strontium Chromate From Austria and
France: Initiation of Less-Than-FairValue Investigations
Enforcement and Compliance,
International Trade Administration,
Department of Commerce.
DATES: Applicable September 25, 2018.
FOR FURTHER INFORMATION CONTACT:
Dennis McClure or Brian Smith at (202)
482–5973 or (202) 482–1766,
respectively; AD/CVD Operations,
Enforcement and Compliance,
International Trade Administration,
U.S. Department of Commerce, 1401
Constitution Avenue NW, Washington,
DC 20230.
SUPPLEMENTARY INFORMATION:
AGENCY:
The Petitions
On September 5, 2018, the U.S.
Department of Commerce (Commerce)
received antidumping duty (AD)
petitions concerning imports of
strontium chromate from Austria and
France, filed in proper form on behalf of
the Lumimove Inc., d.b.a. WPC
Technologies (the petitioner).1
From September 7 to 19, 2018, we
requested from the petitioner
1 See the petitioner’s Letter, ‘‘Petitions for the
Imposition of Antidumping Duties on Strontium
Chromate from Austria and France,’’ dated
September 5, 2018 (the Petitions).
PO 00000
Frm 00014
Fmt 4703
Sfmt 4703
49543
information pertaining to the scope and
allegations contained in the petition.2
The petitioner supplemented the record
in response to these requests.3
In accordance with section 732(b) of
the Tariff Act of 1930, as amended (the
Act), the petitioner alleges that imports
of strontium chromate from Austria and
France are being, or are likely to be, sold
in the United States at less than fair
value within the meaning of section 731
of the Act, and that such imports are
materially injuring, or threatening
material injury to, the domestic industry
producing strontium chromate in the
United States. Consistent with section
732(b)(1) of the Act, the Petitions are
accompanied by information reasonably
available to the petitioner supporting its
allegation.
We find that the petitioner filed the
Petitions on behalf of the domestic
industry because the petitioner is an
interested party as defined in section
771(9)(C) of the Act. We also find that
the petitioner demonstrated sufficient
industry support with respect to the
2 See Commerce’s Letters, ‘‘Petitions for the
Imposition of Antidumping Duties on Imports of
Strontium Chromate from Austria and France:
Supplemental Questions,’’ dated September 7,
2018; ‘‘Petition for the Imposition of Antidumping
Duties on Imports of Strontium Chromate from
France: Supplemental Questions,’’ dated September
7, 2018; ‘‘Petition for the Imposition of
Antidumping Duties on Imports of Strontium
Chromate from Austria: Supplemental Questions,’’
dated September 7, 2018; ‘‘Phone Call with Counsel
to Petitioner,’’ dated September 14, 2018; ‘‘Phone
Call with Counsel to Petitioner,’’ dated September
17, 2018; and Memorandum, ‘‘Petitions for the
Imposition of Antidumping Duties on Imports of
Strontium Chromate from Austria and France;
Phone Call with Counsel to the Petitioner,’’ dated
September 19, 2018 (September 19, 2018
Memorandum).
3 See the petitioner’s Letters, titled, ‘‘Petitioner’s
Response to the Department of Commerce’s
September 7, 2018 General Issues Questionnaire
Regarding the Petitions for the Imposition of
Antidumping Duties on Strontium Chromate from
France and Austria,’’ dated September 13, 2018
(General Issues Supplement); ‘‘Petitioner’s
Response to the Department of Commerce’s
September 7, 2018 Volume II Supplemental
Questionnaire Regarding the Petitions for the
Imposition of Antidumping Duties on Strontium
Chromate from Austria’’, dated September 13, 2018
(Austria AD Supplement); ‘‘Petitioner’s Response to
the Department of Commerce’s September 7, 2018
Volume II Supplemental Questionnaire Regarding
the Petitions for the Imposition of Antidumping
Duties on Strontium Chromate from France,’’ dated
September 13, 2018 (France AD Supplement);
‘‘Petitioner’s Response to Questions from the
Department of Commerce’s September 14, 2018
Phone Call Regarding the Petitions for the
Imposition of Antidumping Duties on Strontium
Chromate from France and Austria,’’ dated
September 17, 2018 (Second Supplement); and
‘‘Petitioner’s Response to Questions from the
Department of Commerce’s September 17, 2018
Phone Call Regarding the Petitions for the
Imposition of Antidumping Duties on Strontium
Chromate from France and Austria,’’ dated
September 18, 2018 (Third Supplement).
E:\FR\FM\02OCN1.SGM
02OCN1
Agencies
[Federal Register Volume 83, Number 191 (Tuesday, October 2, 2018)]
[Notices]
[Pages 49540-49543]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-21446]
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DEPARTMENT OF COMMERCE
Bureau of Industry and Security
Order Temporarily Denying Export Privileges
Eastline Technologies OU, Akadeemia tee 21, 12618 Tallinn, Estonia;
and Peterburi tee 47-210, 11415 Tallinn, Estonia
Adimir OU, Akadeemia tee 21, 12618 Tallinn, Estonia; and Peterburi
tee 47-210, 11415 Tallinn, Estonia
Valery Kosmachov, a/k/a Valeri Kosmachov, a/k/a Valery Kosmatsov, a/
k/a Valery Kosmatshov, a/k/a Valery Kosmachev, Vaba[otilde]hukooli
tee 76-A9, 12015 Tallinn, Estonia
Sergey Vetrov, a/k/a Sergei Vetrov, 6-39 Karl Marx Str., Ramenskoye,
Moscow, Russia 140100
Real Components Ltd., 8-1 Aviamotornaya Str., Moscow, Russia 111024
I. Introduction and Background of the Parties at Issue
Pursuant to Section 766.24 of the Export Administration Regulations
(the ``Regulations'' or ``EAR''),\1\ the Bureau of Industry and
Security (``BIS''), U.S. Department of Commerce, through its Office of
Export Enforcement (``OEE''), has requested that I issue an order
temporarily denying, for a period of 180 days, the export privileges of
Eastline Technologies OU (``Eastline''), Adimir OU (``Adimir''), Valery
Kosmachov a/k/a Valeri Kosmachov, a/k/a Valery Kosmatsov, a/k/a Valery
Kosmatshov, a/k/a Valery Kosmachev (``Kosmachov''), and Sergey Vetrov
a/k/a Sergei Vetrov (``Vetrov'') (collectively, ``Respondents''). OEE
also has requested, pursuant to Sections 766.23 and 766.24 of the
Regulations, that this order (``the TDO'') be applied to Real
Components, Ltd. (``Real Components'') as a related person.
---------------------------------------------------------------------------
\1\ The Regulations are currently codified in the Code of
Federal Regulations at 15 CFR Parts 730-774 (2018). The Regulations
originally issued under the Export Administration Act of 1979, as
amended, 50 U.S.C. 4601-4623 (Supp. III 2015) (``the EAA''), which
lapsed on August 21, 2001. The President, through Executive Order
13222 of August 17, 2001 (3 CFR, 2001 Comp. 783 (2002)), which has
been extended by successive Presidential Notices, the most recent
being that of August 8, 2018 (83 FR 39871 (Aug. 13, 2018)),
continued the Regulations in full force and effect under the
International Emergency Economic Powers Act, 50 U.S.C. 1701, et seq.
(2012) (``IEEPA''). On August 13, 2018, the President signed into
law the John S. McCain National Defense Authorization Act for Fiscal
Year 2019, which includes the Export Control Reform Act of 2018,
Title XVII, Subtitle B of Public Law 115-232 (``ECRA''). While
Section 1766 of ECRA repeals the provisions of the EAA (except for
three sections which are inapplicable here), Section 1768 of ECRA
provides, in pertinent part, that all rules and regulations that
were made or issued under the EAA, including as continued in effect
pursuant to IEEPA, and were in effect as of ECRA's date of enactment
(August 13, 2018), shall continue in effect according to their terms
until modified, superseded, set aside, or revoked through action
undertaken pursuant to the authority provided under ECRA.
---------------------------------------------------------------------------
Eastline is located in Tallinn, Estonia, and describes itself as a
distributor of electronic parts and components, computer-related
products, industrial personal computers and embedded systems, equipment
for industrial automation, and other state-of-the-art solutions. The
company holds an Estonian business license and has two addresses in
Tallinn identified in registration documents. Eastline is operated
primarily for the purpose of procuring electronic components, including
those of U.S. origin. Kosmachov and Vetrov were listed as co-owners of
Eastline until late 2016. The company is currently listed as being
solely owned by Valeria Mihhailova, whom OEE has reason to believe is
Kosmachov's daughter. Evidence presented by OEE indicates that both
Kosmachov and Vetrov remain active in the business, as well as that
Kosmachov also has previously represented that Eastline partners with
Real Components, which is located in Moscow, Russia, is owned by
Vetrov, and is Eastline's primary customer in Russia.
Kosmachov also has previously identified himself as being the sole
owner of Adimir, an Estonian company. Adimir shares the same business
addresses as Eastline. Adimir is known to have previously been involved
in the transshipment and attempted transshipment of U.S.-origin items
to Russia in apparent violation of the Regulations, as described in a
TDO issued by BIS on March 19, 2015, as amended on March 23, 2015 (the
``March 2015 TDO''). See 80 FR 15979 (March 26, 2015); 80 FR 16632
(March 30, 2015).\2\ During the investigation leading up to the
issuance of the March 2015 TDO, Adimir admitted to transshipping U.S.-
origin items to Russia, but was not named as a respondent, as Adimir
was believed to have ceased operating. See id.; see also Section III.,
infra. However, as discussed in Section IV., infra, recently-obtained
evidence indicates that Adimir appears to have resumed operating, and
to again be involved in the procurement of U.S.-origin items for
transshipment to Russian customers, primarily including Real
Components.
---------------------------------------------------------------------------
\2\ The limited amendment on March 23, 2015, did not relate to
the discussion of Adimir. See 80 FR 16632, at note 2. The March 2015
TDO was renewed for an additional 180 days on September 14, 2015. 80
FR 56439 (Sept. 18, 2015).
---------------------------------------------------------------------------
II. Legal Standard
Pursuant to Section 766.24 of the Regulations, BIS may issue, on an
ex parte basis, an order temporarily denying a respondent's export
privileges upon a showing that the order is necessary in the public
interest to prevent an ``imminent violation'' of the Regulations. 15
CFR 766.24(a)-(b). ``A violation may be `imminent' either in time or
degree of likelihood.'' 15 CFR 766.24(b)(3). BIS may show ``either that
a violation is about to occur, or that the general circumstances of the
matter under investigation or case under criminal or administrative
charges demonstrate a likelihood of future violations.'' Id. As to the
likelihood of future violations, BIS may show that the violation under
investigation or charge ``is significant, deliberate, covert and/or
likely to occur again, rather than technical or negligent[.]'' Id. A
``[l]ack of information establishing the precise time a violation may
occur does not preclude a finding that a violation is imminent, so long
as there is sufficient reason to believe the likelihood of a
violation.'' Id.
Pursuant to Sections 766.23 and 766.24, a TDO also may be made
applicable to other persons if BIS has reason to believe that they are
related to a respondent and that applying the
[[Page 49541]]
order to them is necessary to prevent its evasion. 15 CFR 766.23(a)-(b)
and 766.24(c). A ``related person'' is a person, either at the time of
the TDO's issuance or thereafter, who is related to a respondent ``by
ownership, control, position of responsibility, affiliation, or other
connection in the conduct of trade or business.'' 15 CFR 766.23(a).
III. The March 2015 TDO and Adimir OU'S Admitted Transshipment
Activities
The March 2015 TDO issued against Flider Electronics, LLC d/b/a
Trident International Corporation (``Trident''), Pavel Semenovich
Flider (Trident's president and owner), and Gennadiy Semenovich Flider
(Trident's office manager) for engaging in conduct prohibited by the
Regulations by exporting items subject to the EAR to Russia via
transshipment through third countries, including Estonia and Finland.
Contemporaneous to these events, in or about March 2015, in an
indictment unsealed in the United States District Court for the
Northern District of California, Pavel Flider was charged with fifteen
counts of smuggling goods, one count of conspiracy to commit
international money laundering, and ten counts of money laundering, and
Trident was charged with all the same counts, except conspiracy. On
August 16, 2016, Pavel Flider pled guilty to two counts of felony
smuggling, and Trident pled guilty to two counts of money laundering
involving the transshipment of U.S.-origin electronic components
through Estonia and Finland to Russia. During the investigation, U.S.
authorities identified other companies and individuals involved in the
transshipment of U.S.-origin electronic components to Russia.
Specifically, for example, Trident's president and owner, Pavel
Flider, identified Adimir in Estonia as the ultimate consignee in a
shipment of Xilinix field programmable gate array circuits that were
controlled under Export Control Classification Number 3A001.a.2.c for
national security reasons and required a license for export to Russia.
OEE presented evidence that indicated that Adimir was not the end user
of the items. In addition, Kosmachov, an Adimir corporate officer and
its owner, admitted that Adimir had transshipped U.S.-origin items to
Russia for Trident and Pavel Flider. In an interview with OEE, Trident
office manager Gennadiy Flider stated that Trident had been doing
business with Adimir for many years and that it was the only customer
Trident had. Similarly, Pavel Flider stated in an interview that Adimir
was Trident's one and only customer, and that at times Adimir requested
that items be shipped to a freight forwarder in Finland, rather than to
Adimir in Estonia.
In sum, the March 2015 TDO described a procurement scheme that
featured exports of U.S.-origin items structured as transshipments to
camouflage the actual destination, end users and/or end uses of the
items. As noted above, while Adimir had been involved in transshipping
the items to Russia, Adimir was not made a party to the March 2015 TDO,
as it was believed to have already ceased operating. The March 2015 TDO
and related investigation appears to have for a time deterred Adimir
and those affiliated or associated with it from engaging in similar
activities. However, OEE has presented evidence as part of its current
TDO request indicating that by at least May 2017, Kosmachov and Vetrov
were using a revised scheme with Eastline identified falsely as the
ultimate consignee and have expanded their activities to include the
procurement of U.S.-origin items by both Eastline and Adimir, including
as recently as August and September 2018.
IV. Subsequent Interviews With Kosmachov About Eastline, the Detention
of an Attempted Transshipment in May 2017, and More Recent Procurement
and Transshipment Activities Involving Eastline and Adimir
OEE's current request for a TDO includes evidence that an ongoing
procurement scheme involves Eastline and Adimir in Estonia and
Eastline's customer and partner Real Components Ltd. in Russia, all of
whom share or have shared a common web of ownership or control
involving Kosmachov and Vetrov. For example, Adimir and Eastline not
only share a common address but also have shared a common owner in
Kosmachov, who, as discussed supra, previously admitted to using Adimir
to transship U.S.-origin items to Russia. Kosmachov remains active in
Eastline's procurement operations, though company registration
documents do not currently list him as a shareholder. Furthermore,
Eastline and Real Components both have ties to Vetrov, with his
continuing involvement in Eastline procurement activities and ownership
of Real Components. As set forth below, OEE has presented evidence of
these relationships based on interviews with Eastline in 2015-2016, a
detained shipment in May 2017 and information related to recent export
activities.
In July 2015, Kosmachov, who was Eastline's acknowledged co-owner
at the time (and until late November 2016), told the U.S. Government
that Eastline started in 2005 as an independent distributor of
electronic parts and components, among other items. Kosmachov stated
that 99% of Eastline's business was in electronic components and that
its primary customers are in Russia. According to Kosmachov, he chose
to do business in Estonia because ``it was easier to get electronics
into Estonia than it was into Russia.'' He also stated that U.S.
companies were ``easier to deal with as a European company, rather than
as a Russian company.'' Kosmachov indicated that ``all Eastline's
shipments to Russia go across the Tallinn-Helsinki Ferry to Helsinki
and then across the Finnish-Russian border'' because it was ``cheaper''
and took ``less time'' than shipping directly from Estonia to Russia.
Also present at this meeting was another individual identified as a
purchasing manager for both Eastline and Real Components. Kosmachov
indicated that Eastline partners with Real Components, which is owned
by Vetrov.
In a subsequent meeting in March 2016, Kosmachov confirmed that
nothing had changed in relation to Eastline since the May 2015 meeting
and that he continued to own Adimir, which shares business addresses
with Eastline. He noted again that Eastline primarily exports to Real
Components in Russia. The purchasing manager for both Eastline and Real
Components was again present at this meeting.
OEE has presented evidence that Kosmachov and Vetrov remained the
acknowledged shareholders in Eastline until November 29, 2016, at which
time Valeria Mihhailova, who is believed to be Kosmachov's daughter,
became listed as the sole shareholder. Information obtained from a May
2017 detention by the Department of Homeland Security indicates,
moreover, that Kosmachov and Vetrov continue to be active in Eastline's
business operations by having items from the United States procured
under their names for Eastline and delivered on Eastline's behalf to a
package forwarder's address in the United States. The package forwarder
then consolidated multiple Eastline shipments into one export and,
based on information provided by Eastline, created a commercial invoice
and made an Electronic Export Information (``EEI'') filing in the
Automated Export System (``AES'') \3\ listing Estonia as the
[[Page 49542]]
ultimate destination and Eastline as the ultimate consignee, even
though Eastline has admitted that it is not an end user and that its
primary customers are in Russia. The related export documents listed
the ``bill to'' party as ``Eastline Technologies OU, Attn: Valery
Kosmachov'' in Estonia, and the ``ship to'' as ``Eastline Technologies
OU, Attn: Sergey Vetrov'' at the package forwarder's address in the
United States. Furthermore, OEE has presented evidence that Kosmachov
and Vetrov currently have access to Eastline bank accounts.
---------------------------------------------------------------------------
\3\ The AES system is used by BIS (and U.S. Customs and Border
Protection) for export control and clearance purposes and used by
the U.S. Census Bureau to, inter alia, collect export statistics.
---------------------------------------------------------------------------
Based on a review of EEI filings in AES for 2018, Eastline
continued to order U.S.-origin items and have them delivered to its
package forwarder in the U.S., for consolidation and export from the
United States, with Eastline listed as the ultimate consignee at its
address in Estonia, including as recently as June 2018. Based on the
transshipment activities described in the March 2015 TDO, the May 2017
detention, and its ongoing investigation, OEE has reason to believe
these items were actually intended for Real Components or another
Russian customer and thus were transshipped to Russia. In addition,
Eastline represents itself on its website as an independent
``distributor'' of electronic computers for such locations as Russia,
lending additional support to OEE's contention that Eastline is not an
end user of the items it procures. Moreover, OEE is concerned that
Respondents' strategy of using a package forwarder in the United States
to consolidate orders placed with multiple U.S. manufacturers or
suppliers, rather than having the items exported directly by the
manufacturers or suppliers themselves, may be part of a concerted
effort to conceal their activities.
Further, OEE has presented evidence indicating that both Eastline
and Adimir have received shipments of U.S.-origin items as recently as
August and September 2018, including shipments directly to Eastline and
Adimir and shipments to Eastline through its package forwarder in the
United States. Kosmachov's involvement in both Eastline and Adimir,
Adimir's prior involvement with transshipment of controlled U.S.-origin
items to Russia, and Adimir's continued receipt of U.S.-origin items,
taken together, indicate that Adimir as well as Eastline presents an
imminent threat of a violation of the Regulations and thus a temporary
denial order is appropriate.
V. Findings
I find that the evidence presented by BIS demonstrates that a
violation of the Regulations is imminent in both time and degree of
likelihood. Eastline, Adimir, Kosmachov, and Vetrov have engaged in
knowing violations of the Regulations relating to the procurement of
U.S.-origin items subject to the Regulations for export to Russia, via
transshipment through Estonia and Finland, while providing false or
misleading information regarding the ultimate consignee and final
destination of the items to U.S. suppliers and/or the U.S. Government.
The ways in which their export transactions have been structured and
routed appear designed to conceal or obscure the destinations, end
users, and/or end uses of the U.S.-origin items they procure, including
items on the Commerce Control List, thereby attempting to avoid export
control scrutiny and possible detection by U.S. law enforcement.
In sum, the facts and circumstances taken together, including the
transshipment of U.S.-origin items, misrepresentations made in AES
filings, and concerted actions of the Respondents, provide strong
indicators that future violations are likely absent the issuance of a
TDO. As such, a TDO is needed to give notice to persons and companies
in the United States and abroad that they should cease dealing with
Eastline, Adimir, Kosmachov, and Vetrov in export transactions
involving items subject to the EAR. Accordingly, I find that an order
denying the export privileges of Eastline, Adimir, Kosmachov, and
Vetrov is necessary, in the public interest, to prevent an imminent
violation of the EAR.
Additionally, Section 766.23 of the Regulations provides that in
order to prevent evasion, TDOs ``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.''
15 CFR 766.23(a). Eastline and Real Components are intertwined in
ownership and control and in their conduct of business. As noted above,
Vetrov owns Real Components, Eastline's primary customer in Russia, and
also remains active in Eastline, including apparently receiving
shipments on behalf of the company and also holding a bank card in
Eastline's name. The two companies also share a purchasing manager,
further suggesting that Eastline serves as a procurement and
transshipment agent for Real Components. Accordingly, I find that Real
Components meets the criteria set out in Section 776.23 and should be
added to the TDO as a related person in order to prevent evasion.
This Order is being issued on an ex parte basis without a hearing
based upon BIS's showing of an imminent violation in accordance with
Section 766.24 of the Regulations.
It is therefore ordered:
First, that EASTLINE TECHNOLOGIES OU, with last known addresses at
Akadeemia tee 21, 12618 Tallinn, Estonia, and Peterburi tee 47-210,
11415 Tallinn, Estonia, ADIMIR OU, with last known addresses at
Akadeemia tee 21, 12618 Tallinn, Estonia, and Peterburi tee 47-210,
11415 Tallinn, Estonia, VALERY KOSMACHOV, a/k/a VALERI KOSMACHOV, a/k/a
VALERY KOSMATSOV, a/k/a VALERY KOSMATSHOV, a/k/a VALERY KOSMACHEV, with
a last known address at Vaba[otilde]hukooli tee 76-A9, 12015 Tallinn,
Estonia, SERGEY VETROV, a/k/a SERGEI VETROV, with a last known address
at 6-39 Karl Marx Str., Ramenskoye, Moscow, Russia, 140100, and REAL
COMPONENTS LTD., with a last known address at 8-1 Aviamotornaya Str.,
Moscow, Russia, 111024, and when acting for or on their behalf, any
successors, assigns, directors, officers, employees, or agents (each a
``Denied Person'' and collectively the ``Denied Persons'') 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 Export Administration
Regulations (``EAR''), or in any other activity subject to the EAR
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 EAR, or engaging in any other
activity subject to the EAR; or
C. Benefitting in any way from any transaction involving any item
exported or to be exported from the United States that is subject to
the EAR, or from any other activity subject to the EAR.
Second, that no person may, directly or indirectly, do any of the
following:
A. Export or reexport to or on behalf of a Denied Person any item
subject to the EAR;
[[Page 49543]]
B. Take any action that facilitates the acquisition or attempted
acquisition by a Denied Person of the ownership, possession, or control
of any item subject to the EAR that has been or will be exported from
the United States, including financing or other support activities
related to a transaction whereby a 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 a Denied Person of any item subject to
the EAR that has been exported from the United States;
D. Obtain from a Denied Person in the United States any item
subject to the EAR 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 EAR
that has been or will be exported from the United States and which is
owned, possessed or controlled by a Denied Person, or service any item,
of whatever origin, that is owned, possessed or controlled by a Denied
Person if such service involves the use of any item subject to the EAR
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, after notice and opportunity for comment as provided
in Section 766.23 of the EAR, any other person, firm, corporation, or
business organization or entity related to Eastline Technologies OU,
Adimir OU, Valery Kosmachov, or Sergey Vetrov by ownership, control,
position of responsibility, affiliation, or other connection in the
conduct of trade or business may also be made subject to the provisions
of this Order.
In accordance with the provisions of Section 766.24(e) of the EAR,
Eastline Technologies OU, Adimir OU, Valery Kosmachov, and Sergey
Vetrov may, at any time, appeal 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.
In accordance with the provisions of Sections 766.23(c)(2) and
766.24(e)(3) of the EAR, Real Components Ltd. may, at any time, appeal
its inclusion as a related person 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.
In accordance with the provisions of Section 766.24(d) of the EAR,
BIS may seek renewal of this Order by filing a written request not
later than 20 days before the expiration date. Eastline Technologies
OU, Adimir OU, Valery Kosmachov, and Sergey Vetrov may oppose a request
to renew this Order by filing a written submission with the Assistant
Secretary for Export Enforcement, which must be received not later than
seven days before the expiration date of the Order.
A copy of this Order shall be sent to Eastline Technologies OU,
Adimir OU, Valery Kosmachov, Sergey Vetrov, and Real Components Ltd.,
and shall be published in the Federal Register.
This Order is effective upon issuance and shall remain in effect
for 180 days.
Douglas Hassebrock,
Director, Office of Export Enforcement, performing the non-exclusive
functions and duties of the Assistant Secretary of Commerce for Export
Enforcement.
[FR Doc. 2018-21446 Filed 10-1-18; 8:45 am]
BILLING CODE P