CHINESE COMPANIES EVADE U.S. TRADE BAN

A Report by the Wisconsin Project on Nuclear Arms Control

December 15, 2009

By Matthew Godsey

 

Lax enforcement of U.S. sanctions is allowing Chinese companies to continue to ship goods to the United States even after being hit with an import ban for proliferation to Iran. See Appendix listing U.S. companies that received imports from a sanctioned Chinese company since 2006. See also related story in the Wall Street Journal. (**Note: information contained in this report was presented to the Office of Foreign Assets Control (OFAC) in mid-December 2009. On December 31, 2009, after reviewing this information, OFAC added the name of one of the companies described in the report – “China JMM Import & Export Shanghai Pudong Corporation” – to its Specially Designated National (SDN) list.)

 

As the United States tries to muster support for stronger international sanctions against Iran, there is mounting evidence that the United States itself is not devoting the resources needed to enforce its own sanctions – notably against companies arming Iran. Tough laws have been enacted to punish such companies, but these laws are not being adequately enforced. In fact, the Wisconsin Project has discovered several instances in which two Chinese companies, sanctioned for arming Iran, have exploited holes in the U.S. sanctions regime.

These companies have managed to evade – and are still evading – one of the most powerful punishments the U.S. government can impose on a foreign company – to ban it from selling its goods in the United States. The purpose of the ban is to discourage a foreign company from conduct such as contributing to the spread of mass destruction weapons. By denying a foreign company access to the American consumer, our government can force the company to choose between what it can earn from exporting to the United States and what it can earn elsewhere from its sanctionable conduct. The hope is that the company will decide that exporting to the United States is better for its bottom line.

This strategy, however, can only work if the import ban is enforced. Unfortunately, in recent years more attention has been given to announcing prohibitions than to enforcing them. The Treasury Department’s Office of Foreign Assets Control (OFAC), which is responsible for administering and enforcing approximately 30 economic sanctions programs,[1] has seen its workload increase rapidly as new sanctions are announced and additional companies are blacklisted. Although it runs one of the U.S. government’s only effective programs for fighting weapons proliferation and publishes by far the most thorough and usable blacklists of suspect entities, OFAC has not been given nearly the resources it needs to keep up with the growth in its responsibilities. This failure to properly fund an agency widely acknowledged to play a vital role in national security is both dangerous and baffling, especially when one considers that OFAC’s 2009 budget of $32 million was roughly equivalent to the cost of a single F-18C fighter jet.[2]

China Precision Machinery Import-Export Corporation

One tangible consequence of underfunding enforcement is that American firms have been receiving prohibited imports—probably unwittingly—from foreign firms that are barred from doing business in the United States. One such firm is China Precision Machinery Import-Export Corporation (CPMIEC), a Chinese company that U.S. officials have branded a “serial proliferator” because of its long-time supply of missile technology to Iran.[3]

CPMIEC was first sanctioned by the United States in 1991 because it sold equipment for M-11 short-range ballistic missiles to Pakistan.[4] In 2002, CPMIEC was punished for missile-related sales to Iran,[5] the first in a series of sanctions that would be imposed on the company on a near-yearly basis under the then-new Iran Nonproliferation Act.[6] But these measures, while useful for drawing international attention to CPMIEC’s reckless sales, did nothing to restrict its access to the U.S. market.

In July 2003, however, CPMIEC was sanctioned by the U.S. State Department under Executive Order 12938.[7] It was the first time that CPMIEC was subjected to an import ban, a prohibition that remains in effect today. The special strength behind this measure, the part that gives it “teeth,” is the fact that the ban applies not only to CPMIEC itself, but also to any entity it owns or controls,[8] including “any subsidiaries and branches, wherever located…”[9] In June 2006, CPMIEC was also penalized under Executive Order 13382,[10] which freezes assets under U.S. jurisdiction and bans transactions with U.S. parties.[11] E.O. 13382 applies not only to the listed entity itself, but to any entity “in which it owns, directly or indirectly, a 50% or greater interest,” and applies “regardless of whether the entity itself is listed in the annex to an Executive order or otherwise placed on OFAC’s list of Specially Designated Nationals.”[12] Yet the U.S. government has never provided the names or addresses of any such CPMIEC subsidiaries, making it difficult for American buyers to figure out their identities and comply with the law.

CPMIEC Shanghai Pudong Corp./China JMM Import and Export Shanghai Pudong Corp.

Since at least 2006, American companies have been importing prohibited goods from two CPMIEC subsidiaries. The first is “CPMIEC Shanghai Pudong Corp.,” which CPMIEC lists in English as one of its subsidiaries in a brochure obtained by the Wisconsin Project.[13] The full Chinese name of this subsidiary, which CPMIEC lists in a second brochure with both English and Chinese text, translates directly as “China Precision Machinery Import-Export Shanghai Pudong Corporation.”[14] Thus, there can be no doubt that this company is a CPMIEC subsidiary and that imports into the United States from it are banned. Nevertheless, at least four shipments of goods have passed through U.S. ports since 2006 with the full name of the subsidiary listed as the shipper. Two went to U.S. consignees: the first, to “Component Supply” in Louisville, Kentucky,[15] the second to “American Forge & Foundry” in New York.[16] The two other shipments transited U.S. ports on their way to foreign destinations.[17]

A far greater number of this company’s shipments, however, have arrived in America under an alias: “China JMM Import and Export Shanghai Pudong Corp.” Although this name may not have raised red flags when run through U.S. government screening lists, it is actually an alias for CPMIEC Shanghai Pudong Corp., described above. This fact is revealed on China’s Ministry of Commerce (MOFCOM) website, which provides brief company descriptions in both Chinese and English. There, “China JMM Imp. & Exp. Shanghai Pudong Corp.” is given as the English name of a company whose name in Chinese characters translates literally as “China Precision Machinery Import and Export Shanghai Pudong Corporation.”[18] (The Chinese word for “precision” is rendered into English as “jing-mi,” so “JMM” appears to be an abbreviation for “Jingmi Machinery”).[19] Several other sources in English, such as the websites of the Canton Trade Fair and the Chinese Export Commodities Fair,[20] use the two names interchangeably, while a number of purely Chinese sources use only the “China Precision Machinery Import-Export Shanghai Pudong Corp.” version of the name, yet provide the same address and company website as the one given by China’s Ministry of Commerce.[21] In addition to these sources, the identity of the two names has been confirmed by the company itself. When asked, via email, whether the two names referred to different companies or the same company, a representative replied, “Yes, we are the same company. JMM is the abbreviation of our name.”[22]

Because it is a wholly-owned subsidiary of CPMIEC, imports from China JMM into the United States are prohibited, and U.S. companies or individuals receiving these imports are subject to civil and criminal penalties. Nonetheless, bills of lading obtained by the Wisconsin Project show that China JMM has made numerous shipments to and through the United States during the past four years, including at least 79 in 2006, at least 81 in 2007, at least 94 in 2008, and at least 49 as of November 29, 2009.[23] These shipments went to 39 different American companies and consisted of a wide range of goods, from automobile parts and textiles to pet toys.[24]

CPMIEC Fuzhou Company/Sharp Industrial Company Ltd.

The second CPMIEC subsidiary that is making prohibited shipments to the United States, and that CPMIEC identifies in its English language brochure, is “CPMIEC Fuzhou Corp.”[25] CPMIEC’s English/Chinese brochure also provides the Chinese version of this subsidiary’s name, which translates directly into English as “China Precision Machinery Import-Export Fuzhou Corporation.”[26] In 2003 this subsidiary’s address, as it appeared on the company website at the time, was “3/F, Minxing Bldg., 190, 817 Northern Street, Fuzhou, China.”[27] This is the very location identified by the Treasury Department in its import ban designation of CPMIEC in July of that year, which read “wherever located, including, 3/F, Minxing Building No. 190, 817 (North) Road, Fuzhou City, Fujian Province, China”.[28] Thus, there can be no doubt that this company is a subsidiary of CPMIEC.

Shipments from this subsidiary sent under the name “China Precision Machinery Imp and Exp Fuzhou Corp.” have gone through U.S. ports to foreign destinations several times since 2006. These shipments should have produced a “hit” during a search of the U.S. government’s screening lists, and should have been denied access to U.S. territory. The shipper’s name and address were a near match and perfect match, respectively, to CPMIEC’s U.S. government listing.[29]

This subsidiary has also been shipping directly to American buyers, but by using a different name: “Sharp Industrial Company Ltd.” In August 2005, the website for CPMIEC Fuzhou Corp. was changed abruptly to become the website for Sharp Industrial. Everything on the website remained exactly the same except for the new corporate name (unchanged were the name of the person to contact, the telephone number and address, graphic displays, the navigation bar, and the text describing the company).[30] China’s Ministry of Commerce continues to list the company under the name China Precision Machinery Import and Export Fuzhou Corp., but refers the reader to the website for Sharp Industrial.[31] Even the company itself has admitted that both names describe the same entity. When asked about the two names, a sales manager confirmed that the name was changed from “China Precision Machinery Import & Export Fuzhou Corp.” to “Sharp Industrial Company Ltd.,” but went on to explain that this change was in name only. She wrote: “Although we changed the name, the employees and business are same as before.”[32]

Three shipments arrived in the United States under the name “Sharp Industrial Company Ltd.” in 2008.[33] The U.S. consignee for all three shipments was “Amaury Int’l Corp.” in Miami. Amaury also received shipments from Sharp Industrial in 2007 and 2006, in each case for “twist drills” and other hardware.[34]

LIMMT Economic and Trade Company, Ltd.

A second Chinese company that has managed to circumvent U.S. restrictions is LIMMT Economic and Trade Company, Ltd. Over the past several years, LIMMT has been the target of both U.S. government sanctions and legal action in New York due to its continued proliferation to Iran.[35] LIMMT was penalized under Executive Order 13382 in June 2006,[36] and was the subject of E.O. 12938 sanctions in February 2009, which banned any import by LIMMT into the United States.[37] In April 2009, LIMMT was indicted in New York State on charges of falsifying business records and conspiracy.[38] In the indictment, prosecutors documented LIMMT’s repeated use of aliases and false names to evade U.S. sanctions.[39]

The Wisconsin Project has found what appears to be an additional alias that LIMMT is now using to continue exporting to customers in the United States. It is “Dalian Orient Pipe Components Co., Ltd.” There are several reasons to believe that this is the same company as LIMMT. First, its address, as listed on bills of lading obtained by the Wisconsin Project, is identical to the address for LIMMT that has been listed by the Treasury Department. The address is “2501-2508 Yuexiu Mansion, No. 82 Xinkai Road, Dalian, China.”[40] Second, on several bills of lading Dalian Orient Pipe lists the same address and same phone number as given on bills of lading for “Dalian Sunny Industry and Trade Co.,”[41] which has been identified as an LIMMT alias by the U.S. Treasury and the U.S. State Department.[42] Finally, the pattern of Dalian Orient Pipe’s exports to one U.S. customer in particular strongly suggests that Dalian was used as an alias to avoid detection. In 2006, “Dalian Sunny Industry and Trade,” an acknowledged alias for LIMMT, made seven shipments of “carbon steel forgings” to “Coastal Flange, Inc.” in Houston.[43] Beginning in 2007, bills of lading stopped showing shipments of carbon steel forgings from Dalian Sunny to Coastal Flange and began showing shipments of the same product from “Dalian Orient Pipe Components Co., Ltd” to the same company.[44] For many of these shipments to Coastal Flange, the only difference in the bills of lading from Dalian Sunny and Dalian Orient Pipe was the shipper’s name. Other essential information remained the same, including shipper and consignee addresses,[45] “notify party” information,[46] and commodity descriptions.[47]

The example of LIMMT shows that the utmost vigilance is required to maintain trade restrictions against a company that is determined to evade them. In 2004, when LIMMT was sanctioned for the first time, the State Department provided only the company’s primary name, with no aliases or name variations.[48] Two years later, when the Treasury Department initially placed LIMMT on its list, Treasury identified four name variations.[49] In April 2009, largely as a result of LIMMT’s indictment earlier in the year, Treasury published additional names and addresses, resulting in a new total of 12 aliases and four addresses for the same company.[50] Now, in light of the emergence of “Dalian Orient Pipe,” described above, it seems that even that was not enough.

Enforcement

Any U.S. company or individual found to be violating the import ban is subject to civil penalties, including a fine of as much $250,000, and if the violation is willful, criminal penalties of up to 20 years in prison.[51] In addition to actually receiving an import of goods from a banned entity, U.S. companies and individuals are also prohibited from financing, acting as a broker for, transferring, transporting, or otherwise participating in such an import, as well as any transaction that has the purpose of evading or avoiding these prohibitions.[52] None of the companies listed in the annex of this report appear to have been penalized for sanctions violations. In fact, a review of monthly reports on civil penalties imposed since 2003 under Treasury’s sanctions programs did not find any example of a U.S. company penalized for violating the import ban on CPMIEC.[53]

For the import ban to be effective, it is essential that the U.S. government identify each sanctioned company as completely as possible, including the names and addresses of all subsidiaries covered by the sanctions. For most U.S. importing companies, sanctions compliance –if done at all – consists only of checking a supplier’s name against the Treasury list or running it through interdiction software. If the search produces a “hit,” it is the importer’s responsibility to investigate further and/or contact Treasury. Yet, even the most sophisticated interdiction software is no better than the names that go into it. At present, the government is simply not providing enough data for red flags to go up when they should.

Congress needs to provide Treasury the resources and personnel required to monitor the growing number of companies sanctioned for proliferation. That is not happening today. A 2007 audit report from the Inspector General of the Treasury Department found that between 2001 and 2004, Treasury’s sanctions programs increased in number from 21 to 29, yet there was no commensurate increase in personnel to oversee them.[54] According to the testimony of a former director of Treasury’s Office of Foreign Assets Control, in 2004 personnel in OFAC’s Civil Penalties Division had an average individual workload of 477 cases.[55] Moreover, competing priorities such as the embargo on Cuba consumed most of OFAC’s time.[56] In April 2006, almost a year after E.O. 13382, dubbed “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters,” went into effect, only six percent of OFAC’s sanctions administration personnel (approximately three full time employees) were allocated to work on proliferation sanctions.[57] These three individuals were apparently responsible for compliance, licensing, enforcement, and civil penalties for all proliferation sanctions.[58] And although there has been a slight increase in funding for this work since 2006, it remains far below the level needed to truly enforce the import ban and other prohibitions.[59]

Without adequate personnel and resources devoted to enforcing nonproliferation sanctions, it is difficult to see how the prohibitions against even “serial proliferators” like CPMIEC and LIMMT can be real deterrents. Instead, these prohibitions will continue as mostly symbolic gestures, and the companies helping Iran will continue to evade them.

Appendix

Exports into the United States since 2006 by companies controlled by or acting for China Precision Machinery Import and Export Corporation (CPMIEC)

A. Exports to the United States by the CPMIEC subsidiary China Precision Machinery Import and Export Shanghai Pudong Corp. (also known as China JMM Import and Export Shanghai Pudong Corporation)

American Consignees:

1. Great China International (Corona, California)
-12 shipments in 2009.
-26 shipments in 2008.
-22 shipments in 2007.
-28 shipments in 2006.

2. Kohler Engines (Hattiesburg, Mississippi)
-2 shipments in 2009.
-10 shipments in 2008.
-18 shipments in 2007.
-4 shipments in 2006.

3. Crystal Temptations (North Arlington, New Jersey)
-6 shipments in 2008.
-11 shipments in 2006.

4. Greenlee Textron (Southaven, Mississippi)
-5 shipments in 2009.
-9 shipments in 2008.

5. Idm Llc. (Auburn, Indiana)
-11 shipments in 2008.

6. Pettraport (North Bergen, New Jersey)
-1 shipment in 2009.
-7 shipments in 2008.

7. Ivy International Trading (Chula Vista, California)
-1 shipment in 2008.
-3 shipments in 2007.
-4 shipments in 2006.

8. Electro Mechanical Industries (Houston, Texas)
-5 shipments in 2007.
-2 shipments in 2006.

9. American Sportsman Sign (Columbia, Missouri)
-1 shipment in 2007.
-6 shipments in 2006.

10. Rockwell Automation (Madison, Indiana)
-1 shipment in 2007.
-3 shipments in 2006.

11. H + H Dist. (Ann Arbor, Michigan)
-4 shipments in 2007.

12. Bright Solutions Inc. (Troy, Michigan)
-2 shipments in 2009.
-1 shipment in 2008.

13. Convert a Ball (Sidney, Nebraska)
-3 shipments in 2008.

14. Sedco Corporation (Guaynabo, Puerto Rico)
-1 shipment in 2009.
-1 shipment in 2008.

15. International Pet Supplies and Distribution (San Diego, California)
-2 shipments in 2008.

16. Orrco, Inc. (Orrville, Ohio)
-1 shipment in 2007.
-1 shipment in 2006.

17. Textile One (Los Angeles, California)
-1 shipment in 2007.
-1 shipment in 2006.

18. Oxford Textile (Los Angeles, California)
-2 shipments in 2007.

19. Amca International Inc. (Arlington Heights, Illinois)
-2 shipments in 2006.

20. Ton Qiang Construction (Corona, California)
-2 shipments in 2006.

21. Truemark International Corp. (Stafford, Texas)
-1 shipment in 2009.

22. Boca Advanced Materials (Blue Ash, Ohio)
-1 shipment in 2009.

23. N.t.t. Fashion (Bayside, New York)
-1 shipment in 2009.

24. Global Commerce System (Compton, California)
-1 shipment in 2008.

25. Decoy Motion Masters (Rogers, Minnesota)
-1 shipment in 2008.

26. Show Off Body Art (Clarkston, Michigan)
-1 shipment in 2008.

27. Ruben Badillo Sanchez (Rincon, Puerto Rico)
-1 shipment in 2008.

28. Petra Pet Inc. (North Bergen, New Jersey)
-1 shipment in 2008.

29. E.I. Dupont De Nemours (Wilmington, Delaware)
-1 shipment in 2008.

30. Dgi, Llc (Warren, New Jersey)
-1 shipment in 2008.

31. CMC Tech (Houston, Texas)
-1 shipment in 2008.

32. Millennium Int’l Group (Hillside, New Jersey)
-1 shipment in 2007.

33. Maycrick Corporation (Cincinnati, Ohio)
-1 shipment in 2007.

34. Elizondo Inc. (Laredo, Texas)
-1 shipment in 2007.

35. Esca Inc. (Laredo, Texas)
-1 shipment in 2007.

36. Welco Lumber Corp. (South Kent, Washington)
-1 shipment in 2006.

37. Standard Hardware Inc. (Euless, Texas)
-1 shipment in 2006.

38. Giant Fabric Inc. (Vernon, California)
-1 shipment in 2006.

39. Expo Convention Contractors, Inc. (Miami, Florida)
-1 shipment in 2006.

40. Component Supply (Louisville, Kentucky)
-1 shipment in 2006.

41. American Forge and Foundry (New York, New York)
-1 shipment in 2006.

B. Exports to the United States by the CPMIEC subsidiary China Precision Machinery Import and Export Fuzhou Corp. (also known as Sharp Industrial Company Limited)

American Consignees:

1. Amaury Int’l Corp (Miami, Florida)
-3 shipments in 2008.
-3 shipments in 2007.
-4 shipments in 2006.

 

Footnotes:

1. “Hundreds of OFAC Civil Penalty Cases Expired Before Enforcement Action Could Be Completed,” Audit Report (OIG-07-032), Office of Inspector General, Department of the Treasury, March 2, 2007.

2. Fact File, United States Navy World Wide Web site, http://www.navy.mil/navydata/fact_display.asp?cid=1100&tid=1200&ct=1, accessed on August 18, 2009.

3. Testimony of Stephen G. Rademaker, Assistant Secretary for Arms Control, U.S. Department of State, before the U.S.-China Economic and Security Review Commission, March 10, 2005, available at http://www.uscc.gov/hearings/2005hearings/written_testimonies/05_03_10wrtr/
rademaker_stephen_wrts.php, accessed on August 4, 2009; Testimony of Paula A. DeSutter, Assistant Secretary of State for Verification and Compliance, before the U.S.-China Economic and Security Review Commission, July 24, 2003, available at http://www.uscc.gov/hearings/2003hearings/written_testimonies/03_07_24/tesut.htm, accessed on August 4, 2009.

4. “Adherence to and Compliance with Arms Control, Nonproliferation, and Disarmament Agreements and Commitments,” Bureau of Verification and Compliance, U.S. Department of State, August 30, 2005, available at http://www.state.gov/t/vci/rls/rpt/51977.htm, accessed on August 4, 2009.

5. Testimony of Paula A. DeSutter, Assistant Secretary of State for Verification and Compliance, before the U.S.-China Economic and Security Review Commission, July 24, 2003, available at http://www.uscc.gov/hearings/2003hearings/written_testimonies/03_07_24/tesut.htm, accessed on August 4, 2009.

6. Iran Nonproliferation Act of 2000, U.S. Department of State, available at http://www.state.gov/t/isn/c15234.htm, accessed on August 4, 2009.

7. U.S. Department of State, Bureau of Nonproliferation, "Imposition of Nonproliferation Measures on an Entity in China, Including a Ban on U.S. Government Procurement," Federal Register 68 FR 44832, July 30, 2003.

8. U.S. Department of State, Bureau of Nonproliferation, "Imposition of Nonproliferation Measures on an Entity in China, Including a Ban on U.S. Government Procurement," Federal Register 68 FR 44832, July 30, 2003; “31 C.F.R. Part 539—Weapons of Mass Destruction Trade Control Regulations,” Office of Foreign Assets Control, U.S. Department of the Treasury, available at http://law.justia.com/us/cfr/title31/31-3.1.1.1.9.html, accessed on July 13, 2009.

9. “31 C.F.R. Part 539—Weapons of Mass Destruction Trade Control Regulations,” Office of Foreign Assets Control, U.S. Department of the Treasury, available at http://law.justia.com/us/cfr/title31/31-3.1.1.1.9.html, accessed on July 13, 2009.

10. Treasury Designates U.S. and Chinese Companies Supporting Iranian Missile Proliferation, Press Release, U.S. Department of the Treasury World Wide Web site, http://www.treasury.gov/press/releases/js4317.htm, June 13, 2006; Nonproliferation, Office of Foreign Assets Control, U.S. Department of the Treasury World Wide Web site, http://www.treasury.gov/offices/enforcement/ofac/programs/wmd/wmd.pdf, accessed on July 14, 2009.

11. Treasury Designates U.S. and Chinese Companies Supporting Iranian Missile Proliferation, Press Release, U.S. Department of the Treasury World Wide Web site, http://www.treasury.gov/press/releases/js4317.htm, June 13, 2006.

12. “Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked,” Office of Foreign Assets Control, Department of the Treasury, February 14, 2008, available at http://www.treas.gov/offices/enforcement/ofac/programs/common/licensing_guidance.pdf, accessed on July 14, 2009; Weapons of Mass Destruction Proliferators Sanctions Regulations, Office of Foreign Assets Control, U.S. Department of the Treasury, Federal Register Vol. 74, No. 69, April 13, 2009, pp. 16771-16781.

13. CPMIEC brochure obtained by the Wisconsin Project, undated.

14. China National Precision Machinery Import & Export Corporation, undated brochure, available at NEFA Foundation World Wide Web site, http://www.nefafoundation.org/miscellaneous/FeaturedDocs/
US_v_WangWoodford_exhibitB.pdf, accessed on July 21, 2009.

15. Bill of Lading (B/L: ORLCSHUSA509457E).

16. Bill of Lading (B/L: EXDO6394190625).

17. Bill of Lading (B/L: COHE0604455C); Bill of Lading (B/L: MOLU484949879).

18. China JMM Imp. & Exp. Shanghai Pudong Corp., China Commodity Net, Ministry of Commerce World Wide Web site, http://ccn.mofcom.gov.cn/249702, accessed via Google cache on July 14, 2009.

19. China JMM Imp. & Exp. Shanghai Pudong Corp., China Commodity Net, Ministry of Commerce World Wide Web site, http://ccn.mofcom.gov.cn/249702, accessed via Google cache on July 14, 2009.

20. China JMM Import & Export Shanghai Pudong Corp., Chinese Export Commodities Fair World Wide Web site, http://www.cecf.com.cn/web/en/seller/26741934.html, accessed on July 16, 2009; China JMM Import & Export Shanghai Pudong Corporation, Canton Trade Fair World Wide Web site, http://promoter.cantonfair.org.cn/pages/
simply.aspx?version=en&corpid=0731006928&TopPage_search_bound=exp, accessed on June 24, 2009.

21. Import-Export Representatives, Global Importer World Wide Web site, http://china/globalimporter.net/cgongqiu/35/87/1897552.html (in Chinese), accessed on July 16, 2009; China Precision Machinery Import-Export Shanghai Pudong Corporation, China Import Export Agent World Wide Web site, http://www.cniea.cn/co.asp?id=13590 (in Chinese), accessed on July 22, 2009; China Precision Machinery Import-Export Shanghai Pudong Corporation, Alibaba World Wide Web site, http://china.alibaba.com/company/detail/contact/thomaswy.html (in Chinese), accessed on July 14, 2009; China JMM Imp. & Exp. Shanghai Pudong Corp., China Commodity Net, Ministry of Commerce World Wide Web site, http://ccn.mofcom.gov.cn/249702, accessed via Google cache on July 14, 2009.

22. Email communication with China JMM Imp/Exp Shanghai Pudong Corp, July 17, 2009.

23. Commercial bill of lading database searches for 2006, 2007, 2008, and 2009 shipments from shipper “China JMM,” conducted September 9, 2009.

24. Commercial bill of lading database search for 2006, 2007, 2008, and 2009 shipments from shipper “China JMM”; Bill of Lading (B/L: ACJJSHA08110157); Bill of Lading (B/L: CHHKXSHLGB3AY990); Bill of Lading (B/L: NAQASNYC9402481W).

25. CPMIEC brochure obtained by the Wisconsin Project, undated.

26. China National Precision Machinery Import & Export Corporation, undated brochure, available at NEFA Foundation World Wide Web site, http://www.nefafoundation.org/miscellaneous/FeaturedDocs/
US_v_WangWoodford_exhibitB.pdf, accessed on July 21, 2009.

27. Introduction, China Precision Machinery Imp. & Exp. Fuzhou Corp. World Wide Web site, accessed via http://web.archive.org/web/20030621070233/http://www.cutting-tools.com.cn/, accessed on August 10, 2009.

28. Recent OFAC Actions, July 30, 2003, Office of Foreign Assets Control, U.S. Department of the Treasury, available at http://www.treas.gov/offices/enforcement/ofac/actions/20030730.shtml, accessed on August 10, 2009.

29. Bill of Lading (B/L: DMERDFS670052880); Bill of Lading (B/L: CHHKXSHMTR3AT659).

30. Introduction, China Precision Machinery Imp. & Exp. Fuzhou Corp. World Wide Web site, accessed via www.archive.org at http://web.archive.org/web/20050407172241/http://www.cutting-tools.com.cn on August 10, 2009; Welcome to China Precision Machinery Imp. & Exp. Fuzhou Corp. World Wide Web site, accessed via www.archive.org at http://web.archive.org/web/20050406092040/http://www.cutting-tools.com.cn on August 10, 2009; Welcome to Sharp Industrlal Company Limited, Sharp Industrlal Company Limited World Wide Web site, accessed via www.archive.org at http://web.archive.org/web/20050828153100/http://www.cutting-tools.com.cn, accessed on May 14, 2009.

31. China Precision Machinery Import and Export Fuzhou Corp., China Commodity Net, Ministry of Commerce World Wide Web site, http://ccne.mofcom.gov.cn/html/crse/product.php?ls_fileno=10033291, accessed on July 15, 2009.

32. Email communication with Sharp Industrial Company Ltd., July 20, 2009; Email communication with Sharp Industrial Company Ltd., July 18, 2009.

33. Bill of Lading (B/L: PRSHMZ31973A).; Bill of Lading (B/L: PRSHMZ31615E); Bill of Lading (B/L: PRSHMZ32697F).

34. Bill of Lading (B/L: NAQASMIA7413493W); Bill of Lading (B/L: NAQASMIA6353698W).

35. Indictment, The People of the State of New York v. Li Fang Wei et. al., Supreme Court of the State of New York, County of New York, available at http://manhattanda.org/whatsnew/press/2009-04-07/Indictment%20LFW%20and%20Limmt%20%20FINAL.pdf, accessed on July 24, 2009.

36. Changes to List of Specially Designated Nationals and Blocked Persons Since January 1, 2006, Office of Foreign Assets Control, U.S. Department of the Treasury World Wide Web site, http://www.ustreas.gov/offices/enforcement/ofac/sdn/t11sdnew.pdf, accessed on June 14, 2006; Nonproliferation, Office of Foreign Assets Control, U.S. Department of the Treasury World Wide Web site, http://www.treasury.gov/offices/enforcement/ofac/programs/wmd/wmd.pdf, accessed on June 14, 2006.

37. U.S. Department of State, Bureau of International Security and Nonproliferation,
“Imposition of Nonproliferation Measures on Two Chinese Entities and Two Iranian Entities,” Federal Register Vol. 74, No. 20, p. 5883, February 2, 2009.

38. News Release, New York County District Attorney’s Office, April 7, 2009, available at http://manhattanda.org/whatsnew/press/2009-04-07.shtml, accessed on August 10, 2009.

39. Indictment, The People of the State of New York v. Li Fang Wei et. al., Supreme Court of the State of New York, County of New York, available at http://manhattanda.org/whatsnew/press/2009-04-07/Indictment%20LFW%20and%20Limmt%20%20FINAL.pdf, accessed on July 24, 2009.

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