After Pakistan tested its first nuclear explosive device in 1998, the U.S. Commerce Department added nearly 100 entities involved in Pakistan’s nuclear and missile programs, the majority of which were state-controlled, to the Entity List. These trade restrictions aimed to stem the flow of dual-use goods to Pakistan and slow the expansion of the country’s nuclear and missile arsenals.[1]
From 2014 onwards, the Commerce Department began to target private trading and logistics companies that were procuring items on behalf of restricted Pakistani end users.[2] This approach aimed to disrupt the illicit procurement practices of nuclear and missile entities, including their use of intermediaries, distributors, and front companies, and reliance on transshipment through third countries, notably the United Arab Emirates (UAE).
This report details a procurement network based in Pakistan and the UAE that continues to acquire sensitive goods for Pakistan’s nuclear program, despite trade restrictions. Using open sources, the report illustrates the tactics used by the network to evade export controls and sanctions and highlights the challenges that the U.S. government and industry face in preventing the diversion of goods of proliferation concern to restricted parties and end uses in Pakistan.
The Original Network: Pegasus and NESTACC
In March 2020, UAE-based trading company Pegasus General Trading FZE was added to the Entity List for attempting to acquire U.S.-origin goods for Pakistan’s unsafeguarded nuclear program, providing false and misleading information to the Commerce Department during an end-use check, and falsifying official documents to conceal the end user of items subject to the U.S. Export Administration Regulations (EAR).[3] On the same day, Pakistan-based National Engineering Services Trading and Consultancy Company (NESTACC) was added to the Entity List for its contributions to Pakistan’s unsafeguarded nuclear activities.[4]
Both companies have had extensive business relationships with entities owned, operated, or overseen by the Pakistani government that are sanctioned by the United States and, in some cases, Japan for their contribution to Pakistan’s nuclear and missile programs. Their customers include the Pakistan Atomic Energy Commission (PAEC), the Space and Upper Atmospheric Research Commission (SUPARCO), and Khan Research Laboratories (KRL).[5] Some of the commodities procured by NESTACC and Pegasus may have been diverted to these entities.[6]
Although the Commerce Department did not link Pegasus and NESTACC in its designation, trade data shows that Pegasus had been exporting high volumes of dual-use goods to NESTACC since at least 2014.[7] Additional open-source information reveals connections between Pegasus and NESTACC that go beyond their trade relationship. For example, in 2018, when Pegasus bid on a tender posted by a Pakistani state-owned oil and gas company,[8] it listed NESTACC and its owner, G.Q. Mirza,[9] as the local agents for the bid.[10]
In addition, Mirza created and registered NESTACC’s domain (nestacc.com) using an email address ([email protected]) associated with Pegasus.[11] Mirza had previously owned Pegasus’s domain (pgtfze.com) but transferred its ownership to the current registered manager of Pegasus, Farman Panah.[12]
Pegasus and NESTACC have shared other personnel as well, including Mobeen Ahmed, who represented NESTACC at a 2015 trade show in Islamabad while reportedly serving as a manager at Pegasus.[13]
Trade between Pegasus and NESTACC continued for approximately a year after the companies were sanctioned, with activity ceasing in July 2021, according to trade data.[14]
Designation of Additional Affiliates
Two other Pakistan-based entities with ties to Pegasus and NESTACC have been sanctioned by the Commerce Department.
Triton Educational Equipment & Consultancy Co. was added to the Entity List in March 2020, on the same day as Pegasus and NESTACC, for its contributions to Pakistan’s unsafeguarded nuclear activities.[15] Open-source information suggests that Triton is likely owned and/or operated by NESTACC’s owner, G.Q. Mirza. In May 2018, Mirza registered the presumed domain for Triton (triton-ec.com).[16] Triton and NESTACC are also located in the same building (Khyber Plaza) in Islamabad.[17] Triton, like NESTACC, has a trade relationship with Pegasus, having imported declared U.S.-origin goods with dual-use applications from Pegasus on at least one occasion in June 2020.[18]
In September 2020, Pakistan-based Affiliated Supply and Consultancy Services (ASACS) was added to the Entity List due to its involvement in the procurement of U.S.-origin goods in association with Pegasus.[19] ASACS is the only company that the Commerce Department has explicitly linked to Pegasus. Trade between the two companies ended in July 2020, a few months after Pegasus was added to the Entity List.[20]
Given ASACS’s lack of an online presence, the exact nature of its relationship to other entities in the network is difficult to discern.
The Emergence of Odyssey, Genesis, and Taantu
Although exports from Pegasus to NESTACC, Triton, and ASACS declined, and ultimately ceased, after the companies were sanctioned, the individuals associated with Pegasus and NESTACC appear to have established new companies in the UAE and Pakistan to continue their procurement activities.
UAE-based Odyssey General Trading FZC initially replaced Pegasus as the primary supplier of dual-use goods to Pakistan-based entities in the network – including, briefly, NESTACC itself. Odyssey was likely created for this purpose.
When Pegasus, NESTACC, and Triton were sanctioned in March 2020, Odyssey was not legally incorporated in the UAE, lacked an online presence, and had no recorded business activity. Odyssey’s business license was only issued in May 2020,[21] and its domain (odysseyfzc.com) was created and registered in July of that year.[22]
Odyssey is linked to Pegasus through two individuals: Farman Panah and Tauqir Sadiq. Corporate records indicate that Panah, in addition to being the registered manager of Pegasus,[23] is a shareholder of Odyssey.[24] Sadiq, the registered manager of Odyssey,[25] has also acted on behalf of Pegasus.[26] Odyssey first appeared in trade data in September 2020 and shipped goods to NESTACC on at least five occasions between September 2020 and January 2021.[27]
While Odyssey initially traded with NESTACC, its primary trading partner has been Pakistan-based Genesis Technical Consultancy Services, which is closely linked to NESTACC and bids on Pakistani government tenders.[28] Genesis likely replaced NESTACC as the network’s primary recipient of dual-use goods from the UAE. Since April 2021, Genesis has received over 80 shipments from Odyssey, and between April 2021 to March 2022, Odyssey was its sole supplier.[29]
Connections between NESTACC and Genesis are numerous: Mirza is an executive at both companies;[30] the two entities are located in the same building in Islamabad;[31] and, according to trade data, Genesis has imported goods to the exact same address as NESTACC.[32]
In February 2022, the Commerce Department added Odyssey to the Entity List for contributions to Pakistan’s unsafeguarded nuclear activities.[33]
Since Odyssey’s designation, UAE-based Taantu General Trading LLC has replaced Odyssey as the primary supplier of Genesis. From July through December 2022 (the latest month for which trade data is available), Taantu shipped goods to Genesis on over 40 occasions.[34] Over that same period, Odyssey supplied Genesis just three times.[35]
Taantu, like Odyssey before it, was likely established for the purpose of supplying Pakistan-based companies in the network. Taantu was legally incorporated in March 2022,[36] less than a month after the Commerce Department designated Odyssey, and its domain (taantuae.com) was created and registered that same month.[37] According to commercially available trade data, Genesis is the only company that Taantu has supplied since its establishment.[38]
Taantu’s domain is hosted on the same Pakistan-based IP address as the domains for NESTACC, Odyssey, and Genesis.[39] As a UAE-based company, Taantu’s use of a Pakistan-based internet server, particularly one used by companies in the network, can be considered a red flag and underscores its suspected links to the network.[40]
As of June 2023, Genesis and Taantu have not been added to the Entity List.
Conclusion
Three years after Pegasus and NESTACC were added to the Entity List, the network continues to procure dual-use goods through newly established suppliers and front companies, some of which remain unsanctioned. The designation of Pegasus and NESTACC complicated – but did not eliminate – the network’s ability to procure dual-use goods from abroad, highlighting the challenges that the U.S. government and industry face in identifying risky entities and preventing the diversion of U.S.-origin goods to weapons programs of concern.
In addition to targeting companies involved in illicit procurement, the Commerce Department should focus on identifying the individuals behind such companies. This would more effectively target a network’s central node, increasing the difficulty for individuals like Mirza to continue their procurement activities by simply creating new entities.
While the Commerce Department’s Entity List and resources like the Pakistan Due Diligence Guidance can help industry evaluate trading partners and assess risk, they are no silver bullet. Ultimately, it is critical for industry to conduct comprehensive due diligence – leveraging open-source investigative techniques and reviewing publicly available trade, domain, and corporate registry data – when trading with parties in jurisdictions of concern and known transshipment locations.
Jonathan Gerstein is a Research Assistant at the Wisconsin Project. He contributes research to the Project’s Risk Report database related to Pakistan and Pakistani procurement networks. Research Associate Rachel Kaye contributed to this report.
Footnotes:
[1] “India and Pakistan Sanctions and Other Measures,” U.S. Department of Commerce, Bureau of Export Administration, Federal Register, Vol. 63, No. 223, November 19, 1998, pp. 64337- 64341, available at https://www.govinfo.gov/content/pkg/FR-1998-11-19/pdf/98-30877.pdf, accessed on February 22, 2023.
[2] Beginning with the addition of Advanced Engineering Research Organization (AERO) and its intermediaries and front companies in September 2014. See: “Addition and Modification of Certain Persons on the Entity List; and Removal of Certain Persons From the Entity List,” U.S. Department of Commerce, Bureau of Industry ad Security, Vol. 79, No. 181, September 18, 2014, p. 55999, available at https://www.govinfo.gov/content/pkg/FR-2014-09-18/pdf/2014-22277.pdf, accessed on February 22, 2023.
[3] “Addition of Entities to the Entity List, and Revision of Entry on the Entity List,” U.S. Commerce Department, Bureau of Industry and Security, Federal Register, Vol. 85, No. 51, March 16, 2020, p. 14795, available at https://www.bis.doc.gov/index.php/documents/regulations-docs/federal-register-notices/federal-register-2020/2541-85-fr-14794/file, accessed on April 20, 2023.
[4] “Addition of Entities to the Entity List, and Revision of Entry on the Entity List,” U.S. Commerce Department, Bureau of Industry and Security, Federal Register, Vol. 85, No. 51, March 16, 2020, p. 14794, available at https://www.bis.doc.gov/index.php/documents/regulations-docs/federal-register-notices/federal-register-2020/2541-85-fr-14794/file, accessed on April 20, 2023.
[5] NESTACC Company Profile, p. 4, available via National Engineering Services Training and Consultancy Company World Wide Web site at https://web.archive.org/web/20200223181212/http://www.nestacc.com/index.html, accessed via archive.org on April 19, 2023; “Pegasus General,” Paktradeinfo World Wide Web site, available at http://paktradeinfo.com/international-trade/Pakistan/Import/1/buyername()-sellername(pegasus-general)-itemdesc()-startdate()-enddate()/100, accessed on April 19, 2023; End User List, November 4, 2022, Japanese Ministry of Economy, Trade, and Industry (METI), pp. 22-24, available at https://www.meti.go.jp/policy/anpo/20221104-3.pdf, accessed on April 20, 2023; “Supplement No. 4 to Part 744 – Entity List,” U.S. Department of Commerce, Bureau of Industry and Security, April 12, 2023, pp. 307-308, 325-326, 330, available at https://www.bis.doc.gov/index.php/documents/regulations-docs/2326-supplement-no-4-to-part-744-entity-list-4/file, accessed on April 20, 2023.
[6] The icons in the network map below are intended to reflect the program (nuclear or missile) that the entity is most closely associated with; entities may contribute to both programs.
[7] Jack Margolin and Irina Bukharin, “Hot Commodities: Exposing Pakistan’s Nuclear Supply Chain,” Blog Post, Center for Advanced Defense Studies (C4ADS), March 16, 2022, available at https://c4ads.org/blogposts/hot-commodities/3/16/2020, accessed on April 20, 2023; “Pegasus General,” Paktradeinfo World Wide Web site, available at http://paktradeinfo.com/international-trade/Pakistan/Import/1/buyername()-sellername(pegasus-general)-itemdesc()-startdate()-enddate()/100, accessed on April 19, 2023.
[8] “Technical Evaluation Report for Mud Logging Equipment,” Tender Enquiry, No.Proc/FE/CB/ML-3202/2018, available via Oil and Gas Development Company World Wide Web site at https://ogdcl.com/sites/default/files/tender-file/TE-320220180329145739813.pdf, accessed on April 19, 2023; Invitation to Bid for Tender Enquiry No. PROC-FC/CB/PROD/NASHPA-3200/2018 and Tender Enquiry No. PROC-FE/CB/ML-3202/2018, available via Oil and Gas Development Company Limited (OGDCL) World Wide Web site at https://ogdcl.com/sites/default/files/tenders/Foreign09Jan201820180109144628727.pdf, accessed on April 19, 2023; “Company Status,” Oil and Gas Development Company Limited (OGDCL) World Wide Web site, available at https://ogdcl.com/company-status, accessed on April 19, 2023.
[9] National Engg. Services Trading & Consultancy, Business Listing, Islamabad Chamber of Commerce and Industry World Wide Web site, available at https://www.icci.pk/listing/national-engg-services-trading-consultancy/, accessed on April 19, 2023; “Final list of voters for the year 2020-21 (CM-Class),” Islamabad Chamber of Commerce & Industry World Wide Web site, available at https://icci.com.pk/provisional-list-of-eligible-voters-for-the-year-2020-21-cm-class.html/page/33/?mode=list, accessed on April 19, 2023.
[10] “Technical Evaluation Report for Mud Logging Equipment,” Tender Enquiry, No.Proc/FE/CB/ML-3202/2018, available via Oil and Gas Development Company World Wide Web site at https://ogdcl.com/sites/default/files/tender-file/TE-320220180329145739813.pdf, accessed on April 19, 2023; Invitation to Bid for Tender Enquiry No. PROC-FC/CB/PROD/NASHPA-3200/2018 and Tender Enquiry No. PROC-FE/CB/ML-3202/2018, available via Oil and Gas Development Company Limited (OGDCL) World Wide Web site at https://ogdcl.com/sites/default/files/tenders/Foreign09Jan201820180109144628727.pdf, accessed on April 19, 2023; “Company Status,” Oil and Gas Development Company Limited (OGDCL) site, available at https://ogdcl.com/company-status, accessed on April 19, 2023.
[11] nestacc.com, WHOIS Lookup, Whoxy World Wide Web site, available at https://www.whoxy.com/nestacc.com, accessed on April 19, 2023; “[email protected],” Epieos Reverse Email Search Tool, Epieos World Wide Web site, available at https://epieos.com/?q=pgtfzcnes%40gmail.com&t=email, accessed on April 19, 2023.
[12] pgtfze.com, WHOIS History, Whoxy World Wide Web site, available at https://www.whoxy.com/pgtfze.com, accessed on April 19, 2023; Pegasus General Trading Business License Details, United Arab Emirates Ministry of Economy, National Economic Register, Inquiry by Business Name, available at https://ner.economy.ae/Search_By_BN.aspx, accessed on June 30, 2022.
[13] Facebook Post by Mobeen Ahmed, Facebook World Wide Web site, October 13, 2015, available at https://www.facebook.com/mobeen.ahmed.7/posts/pfbid0Pk4sV9rnx9svdJY3MsBXCZapbfbS9By6rtyiCbVg3a5nWLHamYrhpdES2VSr9A8al, accessed on April 19, 2023; ”Mobeen Ahmed,” Facebook World Wide Web site, available at https://www.facebook.com/mobeen.ahmed.7, accessed on April 19, 2023.
[14] Pakistan Import Manifests, Pegasus General Trading, available via Descartes Datamyne at https://www.datamyne.com/, accessed on April 19, 2023.
[15] “Addition of Entities to the Entity List, and Revision of Entry on the Entity List,” Bureau of Industry and Security, Department of Commerce, Federal Register, Vol. 85, No. 51, March 16, 2020, p. 14794, available at https://www.govinfo.gov/content/pkg/FR-2020-03-16/pdf/2020-03157.pdf, accessed on April 19, 2023.
[16] triton-ec.com, WHOIS History, Whoxy World Wide Web site, available at https://www.whoxy.com/triton-ec.com, accessed on April 20, 2023.
[17] “Addition of Entities to the Entity List, and Revision of Entry on the Entity List,” Bureau of Industry and Security, Department of Commerce, Federal Register, Vol. 85, No. 51, March 16, 2020, p. 14798, available at https://www.govinfo.gov/content/pkg/FR-2020-03-16/pdf/2020-03157.pdf, accessed on April 20, 2023.
[18] Pakistan Import Manifests, Triton Education Equipment and Consultancy Services, available via Descartes Datamyne at https://www.datamyne.com/, accessed on April 19, 2023.
[19] “Addition of Entities to the Entity List; Corrections to Certain Existing Entries on the Entity List,” Bureau of Industry and Security, Department of Commerce, Federal Register, Vol. 85, No. 184, September 22, 2020, pp. 59419-59420, available at https://www.bis.doc.gov/index.php/documents/regulations-docs/federal-register-notices/federal-register-2020/2628-85-fr-59419/file, accessed on April 20, 2023.
[20] “Affiliated Supply And Consultancy Services – Shipments Report,” available via Panjiva at https://panjiva.com/, accessed on October 22, 2020; Pakistan Import Manifests, Affiliated Supply and Consultancy Services, available via Descartes Datamyne at https://www.datamyne.com/, accessed on April 20, 2023.
[21] Odyssey General Trading Business License Details, United Arab Emirates Ministry of Economy, National Economic Register, Inquiry by Business Name, available at https://ner.economy.ae/Search_By_BN.aspx, accessed on June 30, 2022.
[22] odysseyfzc.com, WHOIS Lookup, Whoxy World Wide Web site, available at https://www.whoxy.com/odysseyfzc.com, accessed on April 19, 2023.
[23] Pegasus General Trading Business License Details, United Arab Emirates Ministry of Economy, National Economic Register, Inquiry by Business Name, available at https://ner.economy.ae/Search_By_BN.aspx, accessed on June 30, 2022.
[24] Odyssey General Trading (FZC), Company Record from Cedar Rose, available via Sayari Graph at https://graph.sayari.com/, accessed on April 19, 2023.
[25] Odyssey General Trading Business License Details, United Arab Emirates Ministry of Economy, National Economic Register, Inquiry by Business Name, available at https://ner.economy.ae/Search_By_BN.aspx, accessed on June 30, 2022.
[26] In 2017, Sadiq listed Pegasus, as well as addresses and contact information associated with Pegasus, in the signature block of a response to an inquiry for a carbon density tester posted on a business-to-business website. See: Query for Activated Bulk Density Tester, June 2, 2017, available at http://www.labulk.com/labulk-0325-activated-carbon-bulk-density-tester/, accessed on April 19, 2023.
[27] Pakistan Import Manifests, Odyssey General Trading, available via Descartes Datamyne at https://www.datamyne.com/, accessed on April 19, 2023.
[28] “Qalb – e-Abbas Mirza,“ LinkedIn World Wide Web site, available at https://www.linkedin.com/in/qalb-e-abbas-mirza-201a80273/, accessed on May 19, 2023; Homepage, Public Procurement Regulatory Authority (PPRA) (Pakistan) World Wide Web site, available at http://ppra.org.pk/, accessed on May 19, 2023; ”PUBLIC PROCUREMENT REGULATORY AUTHORITY (PPRA]
CONTRACT AWARD PROFORMA – I,” Tender No. 704, p. 20, available via Public Procurement Regulatory Authority (PPRA) (Pakistan) World Wide Web site at http://ppra.org.pk/contract/9/5wapda23922.pdf, accessed on May 19, 2023.
[29] Pakistan Import Manifests, Genesis Technical Consultancy Services, available via Descartes Datamyne at https://www.datamyne.com/, accessed on April 19 2023.
[30] National Engg. Services Trading & Consultancy, Business Listing, Islamabad Chamber of Commerce and Industry World Wide Web site, available at https://www.icci.pk/listing/national-engg-services-trading-consultancy/, accessed on April 19, 2023; “Final list of voters for the year 2020-21 (CM-Class),” Islamabad Chamber of Commerce & Industry World Wide Web site, available at https://icci.com.pk/provisional-list-of-eligible-voters-for-the-year-2020-21-cm-class.html/page/33/?mode=list, accessed on April 19, 2023; “Members Directory,” Islamabad Chamber of Commerce and Industry, 2022, p. 116, available at https://icci.com.pk/wp-content/uploads/2022/07/Directory%202022%20Final.pdf, accessed on April 19, 2023.
[31] “Members Directory,” Islamabad Chamber of Commerce and Industry, 2022, p. 116, available at https://icci.com.pk/wp-content/uploads/2022/07/Directory%202022%20Final.pdf, accessed on April 19, 2023; “Addition of Entities to the Entity List, and Revision of Entry on the Entity List,” Bureau of Industry and Security, Department of Commerce, Federal Register, Vol. 85, No. 51, March 16, 2020, p. 14798, available at https://www.govinfo.gov/content/pkg/FR-2020-03-16/pdf/2020-03157.pdf, accessed on April 20, 2023.
[32] Pakistan Import Manifests, Odyssey General Trading, available via Descartes Datamyne at https://www.datamyne.com/, accessed on April 19, 2023.
[33] “Addition of Certain Entities to the Entity List,” U.S. Department of Commerce, Bureau of Industry and Security, Federal Register, Vol. 87, No. 30, February 14, 2022, pp. 8181, 8185, available at https://www.govinfo.gov/content/pkg/FR-2022-02-14/pdf/2022-03029.pdf, accessed on April 20, 2023; “Part 744 – Control Policy: End-User and End-Use Based,” U.S. Department of Commerce, Bureau of Industry and Security, June 2, 2022, pp. 3-4, available at https://www.bis.doc.gov/index.php/documents/regulations-docs/2343-part-744-control-policy-end-user-and-end-use-based-2/file, accessed on April 21, 2023.
[34] Pakistan Import Manifests, Taantu General Trading, available via Descartes Datamyne at https://www.datamyne.com/, accessed on April 20, 2023.
[35] Pakistan Import Manifests, Odyssey General Trading FZC, available via Descartes Datamyne at https://www.datamyne.com/, accessed on April 20, 2023.
[36] Taantu General Trading LLC Business License Details, United Arab Emirates Ministry of Economy, National Economic Register, Inquiry by Business Name, available via https://ner.economy.ae/Search_By_BN.aspx, accessed on September 19, 2022.
[37] taantuae.com, WHOIS Lookup, Whoxy World Wide Web site, available at https://www.whoxy.com/nestacc.com,, accessed on April 20, 2023; Taantu General Trading LLC Business License Details, United Arab Emirates Ministry of Economy, National Economic Register, Inquiry by Business Name, available via https://ner.economy.ae/Search_By_BN.aspx,, accessed on September 19, 2022.
[38] Pakistan Import Manifests, Taantu General Trading, available via Descartes Datamyne at https://www.datamyne.com/, accessed on April 20, 2023.
[39] gentcs.com, Reverse IP Lookup, Viewdns.info World Wide Web site, available at https://viewdns.info/reverseip/?host=gentcs.com&t=1, accessed on April 19, 2023; 203.82.48.218, IP Location Finder, Viewdns.info World Wide Web site, available at https://viewdns.info/iplocation/?ip=203.82.48.218, accessed on April 20, 2023.
[40] Don Pearce, “Red Flag #3 – Grist to the milling machine (Don’t let this happen to you!),” WorldECR, Issue 114, November 2022, p. 31, available at https://www.worldecr.com/archive/red-flag-3-grist-to-the-milling-machine-dont-let-this-happen-to-you/, accessed on April 20, 2023.31, available at https://www.worldecr.com/archive/red-flag-3-grist-to-the-milling-machine-dont-let-this-happen-to-you/, accessed on April 20, 2023.