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Cablegate: Response to Rokg Questions Regarding Delivery Of

VZCZCXRO4782
OO RUEHBC RUEHDE RUEHDIR RUEHKUK
DE RUEHC #3737/01 2740941
ZNR UUUUU ZZH
O 291401Z SEP 08
FM SECSTATE WASHDC
TO RUEHUL/AMEMBASSY SEOUL IMMEDIATE 8729-8730
INFO IRAN COLLECTIVE IMMEDIATE

UNCLAS SECTION 01 OF 02 STATE 103737

SENSITIVE

C O R R E C T E D C O P Y (SENSITIVE CAPTION ADDED)

SIPDIS

E.O. 12958: N/A
TAGS: ECON EFIN KNNP PARM PTER IR KS
SUBJECT: RESPONSE TO ROKG QUESTIONS REGARDING DELIVERY OF
SHIPS TO IRISL

REF: A. A) STATE 90303
B. B) SEOUL 001830
C. C) SEOUL 1746

STATE 00103737 001.2 OF 002


1. (U) This is an action request. Please see paragraph 3.

------------------
SUMMARY/BACKGROUND
------------------

2. (SBU) Washington is providing the nonpaper in paragraph 4
to answer questions from the ROKG that arose in response to
our demarche to Seoul regarding the delivery of ships to the
Islamic Republic of Iran Shipping Lines (IRISL) and the
designation of IRISL under E.O. 13382 for facilitating Iran's
proliferation of weapons of mass destruction (REF A).

-------------------------
OBJECTIVES/ACTION REQUEST
-------------------------

3. (SBU) Washington requests Post draw from paragraph 4 when
engaging host government officials on questions regarding the
implications of the IRISL designation for Korean companies.
Points in paragraph 4 may be left as a nonpaper.

------------------
NONPAPER FOR SEOUL
------------------

4. (U) Q: WHAT ARE THE FULL IMPLICATIONS OF THE U.S.
DESIGNATION?

A: This designation publicizes the proliferation activities
of the Islamic Republic of Iran Shipping Lines (IRISL), with
the objective of disrupting or stopping Iran's ability to
procure and develop weapons of mass destruction or their
means of delivery (including missiles capable of delivering
such weapons). It increases pressure on the Iranian regime
with the goal of persuading Tehran to change course. More
immediately, this action helps the United States protect the
U.S. financial system from abuse by WMD proliferators and
their supporters, by blocking all property and interests in
property of IRISL and the other 18 designated entities that
are in the United States, or that hereafter come within the
United States, or that are or hereafter come within the
possession or control of U.S. persons. Further, no U.S.
person is permitted to engage in business with these 19
entities.

Q: WHEN DOES THE U.S. DESIGNATION TAKE EFFECT AND DOES IT
HAVE RETROACTIVE APPLICATION (E.G., TO PRE-EXISTING
CONTRACTS)?

A: The designation of IRISL and 18 subsidiaries under E.O.
13382 took effect when it was announced by the Department of
the Treasury on September 10, 2008.

Q: HOW DOES THE U.S. VIEW THE ACTIONS OF THIRD-COUNTRY FIRMS
THAT CONTINUE TO DO BUSINESS WITH IRISL?

A: We urge companies to immediately end any association with
IRISL to ensure they are not assisting Iran in its evasion of
UNSC sanctions.

In 2007, IRISL transported a shipment of a precursor chemical
destined for use in Iran's missile program. The end user was
Parchin Chemical Industries, an entity listed in UNSCR 1747
as a subordinate of Iran's Defense Industries Organization,
which was also listed in UNSCR 1737.

Any third-country firms doing business with IRISL could
inadvertently be facilitating IRISL's deceptive shipping
practices, such as the use of generic terms to describe
shipments to avoid the attention of shipping authorities and
the creation and the use of cover entities to conduct
official IRISL business. We urge third-country governments
and firms to heed the lesson learned from the U.S.
investigation of the Mayrow Trading Company and related
entities (http://www.bis.doc.gov/news/2008/doj09172008 .htm):
Iran uses deceptive practices to circumvent national and
international restrictions.


STATE 00103737 002.2 OF 002


Q: WHAT ARE THE RISKS TO KOREAN FIRMS THAT CONTINUE TO DEAL
WITH IRISL IN THE ABSENCE OF A UN-DESIGNATION OF THE FIRM?

A: Korean firms risk designation under E.O. 13382 if they act
or purport to act for or on behalf of, directly or indirectly
IRISL, the listed IRISL subsidiaries, or any other E.O. 13382
designated entity, and/or if they provide, or attempt to
provide, financial, material, technological, or other support
for, or goods or services in support of any designated
entity.

Q: COULD THE U.S. DESIGNATION AFFECT A FIRM OR INDIVIDUAL WHO
MOVED CARGO TO IRAN ON AN IRISL VESSEL?

A: If a firm or individual transports goods that pose a risk
of materially contributing to the proliferation of weapons of
mass destruction or their means of delivery, the firm or
individual could be designated under E.O. 13382. We should
work together to ensure that IRISL does not continue to
circumvent UNSC sanctions. The United States continually
reviews the activities of firms and individuals associated
with IRISL and will ensure that Iran is not allowed to
continue its efforts to transport items related to its
proliferation of sensitive nuclear activities or the
development of nuclear weapon delivery systems.

------------------
REPORTING DEADLINE
------------------

5. (U) Please report delivery of the U.S. non-paper and
any response as soon as possible.
Please slug replies for ISN, T, TREASURY, and NEA/IR.
Please use SIPDIS caption on all responses.

----------------
POINT OF CONTACT
----------------

6. (U) Washington point of contact for follow-up information
is Kevin McGeehan, ISN/CPI, (202) 647-5408,
mcgeehankj@state.sgov.gov or Anthony Ruggiero, ISN/CPI, (202)
647-5181, ruggieroaj@state.sgov.gov.

7. (U) Department thanks Post for its assistance.
RICE

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