Viewing cable 09STATE92948
Title: BLUE LANTERN: VERIFYING BONA FIDES OF REGISTERED

IdentifierCreatedReleasedClassificationOrigin
09STATE929482009-09-08 13:51:00 2011-08-30 01:44:00 UNCLASSIFIED Secretary of State
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UNCLAS STATE 092948 
 
SIPDIS 
VILNIUS FOR REBECCA DUNHAM 
POL-MIL 
 
E.O. 12958: N/A 
TAGS: ETTC KOMC LH
SUBJECT: BLUE LANTERN: VERIFYING BONA FIDES OF REGISTERED 
BROKER AMDZELIKA SKUZINSKIENE - CASE NO. K-2499 
 
REF: A. SECTION 38(B)(1)(A)(II) OF THE ARMS 
     ¶B. EXPORT CONTROL ACT (AECA)(22 U.S.C. 2778) 
 
¶1. This is an Action Request.  See paragraphs 3-4. 
 
¶2. U.S. embassies have frequently inquired about the 
legitimacy of arms export transactions involving U.S. 
contractors and host-country partners in support of 
U.S. efforts in Iraq and Afghanistan, or other U.S. 
government programs. The Department's Office of 
Defense Trade Controls Compliance (PM/DTCC) wishes 
to inform Post that U.S. or foreign persons who are 
involved in brokering U.S. defense articles or 
services, or any defense articles or services pursuant 
to U.S. procurement contracts for Iraq and Afghanistan 
or other destinations under USG auspices, must be 
registered with PM/DTCC and obtain Department's 
approval for their brokering activities. 
 
¶3. ACTION:  PM/DTCC requests Post's assistance in 
conducting an inquiry into the brokering activities 
of the U.S. registered broker listed below to 
substantiate its bona fides. Department requests 
that Post conduct a site visit to the company in 
order to assess its business operations, on-site 
security, and reliability as a broker/recipient of 
United States Munitions List (USML) items. If a 
site visit is not possible, please inform the 
PM/DTCC case officer. Post is requested to 
complete this inquiry within 60 days: 
 
AMDZELIKA SKUZINSKIENE, DIRECTOR 
DEFENSA UAB (LLC) 
¶L. ST. GUCEVICIAUS 9-2, LT-01122 
VILNIUS, LITHUANIA 
TEL: 37052655555 
 
¶4. The following points are provided for guidance: 
 
-- Confirm that this entity is in the business of 
brokering defense articles and defense services at 
the location(s) indicated under its legal name(s); 
 
-- Determine whether this entity is authorized to 
conduct such activities in its home country, whether 
the entity has any criminal or other derogatory 
background, and whether Post has any information on 
its brokering or arms export activities that may 
involve proscribed entities such as countries 
under U.S. or international sanctions, or designated 
state sponsors of terrorism; 
 
-- Will the brokering firm be handling or storing 
USML items on behalf of its clients?  If so, does it 
have secure facilities and proper accounting and 
security procedures for handling sensitive USML 
items? 
 
-- When was the company established and who are its 
principals?  How many employees? 
 
-- What is the nature of its business and what other 
types of items does it handle? 
 
-- What types of organizations are among its typical 
clients and in what countries are they located? 
 
-- Does the company understand the restrictions on 
USML items, especially the prohibition against 
unauthorized re-transfers and re-exports? 
 
 
END ACTION. 
 
--------------------------------------------- --------- 
BACKGROUND ON BROKERING REGISTRATION AND AUTHORIZATION 
--------------------------------------------- --------- 
 
¶5. PM/DTCC provides the following background 
information on the requirements for registration and 
obtaining prior approvals for brokering activities: 
 
The requirements for Registration and Obtaining Prior 
Approvals or Brokering Activities are based in the Arms 
Export Control Act (AECA). The Brokering Requirements 
are administered by PM/DTCC. 
 
Section 38(b)(1)(A)(II) of the AECA requires 
registration for any person "who engages in the business 
of brokering activities with respect to the manufacture, 
export, import, or transfer of any defense article or 
defense service". 
 
According to the International Traffic in Arms 
Regulations (ITAR) Section 129.2(a), a broker is 
defined as: 
 
"any agent for others in negotiating or arranging 
contracts, purchases, sales or transfers of defense 
articles or defense services in return for a fee, 
commission, or other consideration." 
 
Additionally, ITAR Section 129.2(b) states that 
"brokering activities means acting as a broker as defined 
(above), and includes financing, transportation, freight 
forwarding, or taking of any other action that facilitates 
the manufacture, export or import of a defense article or 
defense service, irrespective of its origin." 
 
Authorization is typically required for brokering activity. 
However, some activities are exempt from these requirements 
depending on the commodity, the countries involved, and the 
existence of previous authorization.  Any questions about 
specific cases may be directed to this Office to the 
attention of Deborah Carroll, Chief, Compliance & 
Registration. Phone: 202-663-2809; 
SIPRNET: carrolld@state.sgov.gov. 
 
End background on brokering registration and authorization. 
 
¶6. Please slug reply for PM/DTCC and include the words 
"Blue Lantern Broker Inquiry" and the case number in 
the Subject line.  POC is Rachael-Therese S. Joubert-Lin, 
Phone: 202-663-2950; Email:JoubertLinRS@state.gov; 
SIPRNET: JoubertLinRS@state.sgov.gov. The Blue Lantern 
Guidebook is available as a PDF file at http://www. 
intelink.sgov.gov/wiki/Blue Lantern End-Use Monitoring 
Program. 
 
¶7. Department is grateful for Post's assistance in this 
matter. 
CLINTON