Major Export Enforcement Cases - Directorate of Defense Trade ...

ocket launchers. CPMIEC has been sanctioned by the Treasury Department as a specially
designated Weapons of Mass Destruction proliferator, based, in part, on CPMIEC’s history of
selling military hardware to Iran. The investigation was conducted by BIS and ICE.
Carbon-Fiber Material with Rocket & Spacecraft Applications to China – On Oct. 8, 2009,
three individuals were sentenced in the District of Minnesota for illegally exporting highmodulus,
carbon fiber material to the China Academy of Space Technology. Jian Wei Ding was
sentenced to 46 months in prison. Kok Tong Lim was sentenced to just over one year of
confinement because of his cooperation in the case, while Ping Cheng was sentenced to one year
probation due to his cooperation. On March 20, 2009, Ding pleaded guilty to one count of
conspiracy to violate the Export Administration Regulations. Cheng entered his plea on Feb. 13,
2009 and Lim entered his plea on March 9, 2009. All three men were indicted on Oct. 28, 2008
for conspiring to illegally export to China controlled carbon-fiber material with applications in
aircraft, rockets, spacecraft, and uranium enrichment process. The intended destination for some
of the materials was the China Academy of Space Technology, which oversees research institutes
working on spacecraft systems for the PRC government. For national security, nuclear
proliferation and antiterrorism reasons, the U.S. government requires a license to export these
carbon-fiber materials. Jian Wei Ding was a resident of Singapore and owned or was a affiliated
with various Singaporean import/export companies, including Jowa Globaltech Pte Ltd,
FirmSpace Pte Ltd, and Far Eastron Co. Pte Ltd. Kok Tong Lim was a resident of Singapore and
once was affiliated with FirmSpace, Pte Ltd. Ping Cheng was a resident of New York and the sole
shareholder of Prime Technology Corporation. This investigation was conducted by ICE and BIS.
Sensitive Aircraft Components to Iran – On Sept. 24, 2009, Aviation Services International
(ASI), a Netherlands-based aviation services company, its owner, Robert Kraaipoel, and his son
Robert Neils Kraaipoel, pleaded guilty in the District of Columbia to a one-count criminal
information alleging conspiracy to violate the International Emergency Economic Powers Act
(IEEPA) and the Iranian Transactions Regulations. From about October 2005 to about October
2007, the defendants received orders from customers in Iran for U.S.-origin goods, including
various aircraft components that were restricted from being transshipped into Iran. The
defendants then contacted companies in the United States and negotiated purchases of materials
on behalf of Iranian customers. The defendants provided false end-user certificates to certain U.S.
companies to conceal that customers in Iran would be the true recipients of the goods. The goods
were routed to Iran through the Netherlands, the United Arab Emirates, and Cyprus. In 2006
alone, Aviation Services obtained some 290 aircraft-related components from the U.S. and caused
them to be shipped to Iran. Many of these U.S.-origin goods were sent to Iranian government
agencies, Iranian procurement agencies or companies doing business in Iran. ASI agreed to pay a
$100,000 fine and corporate probation for five years. On June 12, 2012, the Kraaipoels were
sentenced to probation as a result of their cooperation in a number of investigations. The
investigation was conducted by BIS, ICE, DCIS and FBI.
Sighting Devices to Afghanistan and Taiwan – On Sept. 18, 2009, Aaron Henderson, doing
business as Vahalla Tactical Supply, pleaded guilty in the Southern District of Iowa to a criminal
information, arising from his illegal export of restricted sighting devices to Taiwan and
Afghanistan without the required export licenses. Henderson was sentenced to time served and
two years-supervised release. The investigation was conducted by BIS, ICE and the Bureau of
Alcohol, Tobacco, Firearms and Explosives.
Restricted Integrated Circuits with Military Applications to China – On Aug. 3, 2009, William
Chai-Wai Tsu, an employee of a Beijing-based military contracting company called Dimigit
62