[Federal Register Volume 80, Number 185 (Thursday, September 24, 2015)]
[Notices]
[Pages 57572-57576]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-24248]


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DEPARTMENT OF COMMERCE

Bureau of Industry and Security


Order Relating to Aiman Ammar, Rashid Albuni, Engineering 
Construction & Contracting Co., Advanced Tech Solutions, and iT Wave 
FZCO

Washington, DC 20230

    In the Matter of: Aiman Ammar, a/k/a Ayman Ammar, with last 
known addresses of: Princess Tower, Apartment 3803, Al Sufouh 
Street, Dubai Marina, Dubai, UAE and 1265 Camden Way, Yuba City, CA 
95991; Rashid Albuni, with last known addresses of: Dubai Silicon 
Oasis, Office # AG 05-2, Dubai, UAE and The Gardens Building 65, 
Apartment 12, Dubai, UAE; Engineering Construction & Contracting 
Co., with last known addresses of: P.O. Box 25858, Damascus, Syria 
and Abu Romana Area, Shahin Building, Ground Floor, Damascus, Syria; 
Advanced Tech Solutions, a/k/a Advanced Technology Solutions, with 
last known addresses of: P.O. Box 25858, Damascus, Syria and Moasa 
Square, Takriti Building, Fourth Floor, Damascus, Syria; iT Wave 
FZCO, a/k/a iT-Wave, a/k/a ITEX-Wave FZCO, with last known addresses 
of: Dubai Silicon Oasis, Office # AG 05-2, Dubai, UAE and The 
Gardens Building 65, Apartment 12, Dubai, UAE, Respondents

14-BIS-0006

    The Bureau of Industry and Security, U.S. Department of Commerce 
(``BIS''), has notified Aiman Ammar a/k/a Ayman Ammar (``Ammar''), of 
Dubai, United Arab Emirates (``U.A.E.''), Rashid Albuni (``Albuni''), 
of Dubai, U.A.E., Engineering Construction & Contracting Co. (``ECC''), 
of Damascus, Syria, Advanced Technology Solutions a/k/a Advanced Tech 
Solutions (``ATS''), of Damascus, Syria, and iT

[[Page 57573]]

Wave FZCO a/k/a iT-Wave a/k/a ITEX-Wave FZCO (``iT-Wave''), of Dubai, 
U.A.E. (collectively, ``Respondents''), that it has initiated an 
administrative proceeding against the Respondents pursuant to Section 
766.3 of the Export Administration Regulations (the 
``Regulations''),\1\ and Section 13(c) of the Export Administration Act 
of 1979, as amended (the ``Act''),\2\ through the issuance of a 
Charging Letter to Respondents that alleges that Respondents violated 
the Regulations. Specifically, the charges are:
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    \1\ The Regulations are currently codified in the Code of 
Federal Regulations at 15 CFR parts 730 through 774 (2015). The 
charged violations occurred in 2010-2013. The Regulations governing 
the violations at issue are found in the 2010-2013 versions of the 
Code of Federal Regulations (15 CFR parts 730 through 774). The 2015 
Regulations set forth the procedures that apply to this matter.
    \2\ 50 U.S.C. app. sections 2401-2420 (2000). Since August 21, 
2001, the Act has been in lapse and the President, through Executive 
Order 13222 of August 17, 2001 (3 CFR, 2001 Comp. 783 (2002)), which 
has been extended by successive Presidential Notices, the most 
recent being that of August 7, 2015 (80 FR 48233 (Aug. 11, 2015)), 
has continued the Regulations in effect under the International 
Emergency Economic Powers Act (50 U.S.C. 1701, et seq.) (2006 & 
Supp. IV 2010).
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As to all Respondents:

Charge 1 15 CFR 764.2(d)--Conspiracy To Export or Reexport to Syria 
Computer Equipment and Software Designed for Use in Monitoring and 
Controlling Web Traffic

    1. Ammar, Albuni, ECC, ATS, and iT-Wave conspired and acted in 
concert with others, known and unknown, to bring about or do an act 
that constitutes a violation of the Regulations. The conspiracy was 
formed by and among Ammar, Albuni, ECC, and ATS in or about October 
2010. iT-Wave joined the conspiracy by no later than in or about 
January 2013, and the conspiracy continued through at least in or about 
March 2013. The purpose of the conspiracy was to bring about exports 
and reexports without the required U.S. Government authorization to 
Syria, including the Syrian Telecommunications Establishment (``STE''), 
of computer equipment and software designed for use in monitoring and 
controlling Web traffic and of other associated equipment. All of these 
items were subject to the Regulations, and nearly all of them were 
classified under Export Control Classification Number (``ECCN'') 5A002 
and controlled for National Security and Anti-Terrorism reasons and as 
Encryption Items.\3\ The items exported or reexported to Syria pursuant 
to the conspiracy were valued in total at approximately $1.8 million.
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    \3\ A limited number of the items were designated as ``EAR99'' 
under the Regulations. EAR99 is a designation for items that are 
subject to the Regulations, but not listed on the Commerce Control 
List.
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    2. The United States has a long-standing and widely-known trade 
embargo against Syria. With the exception of certain medicines and 
food, no item subject to the Regulations may be exported or reexported 
to Syria without a Department of Commerce license, as set forth at all 
times pertinent hereto in General Order No. 2, codified in Supplement 
No. 1 to part 736 of the Regulations.\4\
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    \4\ General Order No. 2 was issued pursuant to the Syria 
Accountability and Lebanese Sovereignty Restoration Act of 2003. On 
December 12, 2011, the controls on exports and reexports to Syria 
were moved to Section 746.9 of the Regulations. The licensing 
requirements continued unchanged. See 76 FR 77115 (Dec. 12, 2011).
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    3. In furtherance of the conspiracy, Ammar and Albuni directed 
activities in and/or from the U.A.E. and Syria in a scheme to export or 
reexport U.S.-origin or U.S.-controlled equipment and software for use 
in Syria and in several instances to fulfill contracts with the state-
run STE. As set forth in further detail below, Albuni negotiated sales, 
submitted purchase orders, and served as the end user contact for 
shipments of controlled items while identifying himself as General 
Manager of ATS, a Syrian company that has been in operations in the 
U.A.E., and as Manager of iT-Wave, which identifies itself as an 
internet computer technology company based in the U.A.E. with 
operations in Syria. Ammar directed payments for the unlawful exports 
and reexports to Syria from personal and business bank accounts, 
including payments from the accounts of ECC, a company based in 
Damascus, Syria. ECC and ATS share the same P.O. Box address in 
Damascus, Syria, and upon information and belief are related companies. 
Ammar also identified himself as the Chief Executive Officer of iT-
Wave.
    4. Both directly and through regional resellers, Ammar, Albuni, 
ECC, ATS, and iT-Wave arranged for the procurement of U.S.-origin or 
U.S.-controlled items for use in Syria. Through various entities, these 
individuals falsely represented, directly and indirectly, to U.S. 
companies or their authorized distributors or resellers that the items 
were intended for end users in such locations as Iraq, Afghanistan, 
Turkey, Egypt and U.A.E, when they actually were intended for Syria, 
primarily STE.

A. Equipment and Software Unlawfully Procured by Respondents in 2010-
2011 for Use in Monitoring and Controlling Web Traffic, including by 
the Syrian Telecommunications Establishment (``STE'')

    5. In or about August 2010, Albuni, holding himself out as General 
Manager of ATS of Damascus, Syria, requested pricing information from a 
regional reseller for products produced by Blue Coat Systems, Inc., of 
Sunnyvale, California (``Blue Coat''). The regional reseller provided 
the order to Computerlinks FZCO, the authorized distributor in the 
Middle East for Blue Coat. On or about October 29, 2010, Computerlinks 
FZCO placed with Blue Coat an order for eight devices used to monitor 
and control web traffic along with accompanying equipment and software. 
In order to evade the Regulations, Albuni concealed the fact that the 
items were destined for Syria, by falsely representing to Blue Coat, 
through Computerlinks FZCO and the regional reseller, that the items 
were intended for the Iraq Ministry of Telecom, and provided his 
personal email address as the end user contact, which also did not 
indicate a Syrian location. Upon receiving the order, Blue Coat 
reexported the items from its facility in the Netherlands to 
Computerlinks FZCO in the U.A.E. On or about December 15, 2010, 
Computerlinks FZCO directed the items' transfer within the U.A.E. for 
their subsequent shipment to ECC in Damascus, Syria, for use by the 
state-run STE. A shipping request notice identified Ammar as the point 
of contact at ECC for the shipment.
    6. On or about December 31, 2010, using the same reseller and 
distributor channel as for the October 29, 2010 order, a second order 
was placed for six of the same Blue Coat devices, again with false 
information being provided indicating that the items were intended for 
the Iraq Ministry of Telecom and listing the end user contact as 
Albuni, when the items were in fact destined for Syria. Upon receiving 
the order, Blue Coat shipped the items from the United States to 
Computerlinks FZCO in the U.A.E. On or about February 9, 2011, 
Computerlinks FZCO directed that three of the six devices be 
transferred within the U.A.E. for their subsequent shipment to ECC in 
Damascus, Syria. In an air waybill dated February 10, 2011, the freight 
forwarder identified Ammar as the point of contact for ECC in Damascus, 
Syria.
    7. To satisfy outstanding bills to Computerlinks FZCO for the items 
for which they falsely stated were for use in

[[Page 57574]]

Iraq, Albuni and Ammar arranged or directed four wire transfers to 
Computerlinks FZCO between February 2, 2011, and May 17, 2011, from 
both Ammar and ECC. Prompted by an email dated April 6, 2011, from an 
intermediary connected with these shipments, Albuni was asked to 
arrange a letter for Ammar to transfer the remaining balance owed to 
Computerlinks FZCO. Ammar had previously made a wire transfer as an 
initial deposit payment to Computerlinks FZCO on February 2, 2011. He 
directed a second payment from ECC on April 13, 2011, and made two 
additional wire transfer payments from an account in his name in 
Damascus, Syria, on May 12 and 17, 2011.
    8. On or about May 15, 2011, using a similar reseller and 
distribution channel, an order was placed for five more devices, along 
with accompanying equipment and software, from Blue Coat, this time 
falsely stating that the items were intended for Liwalnet, an Internet 
service provider in Afghanistan, when in fact the items were again 
destined for Syria. After the items arrived in the U.A.E. from the 
Netherlands, on or about May 26, 2011, Computerlinks FZCO directed its 
freight forwarder to consolidate the remaining three of the six devices 
and software from the December 31, 2010 order, along with the five 
devices and software from the May 15, 2011 order, and transfer the 
ownership of all eight devices and the accompanying equipment within 
the U.A.E. After the transfer of ownership, Albuni, identifying himself 
as General Manager of ATS, directed the subsequent shipment of the 
items to Syria.
    9. Finally, on or about June 5, 2011, an order was placed for three 
additional Blue Coat devices, along with accompanying equipment and 
software, this time falsely stating that the items were destined 
purportedly for Turkey for a company named Turkish Marine Services, 
when the items were in fact destined for Syria. After the items arrived 
in the U.A.E. from the Netherlands, on or about June 27, 2011, 
Computerlinks FZCO directed its freight forwarders to transfer 
ownership of the items within the U.A.E. Albuni in his capacity as 
General Manager of ATS directed the freight forwarder to ship to him at 
ATS, which has the same address as ECC in Syria.
    10. ECC paid for the May and June orders by two wire transfers 
dated, respectively, July 12 and 14, 2011.

B. Additional Equipment Unlawfully Procured by Respondents in 2011 for 
Use by STE

    11. On or about March 24, 2011, Albuni, through his ATS email 
account, notified a different regional reseller that ATS had received 
an STE contract and needed assistance in placing orders for the Brocade 
ServerIron ADX 1000 and related items. These items distribute network 
or application traffic (load balance) across a number of servers to 
increase capacity and reliability of applications for networks and 
large enterprise data centers. On March 27, 2011, an employee of this 
regional reseller responded that he was negotiating about the order 
with Mindware, Brocade's authorized reseller in the Middle East, and 
that he had requested that the reseller ask Brocade to start the 
manufacturing process so that the items could be delivered in six 
weeks. After receiving the regional reseller's invoice, Albuni secured 
payment for the items from Ammar, who, on or about May 10, 2011, 
directed payment to the regional reseller for the order from ECC's bank 
account.
    12. When Brocade, the U.S. manufacturer, requested end user 
information in conjunction with its approval of the order on or about 
April 11, 2011, false information was provided indicating that the end 
user was a company in Egypt, when in fact the items were destined for 
STE in Syria. When the order arrived in the U.A.E. in early May 2011, a 
co-conspirator traveled from Damascus to Dubai to inspect the shipment 
and found the shipment to be acceptable. Emails received by Albuni 
indicate that the shipment was eventually delivered to Syria on or 
about May 17, 2011.

C. Hard Drives Unlawfully Procured by Respondents in 2013 for Use by 
STE

    13. Subsequently, in emails and other correspondence among STE and 
Albuni at ATS and iT-Wave, STE identified hard drive issues relating to 
three products, some of which were items exported or reexported in 
2010-2011 as part of the conspiracy. On or about January 29, 2013, 
Albuni, identifying himself as a representative of iT-Wave, placed 
orders with a U.S. company for three hard drives, falsely stating that 
the items were intended for iT-Wave in Dubai, U.A.E., when in fact the 
items were destined for STE in Syria. On or about January 30, 2013, the 
hard drives were shipped from the United States to the U.A.E. to a ship 
to and bill to address for iT-Wave in Dubai, U.A.E., and transshipped 
to Syria after their arrival in Dubai. Emails indicate that the hard 
drives arrived in Damascus, Syria, in early March 2013.
    14. Following the failure of additional hard drives, STE sought to 
acquire more hard drives through Albuni. On or about March 6, 2013, 
Albuni, holding himself out as a representative of iT-Wave, placed 
another order with the same U.S. company for the same type of hard 
drives, again falsely stating that the items were intended for iT-Wave 
in Dubai, U.A.E., when in fact the items were destined for STE in 
Syria. On or about the same day, the hard drives were shipped from the 
United States to iT-Wave in Dubai and transshipped to Syria after their 
arrival in the U.A.E. Financial records maintained by Ammar, who served 
both as CEO of iT-Wave and Managing Director of ECC, indicate that ECC 
paid for the transport of the hard drives from Dubai to Damascus, 
Syria, for use by STE.

D. Knowledge

    15. As set forth above, Respondents knew at all pertinent times 
hereto that the items were destined for end users in Syria, as 
evidenced by, inter alia, email discussions among and between 
Respondents, the resellers and the forwarders that indicated the final 
destination was Syria, shipping documents showing Syria as the ultimate 
destination, and wire transfer payment made from Syria for the items.
    16. Respondents also knew at all times pertinent hereto that 
exports and reexports of the items to Syria were prohibited by the 
United States' trade embargo against Syria and related export control 
laws. For example, in an interview with BIS and the Department of 
Homeland Security special agents on or about August 6, 2013, Ammar 
admitted that he was ``one hundred percent'' aware of U.S. sanctions on 
Syria and stated that ``[b]efore the sanctions started, I worked for 
this American company . . . and when the sanctions started, they told 
me to Syria we cannot ship.'' During this interview, he had a business 
card that identified him as the managing director of ECC. Based on 
emails, Albuni, in turn, was aware of U.S. sanctions on Syria, which 
prevented U.S. companies from having registered partners in Syria, as 
early as in or about October 2009. Moreover, in correspondence dated 
November 29, 2010, Albuni indicated that he knew that there were 
problems shipping to Syria and suggested placing STE orders through a 
regional reseller, falsely stating that the items were for an Iraq 
project.
    17. As also set forth above, Ammar and Albuni managed and/or 
controlled ECC, ATS, and iT-Wave, through which

[[Page 57575]]

they and their other co-conspirators, named and unnamed, acted in 
concert pursuant to a scheme involving a series of transactions to 
evade the Regulations.
    18. In so doing, Ammar, Albuni, ECC, ATS, and iT-Wave each violated 
Section 764.2(d) of the Regulations.

As to all Respondents except iT-Wave:

Charges 2-5: 15 CFR 764.2(h)--Evasion

    19. As set forth in Paragraphs 1-10 and 15-17, supra, which are 
realleged and incorporated herein, on four occasions from on or about 
October 29, 2010, through in or about July 2011, Albuni, Ammar, ECC, 
and ATS engaged in transactions or took actions with intent to evade 
the Regulations in connection with the unlawful export and reexport to 
Syria of items subject to the Regulations. The items included equipment 
and software designed for use in monitoring and controlling Web traffic 
that are classified under ECCN 5A002, controlled for National Security 
and Anti-Terrorism reasons and as Encryption Items, and valued at 
$1,548,959. Respondents knew at all pertinent times hereto that exports 
and reexports of the items to Syria were prohibited by the Regulations.
    20. In so doing, Ammar, Albuni, ECC, and ATS committed four 
violations of Section 764.2(h) of the Regulations and are jointly and 
severally liable for those violations.

Charge 6: 15 CFR 764.2(h)--Evasion

    21. As set forth in Paragraphs 1-4, 11-12, and 15-17, supra, which 
are realleged and incorporated herein, on one occasion between in or 
about March 2011, and in or about April 2011, Ammar, Albuni, ECC, and 
ATS engaged in a transaction or took actions with the intent to evade 
the Regulations in connection with the unlawful export or reexport to 
Syria of items subject to the Regulations for use by STE. The items 
included data servers and associated parts that are classified under 
ECCN 5A002, controlled as Encryption Items for National Security and 
Anti-Terrorism reasons, or designated EAR99, and valued at 
approximately $249,000. Ammar, Albuni, ECC, and ATS knew at all times 
pertinent hereto that exports or reexports of the items to Syria were 
prohibited by the Regulations.
    22. In so doing, Ammar, Albuni, ECC, and ATS committed one 
violation of Section 764.2(h) of the Regulations and are jointly and 
severally liable for that violation.

As to all Respondents except ATS:

Charges 7-8: 15 CFR 764.2(h)--Evasion

    23. As set forth in Paragraphs 1-4 and 13-17, supra, which are 
realleged and incorporated herein, between in or about January 2013, 
and in or about March 2013, Ammar, Albuni, ECC, and iT-Wave engaged in 
transactions or took actions with the intent to evade the Regulations 
in connection with the unlawful export or reexport to Syria of items 
subject to the Regulations for use by STE. The items were U.S.-origin 
hard drives designated as EAR99 and valued in total at approximately 
$884. Ammar, Albuni, ECC, and iT-Wave knew at all times pertinent 
hereto that exports or reexports of the items to Syria were prohibited 
by the Regulations.
    24. In so doing, Ammar, Albuni, ECC, and iT-Wave committed two 
violations of Section 764.2(h) of the Regulations and are jointly and 
severally liable for those violations.
    WHEREAS, BIS and Respondents have entered into a Settlement 
Agreement pursuant to Section 766.18(b) of the Regulations, whereby 
they agreed to settle this matter in accordance with the terms and 
conditions set forth therein; and
    WHEREAS, I have approved of the terms of such Settlement Agreement; 
IT IS THEREFORE ORDERED:
    FIRST, Respondents shall be assessed a civil penalty in the amount 
of $7,000,000. Respondents are jointly and severally liable for the 
payment of this civil penalty. Payment of $250,000 shall be made to the 
U.S. Department of Commerce in four installments as follows: $62,500 
not later than March 1, 2016; $62,500 not later than September 1, 2016; 
$62,500 not later than March 1, 2017; and $62,500 not later than 
September 1, 2017. Payment shall be made in the manner specified in the 
attached instructions. Payment of the remaining $6,750,000 shall be 
suspended for a period of two years from the date of this Order, and 
thereafter shall be waived, provided that during this two-year payment 
probationary period under this Order, Respondent has committed no 
violation of the Act, or any regulation, order, license or 
authorization issued thereunder and has made full and timely payment of 
$250,000 as set forth above. If any of the four installment payments is 
not fully and timely made, any remaining scheduled installment payments 
and any suspended penalty may become due and owing immediately.
    SECOND, pursuant to the Debt Collection Act of 1982, as amended (31 
U.S.C. 3701-3720E (2000)), the civil penalty owed under this Order 
accrues interest as more fully described in the attached Notice, and if 
payment is not made by the due date specified herein, Respondents will 
be assessed, in addition to the full amount of the civil penalty and 
interest, a penalty charge and an administrative charge, as more fully 
described in the attached Notice.
    THIRD, for the applicable time periods, starting from the date of 
this Order, that are set forth in Paragraph Sixth below, Aiman Ammar a/
k/a Ayman Ammar, with last known addresses of Princess Tower, Apartment 
3803, Al Sufouh Street, Dubai Marina, Dubai, U.A.E., and 1265 Camden 
Way, Yuba City, CA 95991; Rashid Albuni, with last known addresses of 
The Gardens Building 65, Apartment 12, Dubai, U.A.E., and Dubai Silicon 
Oasis, Office #AG 05-2, Dubai, U.A.E.; Engineering Construction & 
Contracting Co., with last known addresses of P.O. Box 25858, Damascus, 
Syria, and Abu Romana Area, Shahin Building, Ground Floor, Damascus, 
Syria; Advanced Tech Solutions a/k/a Advanced Technology Solutions, 
with last known addresses of P.O. Box 25858, Damascus, Syria, and Moasa 
Square, Takriti Building, Fourth Floor, Damascus, Syria; and iT Wave 
FZCO a/k/a iT-Wave a/k/a ITEX-Wave FZCO, with last known addresses of 
Dubai Silicon Oasis, Office #AG 05-2, Dubai, U.A.E., and The Gardens 
Building 65, Apartment 12, Dubai, U.A.E., and when acting for or on 
their behalf, their successors, assigns, directors, officers, 
employees, representatives, or agents (hereinafter each a ``Denied 
Person'' and collectively the ``Denied Persons''), may not, directly or 
indirectly, participate in any way in any transaction involving any 
commodity, software or technology (hereinafter collectively referred to 
as ``item'') exported or to be exported from the United States that is 
subject to the Regulations, or in any other activity subject to the 
Regulations, including, but not limited to:
    A. Applying for, obtaining, or using any license, license 
exception, or export control document;
    B. Carrying on negotiations concerning, or ordering, buying, 
receiving, using, selling, delivering, storing, disposing of, 
forwarding, transporting, financing, or otherwise servicing in any way, 
any transaction involving any item exported or to be exported from the 
United States that is subject to the Regulations, or in any other 
activity subject to the Regulations; or
    C. Benefitting in any way from any transaction involving any item 
exported or to be exported from the United States that is subject to 
the Regulations, or in

[[Page 57576]]

any other activity subject to the Regulations.
    FOURTH, for the applicable time periods, starting from the date of 
this Order, that are set forth in Paragraph Sixth below, no person may, 
directly or indirectly, do any of the following:
    A. Export or reexport to or on behalf of a Denied Person any item 
subject to the Regulations;
    B. Take any action that facilitates the acquisition or attempted 
acquisition by a Denied Person of the ownership, possession, or control 
of any item subject to the Regulations that has been or will be 
exported from the United States, including financing or other support 
activities related to a transaction whereby a Denied Person acquires or 
attempts to acquire such ownership, possession or control;
    C. Take any action to acquire from or to facilitate the acquisition 
or attempted acquisition from a Denied Person of any item subject to 
the Regulations that has been exported from the United States;
    D. Obtain from a Denied Person in the United States any item 
subject to the Regulations with knowledge or reason to know that the 
item will be, or is intended to be, exported from the United States; or
    E. Engage in any transaction to service any item subject to the 
Regulations that has been or will be exported from the United States 
and which is owned, possessed or controlled by a Denied Person, or 
service any item, of whatever origin, that is owned, possessed or 
controlled by a Denied Person if such service involves the use of any 
item subject to the Regulations that has been or will be exported from 
the United States. For purposes of this paragraph, servicing means 
installation, maintenance, repair, modification or testing.
    FIFTH, after notice and opportunity for comment as provided in 
section 766.23 of the Regulations, any person, firm, corporation, or 
business organization related to a Denied Person by affiliation, 
ownership, control, or position of responsibility in the conduct of 
trade or related services may also be made subject to the provisions of 
this Order for the applicable time periods, starting from the date of 
this Order, that are set forth in Paragraph Sixth, below.
    SIXTH, that the provisions of Paragraphs Third, Fourth, and Fifth, 
above, shall apply for the following periods of time:
    A. As to Engineering Construction & Contracting Co., and when 
acting for or on its behalf, its successors, assigns, directors, 
officers, employees, representatives, or agents, for a period of seven 
(7) years from the date of this Order;
    B. As to Advanced Tech Solutions a/k/a Advanced Technology 
Solutions, and when acting for or on its behalf, its successors, 
assigns, directors, officers, employees, representatives, or agents, 
for a period of seven (7) years from the date of this Order;
    C. As to Rashid Albuni, and when acting for or on his behalf, his 
successors, assigns, representatives, agents, or employees, for a 
period of six (6) years from the date of this Order;
    D. As to Aiman Ammar a/k/a Ayman Ammar, and when acting for or on 
his behalf, his successors, assigns, representatives, agents, or 
employees, for a period of five (5) years from the date of this Order; 
and
    E. As to iT Wave FZCO a/k/a iT-Wave a/k/a ITEX-Wave FZCO, and when 
acting for or on its behalf, its successors, assigns, directors, 
officers, employees, representatives, or agents, for a period of four 
(4) years from the date of this Order.
    SEVENTH, Respondents shall not take any action or make or permit to 
be made any public statement, directly or indirectly, denying the 
allegations in the Charging Letter or this Order. The foregoing does 
not affect Respondents' testimonial obligations in any proceeding, nor 
does it affect its right to take legal or factual positions in civil 
litigation or other civil proceedings in which the U.S. Department of 
Commerce is not a party.
    EIGHTH, that the Charging Letter, the Settlement Agreement, and 
this Order shall be made available to the public.
    NINTH, that this Order shall be served on Respondents, and shall be 
published in the Federal Register.
    This Order, which constitutes the final agency action in this 
matter, is effective immediately.\5\
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    \5\ Review and consideration of this matter have been delegated 
to the Deputy Assistant Secretary of Commerce for Export 
Enforcement.

     Issued this 18th day of September, 2015.
Richard R. Majauskas,
Deputy Assistant Secretary of Commerce for Export Enforcement.
[FR Doc. 2015-24248 Filed 9-23-15; 8:45 am]
BILLING CODE P