Comments on: The Name Game Chinese Style http://www.exportlawblog.com/archives/1150 Latest News on DDTC, BIS, OFAC, and other export law matters Thu, 09 Sep 2010 18:58:42 +0000 hourly 1 http://wordpress.org/?v=3.0 By: Clif Burns http://www.exportlawblog.com/archives/1150/comment-page-1#comment-92290 Clif Burns Fri, 08 Jan 2010 15:58:07 +0000 http://www.exportlawblog.com/?p=1150#comment-92290 @ex-OFAC: You're exactly right about IRISL changing names of the vessels. We blogged on that <a href="http://www.exportlawblog.com/archives/478" rel="nofollow">here</a>. @ex-OFAC: You’re exactly right about IRISL changing names of the vessels. We blogged on that here.

]]> By: ex-OFAC http://www.exportlawblog.com/archives/1150/comment-page-1#comment-92288 ex-OFAC Fri, 08 Jan 2010 14:54:23 +0000 http://www.exportlawblog.com/?p=1150#comment-92288 The Islamic Republic of Iran Shipping Line (IRISL) vessels, which are blocked on the SDN List under the weapons of mass destruction sanctions, change names faster than OFAC can keep up. While the International Maritime Organization's numbers for the vessels seem to remain constant, those numbers are not on funds transfer documents, making the banks' tasks more than formidable. The Islamic Republic of Iran Shipping Line (IRISL) vessels, which are blocked on the SDN List under the weapons of mass destruction sanctions, change names faster than OFAC can keep up. While the International Maritime Organization’s numbers for the vessels seem to remain constant, those numbers are not on funds transfer documents, making the banks’ tasks more than formidable.

]]> By: Tatsuya Kanemitsu http://www.exportlawblog.com/archives/1150/comment-page-1#comment-92279 Tatsuya Kanemitsu Wed, 06 Jan 2010 06:51:29 +0000 http://www.exportlawblog.com/?p=1150#comment-92279 I understand the difficulty of this kind of screening, as I had a similar experience of screening failure when I worked in US computer company. There are some Japanese individuals who are listed on US Denied Persons or Debarred list. The call center happened to receive a call from one of these restricted individuals in Japan and provided verbal technical service. The call center of this US company had the capability to check such restricted entities by using the sophisticated online database, however the name of the caller is always recognized in Kanji (Chinese character). The US government doesn't provide the names of restricted entities in local languages, but provides them only in the Roman alphabet. Japanese names expressed in the Roman alphabet often lead to so many types of Kanji names, so it is really difficult to exactly find the entity with only the name in the Roman alphabet. I understand the difficulty of this kind of screening, as I had a similar experience of screening failure when I worked in US computer company. There are some Japanese individuals who are listed on US Denied Persons or Debarred list. The call center happened to receive a call from one of these restricted individuals in Japan and provided verbal technical service. The call center of this US company had the capability to check such restricted entities by using the sophisticated online database, however the name of the caller is always recognized in Kanji (Chinese character).
The US government doesn’t provide the names of restricted entities in local languages, but provides them only in the Roman alphabet. Japanese names expressed in the Roman alphabet often lead to so many types of Kanji names, so it is really difficult to exactly find the entity with only the name in the Roman alphabet.

]]> By: Clif Burns http://www.exportlawblog.com/archives/1150/comment-page-1#comment-92278 Clif Burns Wed, 06 Jan 2010 05:48:00 +0000 http://www.exportlawblog.com/?p=1150#comment-92278 Yes, it is possible to change names in other countries, including the U.S., but I suspect that, given that China has objected to the US's proliferation designations of Chinese companies, the government may make such ruses easier than in many other countries. Yes, it is possible to change names in other countries, including the U.S., but I suspect that, given that China has objected to the US’s proliferation designations of Chinese companies, the government may make such ruses easier than in many other countries.

]]> By: Su Ross http://www.exportlawblog.com/archives/1150/comment-page-1#comment-92277 Su Ross Wed, 06 Jan 2010 01:46:31 +0000 http://www.exportlawblog.com/?p=1150#comment-92277 Clif, Let's be fair. It isn't just Chinese companies that easily create new entities and change names. This happens frequently in the U.S. as well. Admittedly, this is generally a sign of playing "fast and loose" with the rules, but it does happen here, to, and elsewhere in the world Regards, Su Clif,

Let’s be fair. It isn’t just Chinese companies that easily create new entities and change names. This happens frequently in the U.S. as well. Admittedly, this is generally a sign of playing “fast and loose” with the rules, but it does happen here, to, and elsewhere in the world

Regards,

Su

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