SIA PROPRIETARY NOTE: All speaker comments are off-the- record and not for public release
SIA PROPRIETARY NOTE: All speaker comments are off-the- record and - - PowerPoint PPT Presentation
SIA PROPRIETARY NOTE: All speaker comments are off-the- record and - - PowerPoint PPT Presentation
SIA PROPRIETARY NOTE: All speaker comments are off-the- record and not for public release Export Enforcement Coordination Center E2C2 Strengthening Export Enforcement and U.S. National Security through Inter - Agency Partnerships
Executive Order 13558
- Established from the Export Control Reform
Initiative
- Signed November, 2010
- Created Export Enforcement Coordination
Center – E2C2
- Establishes formal forum for enforcement and
intelligence agencies to coordinate export enforcement actions
- Provides conduit between enforcement and
licensing agencies
- Preserves existing authorities and inter-agency
relationships
Export Enforcement Coordination Center – E2C2 “Strengthening Export Enforcement and U.S. National Security through Inter-Agency Partnerships”
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
Mission
“Export Controls are critical to achieving our national security and foreign policy goals. To enhance our enforcement efforts and minimize enforcement conflicts, executive departments and agencies must coordinate their efforts to detect, prevent, disrupt, investigate and prosecute violations of U.S. export control laws, and must share intelligence and law enforcement information related to these efforts to the maximum extent possible, consistent with national security and applicable law.” – Executive Order 13558 – Export Enforcement Coordination Center (E2C2), November 9, 2010
UNCLASSIFIED//FOUO SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
Organization
UNCLASSIFIED//FOUO SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
Interagency Partners
To serve as the consistent forum within the Federal Government for executive departments and agencies to coordinate and enhance their export control enforcement efforts
UNCLASSIFIED//FOUO SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
- Department of Homeland Security, U.S.
Customs and Border Protection (CBP)
- Department of Justice, Bureau of Alcohol,
Tobacco, Firearms and Explosive (ATF)
- Department of Justice, Federal Bureau of
Investigation (FBI)
- Department of Justice, National Security
Division (NSD)
- Department of State, Directorate of
Defense Trade Controls (DDTC)
- Department of the Treasury, Office of
Foreign Assets Control (OFAC)
- Office of the Director of National
Intelligence, Office of the National Counterintelligence Executive (ODNI)
- U.S. Postal Inspection Service (USPIS)
- NASA IG
- Export Import Bank IG
Mandates
Primary forum for enforcement agencies to de- conflict and coordinate export enforcement actions Primary conduit between Federal law enforcement agencies and the U.S. Intelligence Community for the exchange of information related to potential U.S. export control violations Primary facilitator between enforcement authorities and agencies engaged in export licensing Coordinate law enforcement public outreach activities related to U.S. export controls Report government-wide statistics on export enforcement
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
De-confliction & Coordination
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
Discussion of Joint Investigations Procurement Networks from:
- Russia
Yahor Osin Et Al.
- Iran
Corezing
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
SIA PROPRIETARY NOTE: All speaker comments are
- ff-the-record
and not for public release
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
Corezing Case
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
These Two single leads led to a 9-year Multi-agency, Multi-National coordinated Joint Inter-agency Investigation after Deconfliction
- HSI Los Angeles, Boston
HSI Attache Singapore
- FBI Minneapolis
FBI LEGAT Singapore
- OEE Chicago, Boston
- Singapore National Police
- Indonesian Customs Officials
2007 - Routine lead covered by FBI Minneapolis to interview local manufacturer who sold 6000 radio transceiver modules to Corezing International of Singapore
- 16 of these modules found in Unexploded IEDs in Iraq
- Led to Joint Investigation FBI MP and OEE Chicago
2008 - Industry Source reported to HSI Los Angeles that Corezing (Singapore) attempted to procure ITAR controlled radar modules used in military aircrafts
- Led to identification of additional US based company and
co-conspirator: Co-Conspirator A in Mass. supplied electronic components to Corezing
- Investigation led to identification of a second US based Co-Conspirator B
employed by a 2nd company located in Mass. who attempted to sell ITAR controlled microwave antennas to Co-Conspirator A ultimately destined for Corezing (Singapore)
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
Corezing
Offices in Singapore
Iranian Front Co. Based in Singapore
NEL Electronics Opto Electronics
- False End User Statements
- Transshipped through:
Malaysia Thailand Hong Kong
Iranian Based Companies
IC Market Iran Paya Electronics Complex
IED(s) Iraq US Based Manufactures
Unwitting Minn based Manufacturer Radio Transceiver Modules Corezing made:
- False End User Statements
- Misrepresentation on end use
- Modules claim to be for Singapore
Telecommunication project Co-conspirators US
- Co-Conspirator A
Radar Modules Employee 2nd Mass Co. Co-Conspirator B
- Microwave Antennas
Failure to obtain export license DDTC Bypass export license after denied by Export Compliance Officer SIA PROPRIETARY NOTE: All speaker comments are
- ff-the-record
and not for public release
Investigative Results
- 9 Persons Indicted
- 4 Singapore Nationals
- 3 Singapore Companies
- 2 Iranian Nationals
- 2 Iranian Companies
- 4 Arrested
- 4 Convictions
- 3 Extraditions
- 2 Outstanding Fugitives
- 15 Persons places on Department of Commerce Entity List from
China, Hong Kong, Iran, Singapore
- First U.S. Prosecution Where Specific U.S. Goods traced to IEDs
located in Battlefields in Iraq
- First Extradition of Singapore subject from Indonesia after arrest
by Indonesian Customs Officials
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
VIOLATIONS CHARGED
- 18 USC 371 Conspiracy
- 18 USC 554 Smuggling
- 18 USC 1001 False Statements
- 18 USC 1512 Obstruction/Tampering
- 22 USC 2778 AECA
- 30 CFR Part 560 Iranian Transactions Regulations
- 50 USC 1705 IEEPA
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
Overview
- Minneapolis Manufacturer provided invaluable
assistance.
- Assisted Law Enforcement in tracing serial
numbers to shipments sold to Corezing found in IEDs in Iraq
- Received Intelligence Community Seal Medallion
from Director of National Intelligence and CIA Director
- Two leads from Industry initiated Multi-Agency
Investigation
- Intelligence obtained highlighted major procurement
network funneling millions dollars worth of technology equipment to Iran
- Disruption and Dismantlement of Network
- Whole of Government approach with Industry
assistance to maximize enforcement of Export Violations
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
E2C2 Principals
Patrick McElwain
E2C2 Director Patrick.McElwain@ice.dhs.gov (703) 287-6870
Greg Concepcion
FBI Liaison E2C2 Deputy Director for Operations Greg.Concepcion@ice.dhs.gov Greg.Concepcion@ic.fbi.gov (703) 287-6809
Patrick McElwain
E2C2 Director Patrick.McElwain@ice.dhs.gov (703) 287-6870
Greg Concepcion
FBI Liaison E2C2 Deputy Director for Operations Greg.Concepcion@ice.dhs.gov Greg.Concepcion@ic.fbi.gov (703) 287-6809
Todd Willis
- Dept. of Commerce Liaison
E2C2 Deputy Director for Programs Todd.Willis@ice.dhs.gov Todd.Willis@doc.bis.gov (703) 287-6808
Todd Willis
- Dept. of Commerce Liaison
E2C2 Deputy Director for Programs Todd.Willis@ice.dhs.gov Todd.Willis@doc.bis.gov (703) 287-6808
E2C2-outreach@ice.dhs.gov
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
Question s
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
E2C2 Presentation and Law Enforcement Panel
- E2C2 Overview/Case Discussion
- Panel Member Agency
Introductions/Interagency Collaboration “Made in America: Defending Our Technology”
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
SPEAKER BIOGRAPHIES
Special Agent in Charge (SAC) Richard Weir – Richard “Rick” Weir is the Special Agent in
Charge (SAC) of The Department of Commerce’s, Bureau of Industry and Security, Office of Export Enforcement, Los Angeles Office. In that role, he is responsible for the protection and promotion of U.S. national security and foreign policy objectives in his assigned area of responsibility. He supervises a highly specialized law enforcement office that is focused on deterring the proliferation of Weapons of Mass Destruction, missile delivery systems, and the diversion of dual-use goods to unauthorized military end-uses, terrorists and state sponsors of terror. The Los Angeles Office is responsible for investigating violations in Southern California, Arizona, New Mexico, Southern Nevada, and Hawaii. SAC Weir joined the Office of Export Enforcement in 2001 and has served previously as the Assistant Special Agent in Charge and as a Field Agent in Los Angeles. Prior to coming to OEE he was a U.S. Customs Inspector in the Port of Long Beach/Los Angeles where he spent all four years on the Outbound Enforcement Team. Rick’s 28 years of federal service include 10 years in the U.S. Navy serving in Operations and Law Enforcement. Rick also served as a member of the California Army National Guard where he served in a Military Intelligence Battalion.
Greg Concepcion was selected as the FBI Senior Detailee to the Export Enforcement Coordination
Center (E2C2) in April 2016 and serves as the E2C2 Deputy Director of Operations. On November 9, 2010, as part of the President’s Export Control Reform Initiative, President Obama signed Executive Order 13558 establishing E2C2 within DHS. The E2C2 serves as the primary focus for 22 law enforcement agencies to coordinate and enhance export investigations and serves as a conduit to the Intelligence Community and regulatory licensing agencies. Mr. Concepcion’s previous assignment was as a Supervisory Special Agent within the New York Field Office’s Counterintelligence Division. Mr. Concepcion entered on duty with the FBI in 1997 at the FBI Los Angeles Field Office. Followinggraduation from the FBI Academy in 2001, he reported to the San Francisco Field Office and was assigned to Criminal and Counterintelligence squads. He subsequently served as a Supervisory Special Agent in the Counterintelligence Division’s Espionage Section at FBI Headquarters in Washington, DC where he oversaw managed a multitude of sensitive espionage investigations throughout the U.S. He is also a certified Special Weaponsand Tactics (SWAT) operator. Mr. Concepcion holds a Bachelor of Science in Criminal Justice and a Bachelor of Arts in Psychology from the California State University of Long Beach.
Joseph Skidmore is a Homeland Security Investigations (HSI) Special Agent who is currently serving as
a Program Manager assigned to the EXODUS Command Center and the Export Enforcement Coordination Center (E2C2). The Exodus Command Center is the single point of contact for HSI Special Agents and U.S. Customs and Border Protection (CBP) officers to obtain operational case support from national export licensing authorities and case suppose for the de confliction of investigative targets. The E2C2 is a focal point for law enforcement agencies to coordinate and enhance export investigations, serve as a conduit to the Intelligence Community and licensing agencies, coordinate national outreach efforts, and establish integrated government- wide statistical tracking and targeting capabilities to support export enforcement. He also serves as the HSI liaison to the Department of State. For the past 14 years, Agent Skidmore has been investigating persons whom attempt to acquire and illegally export some of the United States’ most critical military technology. Many
- f these cases involve coordination with other HSI offices, federal agencies, foreign law enforcement and
contributions from industry partners. Agent Skidmore monitors and coordinates investigative efforts of the field and around the globe in an effort to prevent illicit procurement networks, terrorist groups and hostile nations from illegally obtaining United States military products, sensitive dual-use technology, weapons of mass destruction, or chemical, biological, radiological and nuclear materials. Agent Skidmore began his law enforcement career in 1999 with the U.S. Border Patrol assigned to the Nogales, AZ office. In 2003, Agent Skidmore was hired by the U.S. Customs Service and stationed in Fort Lauderdale, FL. He is currently assigned to the National Security Investigations Division, Counter Proliferation Investigations at HSI Headquarters.
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
SPEAKER BIOGRAPHIES Continued
Robert Rawls graduated from the University of Southern Mississippi in 1979 with a B.S. degree in
Industrial Management. Robert began his federal career in September 1982 with the Social Security Administration as a Benefits Authorizer at the Program Service Center in Birmingham, AL. In 1987, Robert began as a Customs inspector with the U.S. Customs Service in Pascagoula, MS. In 1991, Robert was promoted to Senior Customs Inspector at the Port of Huntsville, AL. He worked with state, local and other federal agencies conducting investigations. In 1999, Robert began working as a Program Officer in the Outbound Programs at U.S. Customs Service Headquarters. He was responsible for the Currency program and budget. In 2000, Robert took over all Exodus related issues, Foreign Military Sales, OFAC Sanctions and Embargoes, Liaison to Other Government agencies, DEA, DOD, and ATF, Exodus Training at the Federal Law Enforcement Training Center, Exodus Handbooks, GAO/OIG Audits updates, the Accountability Reports, the Strategic Plan, and overall program management of the Automated Export System. In 2004 Robert transferred to the Office of International Affairs to work with the World Bank and the Department of State on improving the customs processing procedures in Southeast Europe. He has also worked on the Western Hemisphere Travel Initiative,
- verseeing the development and implementation of the Air rule, and he worked in Preclearance
Operations until January 2009. In 2009 Robert returned to the Outbound Enforcement Division as the Outbound Enforcement and Policies Branch Chief to work on re-establishing outbound enforcement for CBP, working on the President’s Export Control Reform Initiative, the National Export Initiative, the development of a pre-departure electronic export manifest, and the development of the Foreign Military Sales program.
Traditional Red Flag Indicators
Below are common RED FLAG indicators of a buyer who may not be authorized to receive yourproducts or is potentially engaged in other criminal activity. If RED FLAGS are present, you shouldexercise due diligence and inquire about the suspicious circumstances to ensure appropriate end-use, end-user, and ultimate country of destination information is obtained.
- Buyer is reluctant to offer information about the end-use of the ordered product
- Product’s capabilities do not fit the buyer’s line of business
- Buyer’s IP address does not match the stated location
- Company receives the same request for a quote (RFQ) from multiple customers
- The RFQ appears to be cut-and-pasted into the email
- Buyer carbon copies unknown individuals
- Buyer is unfamiliar with the product’s performance
- Buyer is evasive when asked about whether parts are for domestic use or re-export listed as
thefinal end-user
- Routine installation, training, warranty, or maintenance services are declined by the buyer
- Buyer has little to no presence on the internet
- The shipping address is a residence or a building that leases virtual office space
- Unusual method of payment or unexpected source of payment.
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
May 2, 2017 8:45am-10:15am
- Defending our Technology
Federal Bureau of Investigation Counterproliferation Center Film
- Hosted by
SIA PROPRIETARY NOTE: All speaker comments are off-the- record and not for public release
“Strengthening Export Enforcement and U.S. National Security through Inter-Agency Partnerships”
Export Enforcement Coordination Center
Participants:
- Department of Homeland Security, Immigration
and Customs Enforcement, Homeland Security Investigations (HSI)
- Department of Homeland Security, U.S. Customs
and Border Protection (CBP)
- Department of Commerce, Office of Export
Enforcement (OEE)
- Department of Justice, Federal Bureau of
Investigation (FBI)
- Department of Justice, National Security Division
(DOJ/NSD)
- Department of Defense, Defense Criminal
Investigative Service (DCIS)
- Director of National Intelligence, Office of the
National Counterintelligence Executive (ODNI)
- Department of Energy, (DOE)
- Department of State, Directorate of Defense
Trade Controls (DDTC)
- Department of the Treasury, Office of Foreign
Assets Control (OFAC)
- Department of Justice, Bureau of Alcohol,
Tobacco, Firearms and Explosives (ATF)
- Department of Defense, Air Force Office of
Special Investigations (OSI)
- Department of Defense, Defense
Counterintelligence and Human Intelligence Center, Defense Intelligence Agency (DIA)
- Department of Defense, Defense Security Service
(DSS)
- Department of Defense, Naval Criminal
Investigative Service (NCIS)
- Department of Defense, Office of Naval
Intelligence (ONI)
- U.S. Postal Inspection Service (USPIS)
For additional information contact the E2C2 at (703) 287-6811
E2C2
“[It is] critically important …to have a vigorous, comprehensive export-control system that prevents adversaries from getting access to technology or equipment that could be used against us. ……the coordination of our currently dispersed enforcement resources by one agency will do a great deal to strengthen enforcement, particularly abroad, as well as coordination with the intelligence
- community. Those who endanger our
troops and compromise our national security will not be able to hide behind jurisdictional uncertainties or game the
- system. Violators will be subject to
thorough investigation, prosecution, and punishment severe enough to deter law breaking.”
- Secretary Of Defense Robert M. Gates,
April 20, 2010
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
E2C2 Mission:
- In November 2010 as part of the Export Control
Reform Initiative, President Obama issued Executive Order 13558 creating the Export Enforcement Coordination Center (E2C2);
- Established to coordinate and enhance criminal,
administrative, and related export enforcement activities thereby protecting national security through greater export enforcement and intelligence exchange.
- The E2C2 is a multi-agency center, officially
- perational in March 2012, with representation
from eight U.S. governmental departments and fifteen federal agencies (see Participants).
- The E2C2 is the designated focal point for the
coordination and enhancement
- f
U.S. Government export enforcement efforts;
- It serves as a conduit between Federal law
enforcement agencies and the intelligence community;
- It is the primary point of contact between
enforcement authorities and agencies engaged in export licensing, coordinating law enforcement public
- utreach
activities, and establishing government-wide statistical tracking capabilities for U.S. criminal and administrative export enforcement activities.
- The E2C2 promotes a more robust whole-of-
government approach to enforcement by ensuring inter-agency coordination, promoting multi-agency collaboration, minimizing duplication of efforts and strengthening the critical link between law enforcement, the intelligence community and export licensing entities.
- The E2C2 is housed and administered by the
Department of Homeland Security with an inter- agency management team consisting of:
- The Director, who is a full-time senior officer of
the Department
- f
Homeland Security, Immigration and Customs Enforcement, Homeland Security Investigations; and
- Two Deputy Directors: one from the Department
- f Commerce, Office of Export Enforcement, and
- ne from the Department of Justice, Federal
Bureau of Investigation.
- The E2C2 also has a Senior Intelligence
Community (IC) Liaison designated by the Office
- f the Director of National Intelligence.
E2C2 Functions:
- Serves as the primary forum for governmental
departments and agencies to coordinate and enhance their export enforcement efforts and to identify and resolve conflicts in criminal and administrative investigations and actions involving violations of U.S. export control laws;
- Serves as a de-confliction center for export
enforcement and intelligence activities;
- Has access, through the participating agencies, to
relevant data and information to enhance export enforcement efforts and minimize potential for conflict;
- Serves as a conduit between the U.S. Intelligence
Community, the Information Triage Unit, and Federal export enforcement agencies for the exchange of information related to potential U.S. export control violations;
- Serves as a primary point of contact between
export enforcement agencies and agencies engaged in export licensing;
- Coordinates law enforcement public outreach
activities related to U.S. export controls;
- Establishes government wide statistical tracking
capabilities for U.S. criminal and for administrative export control enforcement activities with information provided by and shared with all relevant departments and agencies participating in the E2C2; and
- Convenes
and coordinates sub-groups
- f
participating agency members within the E2C2 on matters related to export enforcement to enhance intelligence exchange in order to provide more coordinated enforcement of U.S. export control laws.
“Export controls are critical to achieving our national security and foreign policy goals. To enhance our enforcement efforts and minimize enforcement conflicts, executive departments and agencies must coordinate their efforts to detect, prevent, disrupt, investigate and prosecute violations of U.S. export control laws, and must share intelligence and law enforcement information related to these efforts to the maximum extent possible, consistent with national security and applicable law.”
- Executive Order 13558 – Export
Enforcement Coordination Center, November 9, 2010
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release
Export Enforcement Coordination Center - E2C2
"Export controls are critical to achieving our national security and
foreign policy goals. To enhance
- ur enforcement
efforts and minimize enforcement conflicts, executive departments and agencies must
coordinate their efforts to detect, prevent, disrupt, investigate and prosecute violations of U.S. export control laws, and must share intelligence and law enforcement information related to these efforts to the maximum extent possible, consistent with national security and applicable law."
- Executive Order 13558 - Export Enforcement Coordination Center, November 9, 2010
In November 2010, as part of the Administration's
Export Control Reform Initiative, President
Obama issued Executive Order 13558 creating the Export Enforcement Coordination
Center (E2C2). The mission of the E2C2 is to coordinate and enhance criminal, administrative,
and related export enforcement activities thereby protecting national security through greater export enforcement and intelligence exchange.
Officially operational
in March 2012, the E2C2 is a multi-agency center with representation from eight U.S. governmental departments and fifteen federal agencies from the Departments of
Homeland Security, Commerce, Defense, Energy, Justice, State, Treasury, and the Office of the
Director of National Intelligence. The E2C2 is the designated focal point for the coordination and enhancement of U.S. Government export enforcement efforts. It serves as a conduit between Federal law enforcement agencies and
the intelligence community, as well as the primary point of contact between enforcement
authorities and agencies engaged in export licensing, coordinate law enforcement public outreach activities, and establish government-wide statistical tracking capabilities for U.S. criminal and administrative export enforcement activities. The E2C2 promotes a more robust whole-of-government approach to enforcement by ensuring inter-agency coordination, promoting multi-agency collaboration, minimizing duplication of efforts and strengthening the critical link between law enforcement, the intelligence community and export licensing entities. The E2C2 is housed and administered by the Department
- f Homeland
Security with an inter-
agency management team consisting of the Director, who is a full-time senior officer of the Department of Homeland Security, Immigration and Customs Enforcement,
Homeland Security
Investigations, and two Deputy Directors: one from the Department of Commerce, Office of Export Enforcement, and one from the Department of Justice, Federal Bureau of Investigation. The E2C2
also has a Senior Intelligence Community (IC) Liaison designated by the Office of the Director of National Intelligence. For additional information contact the E2C2 at e2c2-outreach@ice.dhs.~ov
- r (703) 287-6811
E2C2 - Strengthening Export Enforcement and U.S. National Security
Through Inter-Agency Partnerships
SIA PROPRIETARY NOTE: All speaker comments are off-the-record and not for public release