September 5, 2018

70 Pakistani Entities on US Entity List Now


US Bureau of Industry and Security (BIS) has sanctioned another two (2) Pakistani companies to the Entity List – snowballing the country’s entities’ tally to seventy (70), which are now enlisted in the ‘Rule’.

Trump Administration believes that the companies solicited in the Entity List are involved or to pose a significant risk of being involved in activities contrary to the national security or foreign policy interests of the United States.

The End-User Review Committee (ERC) added Technology Links (Pvt.) Ltd. including Techlinks and Techlink Communications to the Entity List based on its involvement in supplying items to nuclear and missile-related entities in Pakistan without license.

It further determined that UEC (Pvt.) Ltd. including Techcare Services FZ LLC made several attempts to acquire US-origin commodities for Pakistan’s nuclear program and have provided false and misleading information to BIS during an end-use check.

These companies will be subject to additional license requirements as well as limitations on license exceptions. The license requirements will be applied to any transaction relating to exports, reexports, or transfers (in-country).

Earlier in March 2018, the department had also added seven (7) companies to the Entity List under the destination from Pakistan.

The companies – Mushko Electronics, Solutions Engineering, Akhtar & Munir, Proficient Engineers, Pervaiz Commercial Trading Co. (PCTC), Marine Systems Ltd., and Engineering and Commercial Services (ECS) – were alleged to procure items on behalf of nuclear-related entities in Pakistan without the required licenses.

The recent burst of US ruses are being prophesied in the backdrop of the its rising frustration in Afghanistan after its ally Afghan government has consistently lost control on Afghan territory and population despite US spending of $687 billion through 2017.

Pakistan foreign office spokesperson had cautioned the United States for ‘unnecessarily politicizing the issue’ and rebuffed attempts of detraction ‘to exploit these listings to cast aspersions on Pakistan’s non-proliferation credentials’.

The press release further stated that ‘Pakistan’s efforts in the area of export controls and non-proliferation as well as nuclear safety and security are well known’.

Here is the complete index of the Entity List which includes seventy (70) companies – excluding two (2) recently added – under the destination from Pakistan, according to US Electronic Code of Regulations (e-CFR) as of August 31, 2018:


1. Abdul Qadir Khan Research Laboratories (AQKRL) and its affiliates;

2. Abdul Sattar Ghoura;

3. Advanced Engineering Research Organization (AERO) – Integrated Solutions;

4. Ahad International;

5. Air Weapons Complex (AWC);

6. Akhtar & Munir;

7. Al-Technique Corporation of Pakistan (ATCOP);

8. Allied Trading Co. – UCB Arcade;

9. ANZ Importers and Exporters;

10. Azad Motors Property Choice and its affiliates;

11. Azam Electronics and its affiliates;

12. Creative Dynamics Engineering – Creative Dynamics;

13. Defense Science and Technology Organization (DEFTO) and its affiliates;

14. Engineering and Commercial Services (ECS);

15. Engineering Solutions Pvt. Ltd.;

16. FACO Trading;

17. Farzad Fazal Karim – Ahmad Farzad;

18. Fazal Rahim Farid and three aliases;

19. Future Systems Pvt. Ltd.;

20. Hakim Noor – Hakim Nur;

21. HakimNur Sarafa and two aliases;

22. High Technologies Ltd. (HTL) – High Technology Ltd.;

23. IKAN Engineering Services – IKAN Sourcing

24. Iman Group – Pana Communication Inc.;

25. Interscan;

26. Irum Mehboob Raja, Pakistan Institute of Nuclear Science & Technology (PINSTECH);

27. Jalaluddin Haqqani and seven aliases;

28. Khalil Zardan and eight aliases;

29. Khalil Zardan Company – Khalil Construction;

30. KMA International Import and Export Co.;

31. Khurshid Ghoura and two aliases;

32. Lapcom Computer Stores;

33. Lastech Associates;

34. LT Engineering and Trade Services Pvt. Ltd. (LTE);

35. Machinery Master Enterprises Pvt. Ltd. (MME);

36. Makkays Hi-Tech Systems – Zaib Electronics;

37. Maple Engineering Pvt. Ltd.;

38. Marine Systems Pvt. Ltd.;

39. Maritime Technology Complex (MTC);

40. Micado;

41. Mohammad Azam – Mohammad Akram;

42. MSN International;

43. Muhammad Halim Ghoura;

44. Mushko Electronics Pvt. Ltd.;

45. National Engineering and Scientific Commission (NESCOM);

46. Nazir and Sons International;

47. New Auto Engineering (NAE);

48. Ologh Beg International Forwarders Ltd.;

49. Orient Importers and Exporters;

50. Oriental Engineers;

51. Orion Eleven Pvt. Ltd.

52. Pakistan Atomic Energy Commission (PAEC) and its affiliates;

53. People’s Steel Mills;

54. Pervaiz Commercial Trading Co. (PCTC);

55. Premier International – Align Impex;

56. Prime International;

57. Proficient Engineers;

58. Sher Qadir;

59. Solutions Engineering Pvt. Ltd. and its affiliates;

60. Space and Upper Atmosphere Research Commission (SUPRACO);

61. Sumico Technologies;

62. Technical Services;

63. The Tempest Trading Company;

64. Unique Technical Promoters;

65. Universal Tooling Services and its affiliates;

66. Veteran Avia LLC – Veteran Airline;

67. Wah Chemical Product Plant – Wah Noble Chemicals Ltd.;

68. Wah Munitions Plant