A few weeks ago, BIS published in the Federal Register an Order Temporarily Denying Export Privileges to a number of entities for illegal exports to Pakistan. The FR notice contains more detail than I ever recall seeing in such a notice.
This is a good summary:
Respondents operated a well-developed procurement scheme for at least five years, designed to circumvent U.S. restrictions on exports of items to the PAEC and AERO based on their involvement in the proliferation of nuclear and missile technology. This scheme involved multinational entities and players located in at least three countries, the use of related and unrelated companies, changeable transshipment routes, and duplicitous methods of payment. Respondents themselves routinely generated false information to avoid detection of the scheme. In addition, on its own, the unsealing of the criminal indictment against the individual Respondents will not give the public sufficient notice of the individuals and entities involved in the ongoing procurement scheme. Thus, with the identification of the Respondents as set forth in this TDO, the undersigned expects to reduce the likelihood that U.S.-origin items will be exported, reexported or transferred to listed entities as part of the procurement scheme.
The notice adds that “the scheme is durable and ongoing.” Below are highlighted portions of the FR notice which explain some of what PAEC, AERO, et al have been up to and for what they’ve been shopping.