Risk Level:
99% May harm your business future; Persons or entities that engage in transactions with this entity will be exposed to sanctions or subject to an enforcement action;

Working with this entity means supporting Iranian Regime, Regime Terrorist Activities & development of WMD

Top Alert – Entity designated / sanctioned for terror, WMD and human rights violation

Principal and commercial manager of LIMMT Economic and Trade Company, Ltd. (LIMMT);

Supplies goods to entities involved in Iran’s ballistic missile program;

Has reportedly worked through the Iranian embassy in Beijing to sell missile-usable components to Iranian entities, including gyroscopes, accelerometers, graphite cylinders, ultra-high strength steel, and high-grade aluminum alloy;

In 2011, reportedly agreed to supply 1,500 gyroscopes and accelerometers, a quantity sufficient to equip approximately 500 missiles, to U.N.-sanctioned Shahid Bagheri Industrial Group (SBIG); continuing to supply items to missile entities in Iran as of March 2014, according to a senior U.S. State Department official;

Indicted on April 28, 2014, in the U.S. District Court for the Southern District of New York, on charges of violating the International Emergency Economic Powers Act (IEEPA), conspiracy to commit money laundering, and wire fraud; subject of a $5 million award offered by the U.S. Department of State’s Transnational Organized Crime Rewards Program for information leading to his arrest and/or conviction;

Allegedly sold “weapons materials” to subsidiary organizations of Iran’s Defense Industries Organization (DIO), including Amin Industrial Group, Khorasan Metallurgy Industries, Shahid Sayyade Shirazi Industries, and Yazd Metallurgy Industries;

Allegedly sent an invoice in June 2008 to an agent of Amin Industrial Complex for 24,500 kilograms of maraging steel rods; allegedly acknowledged receipt of payment in 2007 for eight pieces of steel plates sold to Khorasan Metallurgy Industries; allegedly in April 2007 sent an invoice to an agent of Shahid Sayyade Shirazi Industries confirming the sale of 450 metric tons of furnace electrodes with 4TPI nipples;

In 2007, allegedly communicated with agents of Aban Commercial and Industrial Co. over the sale and shipment of 2,000 kilograms of tungsten metal powder, 400 pieces of tungsten-copper alloy plates, and 200 pieces of graphite cylinders for an electrical discharge machine (EDM-15);

Allegedly used the bank account of Sunny Minerals Company Limited to fraudulently access the U.S. financial system and transact with Iranian entities; according to the New York County District Attorney, negotiated to send DIO 400 gyroscopes, 600 accelerometers, and 100 pieces of tantalum;

Operates or controls the following companies that have been involved in transactions with Iran:

Dalian Zhenghua Maoyi Youxian Gongsi (Dalian Zenghua Trading Co. Ltd.)
Dalian Zhongchuang Char-White Co., Ltd.
Karat Industry Co. Ltd.
MTTO Industry and Trade Limited
Sinotech Dalian Carbon and Graphite Manufacturing Corporation
Sinotech Industry Co., Ltd.
Success Move Ltd.
Tereal Industry and Trade Limited.

Has allegedly used the following companies to conduct financial transactions:

ABC Metallurgy Limited
Abo Trading Co., Ltd.
Ansi Metallurgy Industry Co., Ltd.
Ara Steel Mills Company
Blue Sky Industry Corporation
Dalian Carbon Co., Ltd.
Dalian Sunny Industry and Trade Co., Ltd.
Liaoning Industry and Trade Co., Ltd.
MMN Industry Corporation
SC (Dalian) Industry and Trade Co., Ltd.
Sino Metallurgy and Minmetals Industry Co., Ltd.
Summit Industry Corporation
Ta Industry Co.
Wealthy Ocean Enterprises Ltd.

Also Known As:
Karl Lee
Sunny Bai
K. Lee
David Li
F.W. Li
Li Fangwei

Involved In:
Nuclear Weapon Program
Missile Weapon Program
Military Weapon Program


September 18, 1972

– Wafangdian, Dalian, Liaoning
– 2501-2508 Yuexiu Mansion, No. 82 Xinkai Road, Dalian, Liaoning 116011, China


National Identification Number:
230225720918531 (China)
W710456843 (National Crime Information Center (NCIC) number)

Reason for the color:
» Sanctioned by the U.S. Department of State on September 2, 2015, December 19, 2014, and February 5, 2013 under the Iran, North Korea, and Syria Nonproliferation Act;
» The sanctions apply for two years and ban the U.S. government from procuring from, contracting with, or providing assistance to the entity
» Sanctioned by the United States on February 11, 2013, pursuant to Executive Order 12938, for engaging in proliferation activities, banning import into the United States of goods produced or provided by the entity;
» Added to the Specially Designated Nationals (SDN) list maintained by OFAC on April 7, 2009, freezing his assets under U.S. jurisdiction and prohibiting transactions with U.S. parties, pursuant to Executive Order 13382, which targets proliferators of weapons of mass destruction (WMD) and their delivery systems;

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IFMAT Color Guide

We sort entities who are connected with terrorist activities, in two sections, first by risk and second by geolocation.
GeoLocation divisions are divided into two fields, Black List and Gray List.
BlackList is a list of all companies, organizations and figures who originate from Iran.
GrayList is a list of all companies, organizations and figures out of Iranian borders, and doing business with Iran.
We identify risk of entities by COLOR selection, each color marks the risk level of the entity.(by declining order)
Designated / Sanctioned / Illicit entities
Entities affiliated with Designated / Sanctioned / Illicit entities.
Entities sanctioned in the past for Terror or Illicit activities / WMD related / Human rights violations.
Entities in a problematic sector - Sector controlled by the Top Alert entities.
Legitimate entities - we cannot determine whether an entity is completely green, and that is due to the facts that the Iranian economy is not transparent enough for us. Be sure.