Evaluating Risk - The Aftermath of the Rogelio Vasquez Conviction

Kristal Snider
ERAI, Inc.

On May 30, 2019, Rogelio Vasquez, aka “James Harrison”, owner of PRB Logics Corporation, was sentenced to 46 months in a federal prison after pleading guilty to trafficking in counterfeit military goods, trafficking in counterfeit goods, and wire fraud.

Vasquez’s guilty plea, entered on January 17, 2019, was the result of a multi-agency investigation that began in 2015 and that unraveled a scheme to defraud beginning on or before July 2009. The investigation was conducted by U.S. Department of Defense, Office of Inspector General – Defense Criminal Investigative Service; U.S. Immigration and Customs Enforcement’s Homeland Security Investigations; and the National Reconnaissance Office, Office of Inspector General.

The investigation revealed that Vasquez, for at least seven years from approximately July 2009 through May 31, 2016, imported counterfeit integrated circuits from suppliers in China and re-sold them to customers in the United States, many of which were ultimately purchased by defense contractors for use in the U.S. military. Vasquez knew, and took great lengths to cover up, the ICs he was selling were old, used and/or discarded and that his Chinese suppliers had sanded off all of the original markings, and then resurfaced and remarked these chips using a process commonly referred to as “blacktopping”. Once the parts were resurfaced and remarked, the parts were sold as new parts.

Equally disturbing, Vasquez instructed a test laboratory in China by the name of Advanced-Lab Technology Center to prepare two separate versions of test reports to hide the fact the parts failed remarking and resurfacing tests such as resistance to solvents using acetone. In addition to defrauding his customers, Vasquez also engaged in a scheme to avoid seizures by CBP by including sanitized versions of test reports generated by Advanced-Lab in shipments as evidence the goods contained therein were genuine when, in fact, they were counterfeit.

On May 26, 2016, federal agents executed a search warrant at the office of PRB Logics, which was Vasquez’s home, where parts marked with part numbers historically used in military applications were seized. We know for certain some of the counterfeit ICs sold by Vasquez ended up in a classified Air Force program, and others were intended for use in the B-1 Bomber aircraft, but we will likely never know the whereabouts of all the counterfeit parts linked to Vasquez’s criminal operation. We can safely assume a significant number of counterfeit parts have entered the supply chain as a result of Vasquez’s illegal enterprise. We should also assume, any part sold by Vasquez was counterfeit unless the part was fully vetted in accordance with industry recommended inspection and testing guidelines.

Under the terms of his plea agreement, Vasquez agreed to forfeit 169,148 suspect/presumed counterfeit integrated circuits seized by the government from his residence. These parts have been added to ERAI’s High Risk and Suspect Counterfeit Parts Database and assigned a classification of FN - Federal Notice - A part or list of parts which are publicly released as part of a U.S. federal/government agency notice. These parts may require additional evaluation based on your organization’s internal risk mitigation procedures.

The following parts were identified as seized items noted in the Government’s Order of Forfeiture

Part NumberManufacturer
S80C196KB12INTEL CORP
XC4010E-PG191CXILINX INC
XQ4005E-4PG156MXILINX INC
TA7745FTOSHIBA AMERICA ELECTRONIC COMPONENTS INC
SN74F283NTEXAS INSTRUMENTS INC
STK20C04SIMTEK CORP
RF6000-3RF MICRO DEVICES INC (RFMD)
MAB8420C006NXP SEMICONDUCTORS
DS1633J-8/883NATIONAL SEMICONDUCTOR CORP
GRM42-6X7R106K2000MURATA MANUFACTURING CO LTD
MRF9085LSMOTOROLA INC
PIC16F627AMICROCHIP TECHNOLOGY INC
IXFR150N15IXYS CORP
DSD51-16AIXYS CORP
6FL100S05INTERNATIONAL RECTIFIER CORP
VC-2R8A26-1065FUJITSU SEMICONDUCTOR
MBM29LV160TE-70FUJITSU SEMICONDUCTOR
4N26FAIRCHILD SEMICONDUCTOR CORP
CY7C187-35PCCYPRESS SEMICONDUCTOR CORP
AT28C256FATMEL CORP
AM79866AJCADVANCED MICRO DEVICES INC
AM79865JCADVANCED MICRO DEVICES INC
AM29LV008BT-80ADVANCED MICRO DEVICES INC
GRM188R71H221KNEVENKEL LTD
2CF104ZF51LTAIYO YUDEN CO LTD
SI1400DLVISHAY
VI-B12-CVVICOR CORP
SN74F283NTEXAS INSTRUMENTS INC
SMF05CSEMTECH CORP
PIC16F627AMICROCHIP TECHNOLOGY INC
CDP68HC68T1M296INTERSIL CORP
GRM40Y5V105Z016ADMURATA MANUFACTURING CO LTD
GMC21X7R271K100NTCAL-CHIP ELECTRONICS INC
GMC10X7R391K100NTCAL-CHIP ELECTRONICS INC
TAJB476K010YNJAVX CORP
TAJA684K025AVX CORP
18255C105JAT2AAVX CORP
Z8523020VSGZILOG INC
TC55V16100FT-12TOSHIBA AMERICA ELECTRONIC COMPONENTS INC
TMS320C6713TEXAS INSTRUMENTS INC
FDC37C665GTMICROCHIP TECHNOLOGY INC
K9K8G08U0B-PIB0SAMSUNG SEMICONDUCTOR INC
PM8368-BIPMC-SIERRA INC
PM8315-PIPMC-SIERRA INC
Part NumberManufacturer
PM5354-BIPMC-SIERRA INC
U709B846NVIDIA CORP
MC68HC11E2FNMOTOROLA INC
MC68EN360CFE25MOTOROLA INC
MC68EN360CEM25LMOTOROLA INC
MC68020CRC25EMOTOROLA INC
GDPXA255A0MARVELL SEMICONDUCTOR INC
DG187AINTERSIL CORP
PXA255A0E400INTEL CORP
LXT384LEINTEL CORP
DT28F160S3-100INTEL CORP
IDT77211INTEGRATED DEVICE TECHNOLOGY INC
HY57V161610SK HYNIX
FX105CML MICROSYSTEMS PLC
EPX740LC68-12ALTERA CORP
EP610ILC-10ALTERA CORP
M6117CALI CORP
HDMP-1687AGILENT TECHNOLOGIES INC
XCV1600E-8FG680CXILINX INC
XCV1000E-6FG680IXILINX INC
XC4028XLA (09C)XILINX INC
XC3S400-4FG456CXILINX INC
XC2S200-FG456AMXILINX INC
JANTX2N6251MOTOROLA INC
XQ2VP40-5FG676NXILINX INC
XCV2000E-7FG680CXILINX INC
XCV1000E-6HQ240IXILINX INC
XCS40-4PQ240CXILINX INC
XCS05XL-4VQ100IXILINX INC
XC9536-10VQG44IXILINX INC
XC4085XL-3BG560IXILINX INC
XC2VP40-5FFG1152IXILINX INC
XC2VP40-5FF1152IXILINX INC
XC2V4000-4BFG957CXILINX INC
XC2V1000-4FGG456CXILINX INC
XC2V1000-4FGG456CXILINX INC
XC2S200-5FG456CXILINX INC
S80C196KB12INTEL CORP
XQ4005E-4PG156MXILINX INC
XC3042A-7PG84MXILINX INC
XQ4028EX-4HQ240NXILINX INC
DAC100ACQ5/883ANALOG DEVICES INC
XC95216-10PQ160IXILINX INC


ERAI recommends any parts purchased from Vasquez that were not tested and inspected in accordance with industry recommended inspection and testing guidelines be considered suspect counterfeit or high risk and subject to reevaluation.

Counterfeit electronic parts pose a significant risk to performance of defense systems. Even if counterfeits made from previously used parts and salvaged from e-waste may initially perform, there is no way to predict how well they will perform, how long they will last, and the full impact of failure.

Additional reading:

Government’s Sentencing Position
Government’s Order of Forfeiture
Indictment

To view the parts supplied by Rogelio Vasquez as reported by the government, after logging in to the ERAI website, select “High Risk & Counterfeit Parts” under the search tab. Once the search page appears, open the Advanced Part Search by clicking on 2. High Risk and Suspect Counterfeit Parts Advanced Search. Make sure the “FN Federal Notice” checkbox is checked and click on the Search button. The alerts will have report dates of June 4, 2019 and May 2, 2018.



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