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 Number | Manufacturer |
| S80C196KB12 | INTEL CORP |
| XC4010E-PG191C | XILINX INC |
| XQ4005E-4PG156M | XILINX INC |
| TA7745F | TOSHIBA AMERICA ELECTRONIC COMPONENTS INC |
| SN74F283N | TEXAS INSTRUMENTS INC |
| STK20C04 | SIMTEK CORP |
| RF6000-3 | RF MICRO DEVICES INC (RFMD) |
| MAB8420C006 | NXP SEMICONDUCTORS |
| DS1633J-8/883 | NATIONAL SEMICONDUCTOR CORP |
| GRM42-6X7R106K2000 | MURATA MANUFACTURING CO LTD |
| MRF9085LS | MOTOROLA INC |
| PIC16F627A | MICROCHIP TECHNOLOGY INC |
| IXFR150N15 | IXYS CORP |
| DSD51-16A | IXYS CORP |
| 6FL100S05 | INTERNATIONAL RECTIFIER CORP |
| VC-2R8A26-1065 | FUJITSU SEMICONDUCTOR |
| MBM29LV160TE-70 | FUJITSU SEMICONDUCTOR |
| 4N26 | FAIRCHILD SEMICONDUCTOR CORP |
| CY7C187-35PC | CYPRESS SEMICONDUCTOR CORP |
| AT28C256F | ATMEL CORP |
| AM79866AJC | ADVANCED MICRO DEVICES INC |
| AM79865JC | ADVANCED MICRO DEVICES INC |
| AM29LV008BT-80 | ADVANCED MICRO DEVICES INC |
| GRM188R71H221KNE | VENKEL LTD |
| 2CF104ZF51L | TAIYO YUDEN CO LTD |
| SI1400DL | VISHAY |
| VI-B12-CV | VICOR CORP |
| SN74F283N | TEXAS INSTRUMENTS INC |
| SMF05C | SEMTECH CORP |
| PIC16F627A | MICROCHIP TECHNOLOGY INC |
| CDP68HC68T1M296 | INTERSIL CORP |
| GRM40Y5V105Z016AD | MURATA MANUFACTURING CO LTD |
| GMC21X7R271K100NT | CAL-CHIP ELECTRONICS INC |
| GMC10X7R391K100NT | CAL-CHIP ELECTRONICS INC |
| TAJB476K010YNJ | AVX CORP |
| TAJA684K025 | AVX CORP |
| 18255C105JAT2A | AVX CORP |
| Z8523020VSG | ZILOG INC |
| TC55V16100FT-12 | TOSHIBA AMERICA ELECTRONIC COMPONENTS INC |
| TMS320C6713 | TEXAS INSTRUMENTS INC |
| FDC37C665GT | MICROCHIP TECHNOLOGY INC |
| K9K8G08U0B-PIB0 | SAMSUNG SEMICONDUCTOR INC |
| PM8368-BI | PMC-SIERRA INC |
| PM8315-PI | PMC-SIERRA INC |
|
| Part Number | Manufacturer |
| PM5354-BI | PMC-SIERRA INC |
| U709B846 | NVIDIA CORP |
| MC68HC11E2FN | MOTOROLA INC |
| MC68EN360CFE25 | MOTOROLA INC |
| MC68EN360CEM25L | MOTOROLA INC |
| MC68020CRC25E | MOTOROLA INC |
| GDPXA255A0 | MARVELL SEMICONDUCTOR INC |
| DG187A | INTERSIL CORP |
| PXA255A0E400 | INTEL CORP |
| LXT384LE | INTEL CORP |
| DT28F160S3-100 | INTEL CORP |
| IDT77211 | INTEGRATED DEVICE TECHNOLOGY INC |
| HY57V161610 | SK HYNIX |
| FX105 | CML MICROSYSTEMS PLC |
| EPX740LC68-12 | ALTERA CORP |
| EP610ILC-10 | ALTERA CORP |
| M6117C | ALI CORP |
| HDMP-1687 | AGILENT TECHNOLOGIES INC |
| XCV1600E-8FG680C | XILINX INC |
| XCV1000E-6FG680I | XILINX INC |
| XC4028XLA (09C) | XILINX INC |
| XC3S400-4FG456C | XILINX INC |
| XC2S200-FG456AM | XILINX INC |
| JANTX2N6251 | MOTOROLA INC |
| XQ2VP40-5FG676N | XILINX INC |
| XCV2000E-7FG680C | XILINX INC |
| XCV1000E-6HQ240I | XILINX INC |
| XCS40-4PQ240C | XILINX INC |
| XCS05XL-4VQ100I | XILINX INC |
| XC9536-10VQG44I | XILINX INC |
| XC4085XL-3BG560I | XILINX INC |
| XC2VP40-5FFG1152I | XILINX INC |
| XC2VP40-5FF1152I | XILINX INC |
| XC2V4000-4BFG957C | XILINX INC |
| XC2V1000-4FGG456C | XILINX INC |
| XC2V1000-4FGG456C | XILINX INC |
| XC2S200-5FG456C | XILINX INC |
| S80C196KB12 | INTEL CORP |
| XQ4005E-4PG156M | XILINX INC |
| XC3042A-7PG84M | XILINX INC |
| XQ4028EX-4HQ240N | XILINX INC |
| DAC100ACQ5/883 | ANALOG DEVICES INC |
| XC95216-10PQ160I | XILINX INC |
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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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