EXTRANCHECK: PRE-LICENSE CHECK: Brink's Hong

UNCLAS HONG KONG 003714

SIPDIS

USDOC FOR 532/OEA/LHINES/DFARROW
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM
ZARIT
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS

SIPDIS

E.O. 12958: N/A
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: PRE-LICENSE CHECK: Brink's Hong
Kong Limited

REF: A) USDOC 04706 B) EXP.LIC. D362247


1. Unauthorized disclosure of the information provided
below is prohibited by Section 12C of the Export
Administration Act.


2. As per reftel A request and at the direction of the
Office of Enforcement Analysis (OEA) of the USDOC
Bureau of Industry and Security (BIS),Export Control
Officer Philip Ankel (ECO),conducted a pre-license
check at Brink's Hong Kong Limited, 1022W First Floor,
Kwai Chung Container Terminal 3, New Territories, Hong
Kong (Brink's Hong Kong). The purpose of the visit was
to determine the suitability of Brink's Hong Kong to be
the recipient of 28 tactical police riot helmets and
100 harnesses/chin straps that are the subject of
export license application D362247. The items (ECCN
0A979) are valued at USD $11,220 and are controlled for
crime control (CC) reasons. The license applicant is
Galls Incorporated, 1340 Russell Cave Rd., Lexington,
KY 40505 (Galls).


3. Brinks Hong Kong is the wholly owned subsidiary of
Brink's, Incorporated in the United States and Brink's
Hong Kong has been in operation in Hong Kong since 1979
(www.brinks.com.hk).


4. On August 29, 2006, the ECO visited Brink's Hong
Kong at the address above and met with Joseph Chu,
Assistant Human Resources and Administration Manager.
Mr. Chu stated that guard employees are issued helmets
for use in performing their duties. Employees typically
keep the helmets in their employee lockers when they
are not using them but Mr. Chu stated that there is no
specific requirement that employees keep the helmets at
the Brink's facility after hours.


5. Mr. Chu stated that the work of Brink's Hong Kong
security crews sometimes takes them into mainland China
and that the helmets go with those crews.
Additionally, Mr. Chu volunteered that this latest
order replaces some prior helmets also ordered from
Galls in October 2004 (Galls is the primary supplier of
this type of equipment to Brink's Hong Kong). Mr. Chu
further stated that old helmets are destroyed when they
are no longer useable since they include the Brink's
logo and Brink's is keen to avoid such helmets falling
into the wrong hands.


6. This ECO recommends BIS ascertain whether the 2004
shipment of helmets required a license and, if so,
whether such license was obtained. Note: Reftel A
states that Brink's Hong Kong does not have a licensing
history with BIS.


7. Brink's Hong Kong was very forthcoming during the
PLC visit. Mr. Chu provided information on the
intended use of the items and on past shipments of the
same (or similar) items. Additionally, the items are
appropriate for the intended end-user and stated end-
use. However, the ECO discovered additional facts
during the course of the PLC visit that should be
addressed, as appropriate, during the licensing
process. In particular, as noted above, Brink's Hong
Kong expects that its employees will be taking the
helmets into China from time to time as their duties
take them there. Additionally, it appears Brink's Hong
Kong received a shipment of comparable helmets in
October 2004 for which a license may have been required
but not obtained by Galls. As a result, the ECO
recommends that this PLC be considered to be Limited.
Cunningham