EXTRANCHECK: POST SHIPMENT VERIFICATION:

UNCLAS HONG KONG 004492

SIPDIS

USDOC FOR 532/OEA/LHINES/KGAINES
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM
ZARIT

BEIJING FOR FCS JEANETTE CHU

BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS

SIPDIS

E.O. 12958: N/A
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION:
BEIJING RUST S&T COMPANY LTD.

REF: A) 04971


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 post shipment
verification (PSV) at Beijing Rust S & T Company Ltd.,
7/F Pahsang Industrial Building, 16 San On Street, Hong
Kong (Beijing Rust). The PSV concerned GPS surveying
equipment valued at $26,286 exported to Beijing Rust by
Timble Navigation Ltd. of Dayton, Ohio in April 2006.
Trimble classified the equipment under ECCN 7A994,
which ECCN is controlled for anti-terrorism reasons
(AT).


3. Repeated attempts by FCS staff to reach Beijing Rust
as the number provided in Reftel A were unsuccessful.
In fact, a representative from the telephone company's
directory assistance service stated that there is no
phone number listed for Beijing Rust. The management
company for the Pahsang Building stated that Beijing
Rust had left its building in July and had left no
contact information. Finally, the ECO visited the
Pasang Building on November 15, 2006. No reference to
Beijing Rust was included in the building directory and
both of the two business entrances on the 7th floor of
the building were locked and showed no indication that
Beijing Rust was doing business at those locations.


4. A web search of the name Beijing Rust revealed that
Beijing Rust has an office in Beijing and that it acts
as a distributor for Trimble Navigation
(www.rustsales.com.cn). Inquiry with that company in
Beijing may reveal further information about the
shipment (since this entity is listed as the "bill to"
entity on the applicable invoice).


5. It appears to the ECO that any presence that
Beijing Rust had in Hong Kong was closed in July when
it left the Pahsang building. If the equipment has
been classified correctly, it can most likely be
exported to Hong Kong and reexported/transshipped to
mainland China NLR (No License Required). The ECO can
find no specific reason to assume that anything
untoward has occurred in respect of this shipment.
Therefore, in accordance with guidance on reporting of
PSVs where the items cannot be physically inspected,
the ECO recommends that this PSV be classified as
Limited.
Cunningham