Identifier
Created
Classification
Origin
07HONGKONG417
2007-02-13 06:59:00
UNCLASSIFIED
Consulate Hong Kong
Cable title:  

EXTRANCHECK: PRE-LICENSE CHECK: APS

Tags:  BMGT BEXP HK ETRD ETTC 
pdf how-to read a cable
VZCZCXYZ0015
RR RUEHWEB

DE RUEHHK #0417 0440659
ZNR UUUUU ZZH
R 130659Z FEB 07
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 0470
RHMFIUU/HQ BICE WASHINGTON DC
UNCLAS HONG KONG 000417 

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: APS
Paintball Ltd.
REF: A) USDOC 00886 B) EXP.LIC. D370258

UNCLAS HONG KONG 000417

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: APS
Paintball Ltd.
REF: A) USDOC 00886 B) EXP.LIC. D370258


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 (PLC) at APS Paintball Ltd., Blk B, 22/F, 77-87
Wang Lung St., Richwealth Industrial Building, Tsuen
Wan, Hong Kong (APS). The purpose of the PLC was to
determine the suitability of APS to be the recipient
of various C-More gun sights. The items (ECCN 0A987)
are valued at approximately USD $14,000 and are
controlled for crime control (CC) reasons. The
license applicant is C-More Systems of Manassas,
Virginia.


3. According to the Hong Kong Companies Registry,
APS Paintball Limited has been in existence since
March, 2003 (previous name APS Paintball Supply
Limited). Mr. Chi Keung Lee (Hong Kong resident)
and Mr. Guodong Liang (mainland Chinese national) are
listed as directors. The registered address is the
primary business location of the company.


4. On February 6, 2006, the ECO visited APS at the
address above and met with Mr. Chi Keung Lee, Sales
and Marketing Director. Mr. Lee described the
business of APS as the provision of paintball guns
and related supplies to Hong Kong customers as well
as other customers in the United States and
elsewhere. Approximately 60-70% of sales are exports
to the United States. The paintball guns are
produced in mainland China. APS has a branch office
in the United States serving the U.S. market
(including the law enforcement market). All
information provided by Mr. Lee was consistent with
information on the company's web site
(www.apsram.com).


5. Mr. Lee stated that APS intends to use the items
that are subject to the license on paintball guns for
sale within Hong Kong and for export back to the
United States (as part of a package deal). He stated
that he presently uses Aimpoint sights for this
purpose that he imports from Sweden but those sights
are substantially more expensive than the C-More
units. Other sights produced in mainland China are
much less expensive but not as highly sought by his
customers.


6. Mr. Lee stated that he understands the sights may
not be reexported into mainland China and may require
additional licenses if reexported to other
destinations. He stressed that he does not export
his products back into mainland China because of the
very strict licensing rules for guns in China (he
stated that, in mainland China, paintball guns are
subject to the rigorous licensing rules that govern
real guns). Mr. Lee was keen to comply with U.S.
export restrictions and requested additional
information concerning restricted destinations and
end-users. ECO provided BIS guidance on reexports
and other contact information.


7. APS was very forthcoming during the PLC visit.
Mr. Lee provided information on the underlying
transaction and provided the ECO information
concerning his business and his intent to comply with
U.S. export controls. The ECO recommends that this
PLC be considered Favorable.
Cunningham