EXTRANCHECK: PRELICENSE CHECK: UNIQUE ELECTRONICS LIMITED

UNCLAS HONG KONG 000738 SIPDIS USDOC FOR 532/OEA/LHINES/DFARROW USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS BEIJING FOR FCS JEANETTE CHU SIPDIS E.O. 12958: N/A TAGS: BMGT BEXP HK ETRD ETTC SUBJECT: EXTRANCHECK: PRELICENSE CHECK: UNIQUE ELECTRONICS LIMITED REF: A) USDOC 00888 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) and Commercial Assistant Sandy Lai attempted to conduct a pre-license check (PLC) at Unique Electronics Limited, Unit I, 3/F, Good Harvest Center, 33 On Chuen St., Fanling, Hong Kong (Unique). The items in question are 20 Uni-Imps high-speed transient surge protectors classified under Export Control Classification Number (ECCN) 3A228 and controlled for nuclear nonproliferation (NP) reasons. The license applicant is High Energy Devices LLC of Maryland Heights, MO. ¶3. According to the Hong Kong companies registry, Unique has been in existence since June 2003. Its directors are Song, Fang and Song, Youjun, both mainland Chinese passport holders. The companyQs issued and paid up capital is HK10 (approximately USD 1). According to the companies registry, these directors are not listed as directors in any other Hong Kong companies. ¶4. A review of open source information reveals that several other companies are collocated with Unique at its address in Hong Kong including the following: Easy (H.K.) Trading Company Ltd. (www.easyhk.com),Prosperity International Trading Ltd., HK Perfection Industry Ltd., Parkson Pack Co. Ltd., and Yakoda (H.K.) Co., Ltd. ¶5. A review of the web site of the ultimate consignee (Xian Fangyanming Science & Technology) reveals that this entity has several affiliates. More information on those affiliates may be found at the following websites: www.fy-ic.com, www.fyming.com, www.gatherstar.com, www.winner-fy.com and www.bjfy-ic.com. Note that two affiliates are representative offices in Russia and Ukraine. Shenzhen-based affiliate, Shenzhen Fan Yan Ming Technology Development Company states on its website that it is the authorized sales agent of Rochester Electronics, the worldQs most comprehensive aftermarket supplier of discontinued semiconductors. Shenzhen Fan Yan Ming Technology Development Company further states that it can procure Russian military products. The director of that company also appears to be a director of Unique. ¶6. Commercial Assistant Sandy Lai attempted for several weeks to arrange a meeting to conduct the PLC. According to the receptionist who answered the phone, Mr. Sang Fong was not available to meet because of his travels throughout mainland China. Mr. Sang FongQs unwillingness to meet persisted despite numerous calls and letters to the company. ¶7. OEA has indicated to the ECO that the exporter no longer wishes to proceed with this transaction and has requested that the ECO close out this PLC. The ECO is therefore closing out this PLC as inconclusive. Cunningham