EXTRANCHECK: POST SHIPMENT VERIFICATION:

UNCLAS HONG KONG 000900

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: POST SHIPMENT VERIFICATION:
DORADO CO. (HK)

REF: A) USDOC 02348

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),
accompanied by Commercial Vice Consul Tyler
Warren, conducted a post shipment verification
(PSV) at Dorado Co. (HK) (Dorado),51 Jordan Road,
Room 402, Kowloon, Hong Kong. The items in
question are dielectric resonator oscillators
exported to Dorado on or about January 20, 2007
and valued at USD 22,950. On the applicable
shippers export declaration (SED),these items are
classified as EAR99. Items properly classified as
EAR99 may be exported/reexported to virtually all
destinations and end-users worldwide, license
free. The exporter was Herley-CTI of Whippany,
New Jersey (Herley).


3. Dorado is not included in the Hong Kong
Companies Registry as it is not an incorporated
entity. According to the Hong Kong Inland Revenue
Department Business Registration Office, Dorado is
registered at the address noted above. It is a
sole proprietorship and has been in existence
since 1984. The owner is Mr. Kelvin Kwok.
According to information obtained from the Hong
Kong Trade Development Council (TDC) web site,
Dorado is a representative of high-tech electronic
companies in the United States and United Kingdom
and sells electronic equipment to customers in
Hong Kong and mainland China. It has two
employees.


4. The ECO and Vice Consul Warren visited Dorado
at the address referenced above on March 22, 2007
and met with Kelvin Kwok, Managing Director. The
office is modest in size, typical for a small
trading company in Hong Kong. Mr. Kwok provided
background on Dorado. Consistent with the
information noted above, Mr. Kwok stated that
Dorado is his company and is a reseller of high-
tech equipment into Hong Kong and mainland China.
He has been in this type of business for quite
some time.


5. Mr. Kwok was quite familiar with U.S. export
controls noting that he routinely provides end-use
information to Herley. He claimed that all of his
customers are commercial companies in Hong Kong
and mainland China. He expressed his opinion that
U.S. export controls are overly stringent and out
of date.


6. With respect to the shipment that was the
subject of the PSV, Mr. Kwok provided the
applicable documentation reflecting that the items
had been received by Dorado and subsequently
resold to Tung Pang Group Limited in Hong Kong. A
review of the applicable shipping documentation
from Herley and supplied by Mr. Kwok indicated
that the end-user of the items is the Nanjing
Radio Factory. Mr. Kwok noted that while the
customer is Nanjing Radio Factory, he trades with
Tung Pang Group, an agent for Nanjing Radio
Factory. According to the Hong Kong Companies
Registry, Tung Pang Group has nominal (equivalent
of USD 1,200) share capital. Its director is
mainland Chinese national Defa Ziu. According to
the Companies Registry, Defa Qiu is also director
of Suntek International (HK) Limited (established
in 2005). During the visit, another shipment of
the same type of items arrived at the office. Mr.
Kwok showed the ECO and Vice Consul Warren the
items and the underlying shipping documentation.
It listed Nanjing Radio Factory and Nanjing
Research Institute as end-users.


7. At the time visited, Dorado appeared to be a
suitable recipient of the commodities shipped (as
reseller) since Dorado cooperated with the PSV and
provided all requested information concerning the


final disposition of the applicable items. Dorado
is likewise familiar with and stressed its intent
to comply with U.S. export control rules. At the
same time, the ECO was not able to inspect the
subject items as they had already been delivered
to Dorado's customer. Consistent with guidance on
reporting of PSVs where the items cannot be
physically inspected, the ECO recommends that this
PSV be classified as Limited.
Cunningham