EXTRANCHECK: POST SHIPMENT VERIFICATION:

UNCLAS HONG KONG 001007

USDOC FOR 532/OEA/MNICKSON-DORSEY /LLAUCIUS
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS
SINGAPORE FOR FCS

SIPDIS

E.O. 12958: N/A
TAGS: BMGT BEXP ETRD ETTC HK
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION:
MOS GROUP PTE LTD
REF: A) USDOC 01387 B) D377049

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),Regional Export Control Officer Philip Ankel (ECO)
conducted a post shipment-verification (PSV) at MOS Group Pte Ltd.,
2 Boon Leat Terrace No. 05-03, Harbourside Bldg 2, Singapore (MOS).
The item in question is a hafnium metal sputter target exported to
MOS on or about August 16, 2007 and valued at USD 565. The item is
classified under Export Control Classification Number (ECCN) 1C231
and is controlled for nuclear non-proliferation (NP) reasons. The
exporter was Bayville Chemical Supply Company of Deer Park, New
York.


3. According to the Singapore companies registry, MOS was
registered in 2004 and its registered share capital is the Singapore
dollar equivalent of approximately USD 30,000. Its directors and
shareholders are Singapore permanent residents Li, Wai Ping and Li,
Tan Mua.


4. According to the company's web site, MOS's focus is
manufacturing and refurbishing semiconductor equipment. It has
support centers in Asia and the United States. The company states
that is has over 20 years of process equipment experience and is in
partnership with renowned semiconductor equipment manufacturers to
offer equipment refurbishment and turn-key technology. Key products
include diffusion furnaces, rapid thermal process systems, plasma
ashers and chemical cleaning systems. It supplies several IC
production lines in China. MOS has offices in Singapore, mainland
China, Hong Kong, the United States and service centers in Malaysia,
Taiwan and Thailand.


5. On April 21, 2008, the ECO, accompanied by a representative of
Singapore Customs visited the company and met with Ms. Mavis Tai,
Deputy General Manager. Ms. Tai stated that the company is
primarily a trading company specialized in semiconductor equipment.
It is the authorized representative of some U.S. companies and
supplies a range of semiconductor manufacturing companies including
STAT, SMIC and UMC. It also provides spare parts to various
universities and research institutes in Singapore. The Thailand and
Malaysia offices are primarily involved in equipment sales.
Bayview, the exporter, is an occasional supplier.


6. As to the particular item in question, Ms. Tai stated that this
item had been procured on behalf of the Singapore Institute of
Materials Research and Engineering, a Singapore government sponsored
research institute (http://www.imre.a-star.edu.sg). As to the
end-use of the item, Ms. Tai provided an e-mail from Ms. Emily Chua
of the institute stating that a Denton Sputtering Discovery 18 would
be used to sputter the material on silicon wafers for materials
research. Ms. Tai also provided ECO with documentation confirming
delivery of the item to the Institute.


7. MOS is collocated with another company, namely Prima Research
and Technologies Ptd. Ltd. (Primaco). When asked about the company,
Ms. Tai stated that the two companies share space and a common
director but that Prima is involved in research and production
related to alternative health care products sold in Asia. She
provided the web address of the company as www.primaco.com. A
subsequent review of that web site reveals that this company is
apparently involved in a very similar business as MOS and not in
health care products production. It boasts U.S. and other offices,
some of which are collocated with other MOS offices. Other offices
are located at separate addresses. ECO requested clarification on
the nature of Primaco's business from Ms. Tai by subsequent e-mail.
She responded that she would respond when returning from maternity
leave. ECO will forward her response to OEA if/when it arrives.


8. While the information about the specific order in question and
about MOS's business appeared credible, ECO is concerned that other
exports apparently going to MOS customers may actually be destined
for Primaco customers (or vice-versa). ECO recommends a close
review of past licensed and unlicensed shipments to these two
companies.