EXTRANCHECK: POST SHIPMENT VERIFICATION: BOSCH SECURITY

UNCLAS HONG KONG 001507

USDOC FOR 532/OEA/LHINES/ADYSON
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: BOSCH SECURITY
SYSTEMS LTD

REF: A) USDOC 03399

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) attempted
to conduct post shipment-verifications (PSV) at Bosch Security
Systems Ltd., 12/F Metropole Square, 2 On Yiu Street Shatin, Hong
Kong (Bosch). The items in question are 1000 semiconductors exported
to Bosch on or about March 31, 2006 and valued at USD 20,790. On the
applicable shippers export declaration (SED),these items are
classified as EAR99 and, if properly classified, can be
exported/reexported to virtually all destinations and end-users
(except certain sanctioned countries and restricted end-users/uses).
The exporter was Rochester Electronics of Newburyport,
Massachusetts.


3. According to the Hong Kong Companies Registry, Bosch has been in
existence since 1994. Its paid up share capital is the Hong Kong
equivalent of USD 300,000. U.S. nationals Eric Behlke George and
Christopher Paul Gerace and German national Uwe Glock are listed as
directors. Bosch in Hong Kong is part of the Bosch Group, an
international global supplier of automotive and industrial
technology, consumer goods and building technology. The Group has
more than 270,000 employees. Bosch in Hong Kong provides a range of
products in the security field including intrusion systems, motion
detectors and fire alarms as well as analog and digital video
systems and components (www.boschsecurity.com.hk).


4. Commercial Assistant Carrie Chan attempted for some time to
arrange a time to conduct the PSV. Eventually, Ms. Chan was able to
speak with Mr. Jack Watt at Bosch who explained that the Bosch Hong
Kong operation is now only a sales office and it does not have
information about past shipments (that came through Bosch when the
Hong Kong operation still handled logistics matters for the Bosch
China operation). Since the time of the shipment in question, Bosch
has outsourced its logistics operations in Hong Kong to DHL.


5. Steven Wong of DHL was able to locate and provide to ECO copies
of documentation regarding the shipment in question. That
documentation confirmed that the items in question had been received
by Bosch's warehouse in Hong Kong. According to Mr. Wong, the
documents confirming subsequent reexport to mainland China for use
in Bosch's manufacturing process were lost when Bosch's logistics
operations were outsourced to DHL. ECO finds Mr. Wong's explanation
to be credible.


6. At the time visited, Bosch appeared to be a suitable recipient
of the subject commodities as it cooperated with the PSV and is
involved in production of various products that likely make use of
electronic components such as the ones that were the subject of this
PSV.