EXTRANCHECK: POST SHIPMENT VERIFICATION: JSD BROAD

UNCLAS HONG KONG 002145 USDOC FOR 532/OEA/LHINES/JSALCIDO USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR PATRICK SANTILLO BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS SIPDIS E.O. 12958: N/A TAGS: BMGT BEXP HK ETRD ETTC SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: JSD BROAD ELECTRONIC (HK) CO. LTD. REF: A) USDOC 05607 B) HK 03088 (2007) C) USDOC 06569 ¶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 a post shipment verification (PSV) at JSD Broad Electronic (HK) Co. Ltd., Lot 89, Ping Ha Road, Fau Shan, Yuen Long, New Territories, Hong Kong (JSD Broad (HK)). The item in question is a 20T4G18A microwave amplifier exported to JSD Broad (HK) on or about December 24, 2007 and valued at approximately USD 42,000. The item is classified under Export Control Classification Number (ECCN) 3A001 and is controlled for national security (NS) reasons. Telecom Associates of Saratoga, California was the exporter. ¶3. A review of the Hong Kong Companies Registry reveals that JSD Broad (HK) has been in existence since May 2006. Its paid-up share capital is the Hong Kong equivalent of USD 1250. Its sole director and shareholder is Chinese mainland national, Xie, Jin. The Registry lists Xie, Jin's mainland identification card number as 510102196610187526 (with resulting birth date of October 18, 1966). Xie, Jin is not a director in any other company listed in the Hong Kong Companies Registry. The company's registered address is Room 1007, 10/F Ho King Ctr. No 2-16 Fa Yuen St, Mongkok, Hong Kong. ¶4. This same registered address is the registered address of a corporate secretarial services company named HKRTP Limited. That secretarial services company has offices in Hong Kong and in a range of cities in mainland China. When Commercial Assistant Carrie Chan called HKRTP, the company claimed that it had no record of JSD Broad (HK). ¶5. The registered address of HKRTP and JSD Broad (HK) is also the registered address of Mingxin Technology, a company that was the subject of a previous unfavorable PLC referenced in reftel B as well as a pending PSV referenced in reftel C. The PLC in reftel B involved pumps controlled for chemical and biological weapons reasons. As described further in reftel B, this address is located in an older office building. At the time the ECO visited this location, it was vacant. ¶6. Internet based background research reveals that JSD Broad (HK) is listed as the Asia sales representative of a company called GCP Microwave Technology Co. Ltd. (www.gcpmicrowave.com). A further review of the www.gcpmicrowave.com web site reveals that the company apparently has additional sales offices in Beijing (JSD Technology Co. Ltd.),Shanghai (JSD Technology Co. Ltd.),Canada (Amery Technology Ltd.) and the United States (JC Pacific Techology (sic.) Ltd.). Further internet research reveals that a JSD Technology Co. Ltd. is registered in Beijing as well. An additional company in Shanghai (Shanghai YQF Trading Co., Ltd.) is listed on Alibaba as selling microwave components, waveguide and other products. Its contact details are the same as those of JSD Technology in Shanghai (www.alibaba.com/member/siahairen/contactinfo .html) ¶7. An internet domain search reveals that the domain gcpmicrowave.com is registered by a Sunny Zhang of JSD Technology Ltd. Co., Room 207, The 4 West Building No. 83, Fuxing Rd, HaiDian District, Beijing. The registrant phone number is listed as +86 01051606950 and the registrant e-mail is listed as jesda@vip.sina.com. ¶8. FCS Commercial Assistant Carrie Chan attempted, on several occasions, to schedule the PSV. Often, the phone rang without answer. Eventually, a person answered the phone but declared that she knew nothing of JSD Broad (HK). She declined to give her name as well as the name of her company although she did confirm that the phone number provided in reftel A is located at the ship-to address for the shipment that is the subject of this PSV. ¶9. On September 5, 2008, ECO, ICE representative Stan Seto and Commercial Assistant Carrie Chan attempted to visit the address listed in reftel A. The address does not exist. A review of Shippers Export Declarations (SEDs) reveals that other shipments (from Radar Systems Technology in Mountain View California) have gone to companies named JSD Broad and JSD Broadband at another address in Hong Kong(ITN 20080108000269, ITN 20080225032474 and ITN 20080507019674),namely Flat B, 38/F, Tower 1, Banyan Garden, 863 Lai Chi Kok Rd., Kowloon, Hong Kong. This address is in a residential neighborhood. With shipping documents for these additional shipments, ECO may attempt to schedule an EUC at the Banyan Garden address. ¶10. ECO requested Hong Kong government assistance in finding and making contact with the company but, to date, Hong Kong Customs has been unable to do so. ECO will provide updated information when he receives it. ¶11. In light of the facts noted above, ECO does not believe the JSD Broad is a suitable recipient of U.S. origin technology. Donovan