EXTRANCHECK: POST-SHIPMENT VERIFICATION: MILLIONBOND

UNCLAS HONG KONG 000270 SIPDIS 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: MILLIONBOND TECHNOLOGY LIMITED REF: A) USDOC 00376 B) D370131 ¶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) conducted a post-shipment verification at Millionbond Technology Limited, Flat 2408-12, 24/F, Chun Shing Factory Estate, 85-89 Kwai Fuk Rd, Kwai Chung, N.T., Hong Kong (Millionbond). The items in question are 15 accelerometers exported to Millionbond on or about March 8, 2007 and valued at approximately USD 17,000. The accelerometers are the subject of export license D370131 and are classified under Export Control Classification Number (ECCN) 7A101. This ECCN is controlled for missile technology (MT) reasons. The exporter was Honeywell International Inc. of Redmond, Washington. ¶3. A review of Hong Kong Companies Registry reveals that Millionbond Technology Limited was registered in 1999 and has a registered capital of the Hong Kong equivalent of USD 40,000. Its directors are Hong Kong residents Hung, Hin Pong and Luk, Sui Fong as well as Lucky Engineering Company Limited. Mr. Hung is also a director of several other companies in Hong Kong including AEI Cables Limited, Lucky (HCMS) Limited and Lucky Engineering Company Limited. Mr. Luk is also a director in Artwave Decoration & Design Limited, Hong Kong Electrical Contractors' Association Limited, Hong Kong Walton Steel Pipe Industrial Limited, Koon Dwok Realty Limited, Lucky (Asia) Group Limited, Lucky E& M Limited, Lucky Engineering Company Limited, Ricox Engineering Limited, Super Sharp Company Limited, Super Wisdom Limited, Triple Smart Company Limited, Westson Electrical Supplies Limited and Westson Resource Limited. Lucky Engineering Company Limited was registered in 1981 and has registered capital of the Hong Kong equivalent of USD 8 million. ¶4. Millionbond does not have a web presence. Open source information reveals that Lucky Engineering Company Limited provides electrical engineering, building service engineering and engineering contracting services. ¶5. On January 29, 2008, ECO and Commercial Assistant Carrie Chan visited Millionbond at the address referenced above and met with Mr. Simon H.P. Hung, Executive Director. Mr. Hung provided business cards listing him as the Executive Director of Millionbond and Manager of Lucky Engineering Co., Ltd. ¶6. Mr. Hung provided a general overview of the corporate structure of the Lucky group of companies (including a company profile/brochure that includes extensive background on each of the companies and the scopes of their work). Specifically, Lucky Engineering Company Limited was founded in 1975 (it existed previously as Lucky Air-Conditioning and Electrical Company) to carry out various mechanical and electrical projects both in Hong Kong and China. The Lucky Group of companies also holds a range of other companies including Lucky E&M Limited, Westson Electrical Supplies Limited, Artwave Decoration and Design Limited and Millionbond Technology Limited. Millionbond was founded ten years ago to compete on certain high-tech projects. Information provided by Mr. Hung was consistent with information provided by OEA and independently obtained by the ECO. ¶7. As to the specific items in question, Mr. Hung stated that these had been procured in fulfillment of a project funded by the Hong Kong Highways Department. In particular, the accelerometers were installed in the recently completed bridge linking Hong Kong and Shenzhen, mainland China. Mr. Hung provided documentation confirming payment by the Hong Kong Government for five sets of tri-axial accelerometers (each set has three accelerometers, according to Mr. Hong). The accelerometers were installed to measure the movement of the bridge resulting from wind. Mr. Hung also confirmed that Millionbond had received a Hong Kong Government import license for the items. Cunningham