EXTRANCHECK: POST SHIPMENT VERIFICATION: BIOMERS PTE. LTD.

UNCLAS HONG KONG 000816 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: BIOMERS PTE. LTD. REF: A) USDOC 01391 B) D372838 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 Biomers Pte. Ltd., B Prince George's Park, Singapore (Biomers). The item in question is S2 glass triaxial braided sleeve exported on or about June 22, 2007 and valued at USD 4,000. The item is classified under Export Control Classification Number (ECCN) 1C210 and is controlled for nuclear nonproliferation (NP) reasons. The exporter was A and P Technology, Inc. ¶3. According to the Singapore companies registry, Biomers has been in existence since 2005. Its paid-up share capital is the Singapore equivalent of USD 2.8 million. U.S. national Randall Jay Wall, Canadian George Jim Aliphtiras and Singaporeans Tham Chee Kuan and Mervyn Tathiianathan are listed as directors. ¶4. On April 21, 2008, the ECO, accompanied by a representative of Singapore Customs visited the company and met with Ms. Renuga Gopal, Vice President, Product Development. Ms. Gopal stated that the company's business focuses on orthodontic products. In particular, the company designs and produces aesthetic orthodontic wires. It is a small operation in Singapore and the ECO viewed the three-room production facility. The Singapore operation is an affiliate of U.S. company Biomers Products, LLC located in Naples Florida (www.biomersbraces.com). ¶5. As to the particular item in question, Ms. Gopal stated that the company had considered using it as part of retainers and braces but had not been successful. Presently, the company is using S-2 unidirectional glass product it obtained pursuant to USDOC license D358827. Ms. Gopal produced the item that was subject to the check for review. It was wrapped in four spools of which only one spool had been opened. ECO reviewed the documentation and found it to be in order. ECO also advised Ms. Gopal that prior approval from BIS was required for any resale or reexport of the product as stipulated in the applicable license conditions. ¶6. At the time visited, Biomers appeared to be a suitable recipient of the commodities shipped since Biomers cooperated with the PSV, provided ECO with access to the item and operates a line of business consistent with the item's use. Also, Biomers was informed of the applicable license conditions and indicated its intent to comply with the conditions and U.S. export controls more generally.