EXTRANCHECK: POST SHIPMENT VERIFICATION: BESCOM COMPUTER

UNCLAS HONG KONG 000822

USDOC FOR 532/OEA/MNICKSON /DMUSLU
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: BESCOM COMPUTER
SYSTEMS PTE LTD

REF: A) USDOC 02452

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 Bescom Computer
Systems Pte. Ltd., 8 Boon Lay Way, No. 08-09 Tradehub 21, Singapore
609964 (Bescom). The item in question is one Gimbal camera exported
to Bescom on or about December 3, 2007 and valued at USD 17,346.
The item is classified under Export Control Classification Number
(ECCN) 6A004.D3 and is controlled for national security (NS)
reasons. The exporter was Cloud Cap Technology of Hood River,
Oregon.


3. According to the Singapore companies registry, Bescom was
registered in 1991 and its registered share capital is the Singapore
dollar equivalent of approximately USD 150,000. Its directors are
Singapore citizens Yak, Hock Hwa, and Yak, Bee Hua. Yak, Bee Hua
and Yak, Lay Hwa are also the shareholders of the company. It is a
family business.


4. A review of the company's web site (www.bescom.com.sg) reveals
that the company is primarily an IT systems integrator for corporate
customers. It is also involved in import and export of hardware
products in Southeast Asia.


5. On April 21, 2008, the ECO, accompanied by a representative of
Singapore Customs visited the company and met with Mr. Yak, Hock
Hwa, Managing Director. Mr. Yak confirmed that the company acts
primarily as a system integrator and solutions provider. It sets up
local area networks, file servers and other similar systems for
corporate and government customers. It also acts as a sourcing
agent for some government agencies (that cannot purchase direct from
abroad but must deal with Singaporean companies in accordance with
procurement rules). In addition, the company also sells
internationally to other Southeast Asian countries such as Vietnam
and China as well as the UAE (but not Iran, according to Mr. Yak).
Customers from abroad come to the company because of its listing in
certain export related trade publications. Additionally, when
Bescom has stock that other local distributors cannot obtain
quickly, those distributors (such as HP) may refer customers to
them.


6. As to the particular item in question, Mr. Yak stated that this
item had been procured on behalf of Nayang Technological University
in response to an RFQ from the University. Mr. Yak provided
documentation confirming receipt of the item and delivery to the
Main Aircraft Laboratory, School of Mechanical & Aerospace
Engineering at the Nayang Technological University. According to
Mr. Yak, Cloud Cap Technology is not a regular supplier.


7. At the time visited, Bescom appeared to be a suitable recipient
of the commodities shipped since Bescom cooperated with the PSV,
provided ECO with access to documents showing final disposition of
the items and operates a line of business consistent with the use of
the items. Also, Bescom was informed of applicable export control
rules (especially those relating to reexports to sanctioned
countries) and indicated its intent to comply with them.