EXTRANCHECK: POST SHIPMENT VERIFICATION:

UNCLAS HONG KONG 000928 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: INNOVATIVE POLYMERS PTE LTD. REF: A) USDOC 01385 B)D353591 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 Innovative Polymers Pte. Ltd., 31 UBi Road 1, No 01-00 Aztech Building, Singapore (Innovative Polymers). The item in question is carbon nanotube aggregate exported to Innovative Polymers on or about April 6, 2006 and October 11, 2007. The item is classified under Export Control Classification Number (ECCN) 1C010 and is controlled for national security reasons (NS). The exporter was Hyperrion Catalysis International, Inc. of Cambridge, Massachusetts. ¶3. According to the Singapore companies registry, Innovative Polymers was registered in 1996 and its registered share capital is the Singapore dollar equivalent of approximately USD 7.25 million. Its directors are Singapore citizen, See, Toh Wei-Meng and Singapore permanent resident Ng, Bee Keong. Messrs See and Ng are also the shareholders of the company as is Singapore permanent resident Lee, Sue Lin. ¶4. A review of the company's web site (www.Innovativepolymers.com) reveals that the company specializes in distribution of engineering plastics serving the hard disk drive and semi-conductor industries. Its also manufactures customized engineering plastics. The web site lists a wide range of products for which Innovative Polymers is a distributor. ¶5. On April 22, 2008, the ECO, accompanied by a representative of Singapore Customs, visited the company and met with Mr. Tan, Thiam Hock, Marketing Manager and Mr. Ng, Bee Keong, Managing Director. Mr. Ng provided an overview of the company. As noted on the web site, the company's target customers are hard disk manufacturers and semicon companies. Its products are used in industrial applications. Innovative Products sells finished and semi-finished products to an existing network of customers, not on the open market. ¶6. As to the particular item in question, Mr. Ng stated that the company is interested in the item for use in applications where static electricity is a concern. He stated that the nanotube product is quite expensive so, for the moment, it is only being used for research and development purposes. Hyperion is a regular supplier of this product and it applies for BIS licenses based on projections of annual need provided by Innovative Polymers. Mr. Ng confirmed that the company is aware of the applicable license conditions. ECO inspected the remaining product, much of which remained in its original packaging. ¶7. At the time visited, Innovative Polymers appeared to be a suitable recipient of the commodities shipped since Innovative Polymers cooperated with the PSV, provided ECO with access to the item and related documents and operates a line of business consistent with the use of the items. Also, Innovative Polymers is familiar with the applicable license conditions and expressed its commitment to comply with them.