EXTRANCHECK: POST-SHIPMENT VERIFICATION: ANALOGIC CONTROLS

UNCLAS NEW DELHI 001953 SIPDIS USDOC FOR 532/OEA/M. NICKSON-D/JAY HATFIELD USDOC FOR 3131/USFCS/OIO/ANESA/KREISSL USDOC FOR 4530/MAC/ANESA/OSA ICE HQ FOR STRATEGIC INVESTIGATIONS STATE FOR EB/ESP E.O. 12958: N/A TAGS: BEXP ETRD ETTC IN SUBJECT: EXTRANCHECK: POST-SHIPMENT VERIFICATION: ANALOGIC CONTROLS INDIA LIMITED, HYDERABAD, INDIA REF: USDOC 02445 ¶1. Unauthorized disclosure of the information provided below is prohibited by Section 12(c) of the Export Administration Act. ¶2. On June 11, 2008, Export Control Officer (ECO) Paul Cushman and FSN Shailendra Srivastava conducted a Post-Shipment Verification (PSV) at Analogic Controls India Limited (ACIL),Hyderabad. ¶3. BIS requested a PSV at ACIL, a private sector company located in Padmarao Nagar, Secunderabad. ACIL was listed as the ultimate consignee for eleven Industrial Grade Compass Modules manufactured by KVH Industries of Middletown, Rhode Island. Export License: No License Required. ECCN: 7A994. ¶4. ECO and FSN Srivastava met with Mr. K. Padmanabham, Managing Director, ACIL. ¶5. Padmanabham was not aware of BIS regulations and this was the first visit by BIS officials to his facility. He provided copies of the following documents relating to this transaction: ACIL Purchase Order, KVH Invoice, KVH Proforma Invoice, a receipt for duties paid to the Indian Customs Authority, and the Air Waybill. ¶6. Padmanabhan explained that ACIL is a trading company. This importation was made on behalf of the GOI's Defence Electronics Research Laboratory which falls under the Defence Research & Development Organization (DRDO). After receipt of the shipment, ACIL transferred ten of the compasses to DRDO. ECO verified the following documents relating to the transfer: DRDO Tender Notice, DRDO Purchase Order, ACIL Invoice, and Delivery Challan. The remaining compass is maintained by ACIL as a spare. ¶7. Padmanabhan presented the spare compass for inspection and ECO recorded its serial number as 070202536 (part number 01-0177-15). ¶8. Established in 1996, ACIL is a small company focused on providing high technology products and services (embedded systems, data acquisition, logging, process control instrumentation, automation systems, test & measurement equipment) to the cement, steel, petrochemical, pharmaceutical, defense, and space industries. ACIL has 80 employees. ACIL is located in a two-story dwelling in a residential neighborhood. A roving security guard is on duty at the facility 24/365. ¶9. Recommendation: Based upon a review of documents and information provided by Analogic Controls India Limited, it appears that this controlled technology was imported by a legitimate end-user and used in a manner consistent with the Export Administration Regulations. However, because a physical inspection of all but one of the items could not be performed, this Post-Shipment Verification remains mnconclusive. WHITE