Identifier
Created
Classification
Origin
09HONGKONG1010
2009-06-04 08:46:00
UNCLASSIFIED
Consulate Hong Kong
Cable title:  

EXTRANCHECK: POST SHIPMENT VERIFICATION: NABOND TECHNOLOGY

Tags:  BMGT BEXP HK ETRD ETTC 
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VZCZCXYZ0001
RR RUEHWEB

DE RUEHHK #1010 1550846
ZNR UUUUU ZZH
R 040846Z JUN 09
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 7756
RHMFIUU/HQ BICE WASHINGTON DC
UNCLAS HONG KONG 001010 

USDOC FOR 532/OEA/MHAMES/LLAUCIUS
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR PATRICK SANTILLO
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS

SIPDIS

E.O. 12958: N/A
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: NABOND TECHNOLOGY
HK CO LTD

REF: A) BIS e-mail request dated April 22, 2009
UNCLAS HONG KONG 001010

USDOC FOR 532/OEA/MHAMES/LLAUCIUS
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR PATRICK SANTILLO
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS

SIPDIS

E.O. 12958: N/A
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: NABOND TECHNOLOGY
HK CO LTD

REF: A) BIS e-mail request dated April 22, 2009

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 (PSV) at Nabond Technology HK, Co.,
Ltd., Unit 1001, Forseas Bldg, 208-212 Nathan Road, Hong Kong
(Nabond). The items in question for this PSV are 10 pieces of Duocel
silicon carbide ceramic exported to Nabond on or about October 10,

2008. On the applicable shippers export declaration (SED),these
items are not classified meaning that they are likely EAR99 and
eligible for shipment to virtually all destinations and
end-uses/users worldwide. The exporter was ERG Materials and
Aerospace of Oakland California.


3. According to the Hong Kong Companies Registry, Nabond has been
in existence since 2007. Its paid up share capital is the Hong Kong
equivalent of USD 13. The Hong Kong Companies Registry lists
Chinese Mainland national, Zhang, Chuanyi, as director (with
mainland China passport number 440106197770809184X).


4. According to the company's web site (www.nabond.com),Nabond is
a R&D company focusing on the manufacture and application of nano
materials, adhesives and related machines. The company's contact
details listed on its web site make reference to a Shenzhen address
and phone number. According to the company's web site, it is able
to provide a range of nano-materials for sale.


5. On May 27, 2009, ECO accompanied by Commercial Assistant, Carrie
Chan, visited Nabond and met with Mr. Tom Lee, General Manager. The
meeting occurred at the offices of company secretarial service
company, ATA Corporate Formation & Management Limited. The ship to
address on the ERG shipping documents (as distinct from the ATA
address) corresponds to the address of freight forwarder Safe
Velocity Express Ltd. Mr. Lee's office within ATA had a sign above
the doorway indicating that it was the office of Nabond. ECO
suspects this was done to give Nabond the appearance of having a
Hong Kong operation when, in fact, it has no real Hong Kong
presence.


6. According to Mr. Lee, Nabond ordered the items in question to
use in the research and development of very light ceramic products
able to withstand up to 1000 degree temperatures. These would be
used in vehicle engine applications. Mr. Lee stated that the
company has a range of overseas customers including Unico and BASF.
In fact, Mr. Lee stated that few domestic Chinese companies have an
interest in his company's products and he therefore produces
primarily for export. Mr. Lee stated that he has no government
customers and stated further that government agencies would see his
company as too small to deal with. Mr. Lee stated that his company
has eight staff.


7. When asked about the disposition of the items, Mr. Lee stated
that they had been for use at the company's R&D lab in Hong Kong.
When asked for an address, Mr. Lee demurred, claiming that the
location of the Hong Kong lab was a trade secret.





8. Based on the information noted above, ECO believes that Nabond
most likely does not have any permanent Hong Kong presence and uses
its Hong Kong address to receive shipments and correspond with
international clients and suppliers. While there is no apparent
export control violation associated with this shipment, ECO
nonetheless does not believe Nabond to be a suitable recipient of
controlled U.S. origin technology.