EXTRANCHECK: POST SHIPMENT VERIFICATION:

UNCLAS HONG KONG 001059

USDOC FOR 532/OEA/MCANNER/MHAMES
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:
ASKEY TECH LIMITED; JOINTWAY ELECTRONICS LTD.; WINSUNY TECH (HONG
KONG) LTD.

REF: A) BIS EUC request e-mails dated May 26, 2009; B) HK 01087
(2008) regarding Winsuny and Cam-IC; C) HK 00604 (2009) regarding
Techwing, Askey and Jointway; D) HK 002146 regarding Cam-IC, Winsuny
and Techwing



1. Unauthorized disclosure of the information provided below is
prohibited by Section 12C of the Export Administration Act.


2. As per reftel A requests 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) attempted
to conduct post shipment-verifications (PSVs) at three Hong Kong
consignees, namely (1) Askey Tech Limited, Units 701-703, 7/F Shing
Yip Industrial Building, 19-21 Shing Yip Street, Hong Kong (Askey);
(2) Jointway Electronics Ltd. at the same address (Jointway); and
(3) Winsuny Tech (Hong Kong) Ltd., Rm 1405 A, Chungkiu Commercial
Building, 47-51 Shantung Street, Mong Kok, Hong Kong (Winsuny). The
items in question include a range of electronic components and, in
one instance, acoustic beacons sent to these consignees by a range
of U.S. exporters. On the applicable shippers export declarations
(SEDs),most of the items are classified under export control
classification number (ECCN) 3A001 and, if properly classified,
would be controlled for national security (NS) reasons. Based on
documentation provided by the exporters, in some instances, it
appears that the applicable items are of the class that may be
exported license free to Hong Kong, but would require a license for
export or reexport to mainland China because of their ability to
function at extreme temperatures (ECCN 3A001a2c). Each consignee
(and related shipments) is considered in turn below.


3. As detailed in reftels B-D, Askey, Jointway and Winsuny are
related to each other and to additional companies Cam-IC and
Techwing Electronics Limited through common ownership or course of
dealing. Winsuny, Techwing and Cam-IC were the subject of prior
unfavorable end use checks involving diversion of national security
controlled commodities to mainland China (summarized in reftels
B-D). Additional information about all of these companies can be
found in the applicable cables and is therefore not repeated
herein.


4. Jointway Electronics Limited Shipments Summary: The first
shipment for these PSVs included an acoustic beacon exported to
Jointway by Dukane Corporation of St. Charles, Illinois. Dukane
Corporation classified the beacon as falling under ECCN 6A991 which
is controlled for anti-terrorism reasons (AT) and may be exported to
Hong Kong and mainland China without a license unless end-use and
end-user restrictions apply. The second shipment involved
electronic components exported to Jointway by SG Industries of
Beverly, Massachusetts. SG Industries classified the components
under ECCN 3A001 which is controlled for national security (NS)
reasons.


5. Jointway PSV Results: Commercial Assistant Carrie Chan
attempted, on multiple occasions to schedule a meeting with
Jointway. The Hong Kong Post Office confirmed that Jointway
received the ECO's written request for a meeting. While Ms. Chan
was able to make an initial contact with the company and request a
meeting, subsequent calls went unanswered. ECO believes that as a
result of the PSV detailed in reftel C, Jointway will not agree to
meet with the ECO. Should that change, ECO will inform OEA.


6. Askey Tech Limited Shipments Summary: The first two shipments
for these PSVs were sent by Azego Technology Services of Upper
Saddle River, New Jersey while the third shipment was sent by Digi
Key Corporation of Thief River Falls, Minnesota. Digi-Key
classified its shipments of electronic components under ECCN 3A001a5
which is controlled for national security (NS) reasons and is of the
class of items that may be exported license free to Hong Kong, but
would require a license for export or reexport to mainland China.
Azego classified its items as EAR99, meaning that those items may be
shipped to virtually all end users (uses) worldwide license free.
In its order documentation with Digi-Key, Askey claims that it is
purchasing the applicable items for Techwing. One Azego shipment is
in response to a Techwing purchase order (listing the ship to
address as Askey but at the Winsuny location) while the second order
documentation lists, alternatively, Askey and Techwing as the
purchaser. ECO recommends a close review of this order
documentation.


7. Askey PSV Results: Commercial Assistant Carrie Chan attempted,
on multiple occasions to schedule a meeting with Askey. The Hong
Kong Post Office confirmed that Askey received the ECO's written
request for a meeting. Ms. Chan calls to Askey went unanswered.
ECO believes that as a result of the PSV detailed in reftel C, Askey
will not agree to meet with the ECO. Should that change, ECO will

inform OEA.


8. Winsuny Tech Shipments Summary: These PSVs involve five
shipments by four exporters. All shipments involve electronic
components controlled under ECCN 3A001 and controlled for national
security (NS) reasons. Two shipments, from Rochester Electronics,
involve electronic components classified under ECCN 3A001a2c. That
ECCN may be exported license free to Hong Kong but would require a
license for shipment to mainland China. Rochester Electronics
shipments have been the subject of multiple unfavorable end use
checks involving a range of electronics resellers in Hong Kong. ECO
finds it noteworthy that the Winsuny order documents for these two
shipments both list the Winsuny Hong Kong address as well as the
Winsuny Shenzhen address. Additional shipments of ECCN 3A001
electronic components were made by CMB Components of Holbrook, New
York, Electronic Expediters of Camarillo, California and Microram
Electronics, Inc. of Oldsmar, Florida.


9. Winsuny PSV Results: Commercial Assistant Carrie Chan
attempted, on multiple occasions to schedule a meeting with Winsuny.
Initial calls were quite short and were but off after a few
seconds. Eventually, after several days of trying by Ms. Chan, the
phone was listed as disconnected. The Hong Kong Post Office
confirmed that Winsuny received the ECO's written request for a
meeting. ECO believes Winsuny will not agree to meet with the ECO.
Should that change, ECO will inform OEA.


10. All three consignees are unsuitable recipients of U.S. origin
controlled technology. ECO recommends that BIS reach out to the
exporters to determine what they knew about the final destination of
their shipments to Winsuny when those shipments were made.