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.