EXTRANCHECK: POST SHIPMENT VERIFICATION: COREZING

UNCLAS HONG KONG 002249 USDOC FOR 532/OEA/LHINES 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: COREZING INTERNATIONAL HK CO., LTD., HONG KONG J&T ELECTRONIC, ACTION GLOBAL, WIN SINO CARGO (H.K.) LTD. REF: A) EUC request 01210070 B) EUC request 01210069 C) EUC request 01210071 D) EUC request 01210072 E) EUC request 01210073 F) EUC request 01210079 G) EUC request 01210080 G) EUC request 01210081 ¶1. Unauthorized disclosure of the information provided below is prohibited by Section 12C of the Export Administration Act. ¶2. As per reftels A-G 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) conducted eight post shipment verifications (PSVs) of shipments destined to Corezing International Co., Ltd. (Corezing),Hong Kong J&T Electronics (J&T Electronics) and Action Global Co. Ltd. (Action Global). All of these shipments were shipped to Win Sino Cargo (H.K.) Ltd., Flat 12, 9/F, Po Hong Centre, Hong Kong (Win Sino) and are therefore grouped together in this cable. The items in question for these PSVs are various hydraulic pumps, low noise amplifiers, specialty wire products and connectors, fixed capacitors, fiberglass tape, Dupont Paralux tape exported to Corezing, J&T Electronics and Action Global in 2008 and 2009. For one of the shipments, the items are classified under Export Control Classification Number (ECCN) 3A001b2d, meaning that they are controlled for national security reasons and would require a license for export/reexport to mainland China but may be shipped license free if for use in Hong Kong. The remaining shipments are classified by the exporters as EAR99 and, if properly classified, can be shipped to virtually all destinations and end users worldwide except sanctioned countries and restricted entities and individuals. ECO understands some items were likely improperly classified by the exporters and that their classification may be higher than EAR99. ¶3. According to the Hong Kong Companies Registry, Corezing has been in existence since July 2007. Its paid up share capital is the Hong Kong equivalent of USD 65,000. The Hong Kong Companies Registry lists Luo, Jie (with Mainland passport number 441481198206082304) and Zhou, Zhenyong (with Mainland passport number 441900198910161558) as directors. As relayed separately to BIS, Corezing in Hong Kong is related to a range of Hong Kong and Singapore based companies. Those companies are the subject of ongoing investigations and a recently published temporary denial order (TDO). That TDO restricts the ability of those companies to acquire products that are subject to the Export Administration Regulations (EAR). ¶4. According to the Hong Kong Companies Registry, Ms. Luo, Jie is the director and sole shareholder of Action Global. This company has been in existence since March of 2009. It has no paid up share capital. J&T Electronics has been in existence since October 2007 and its share capital is the Hong Kong equivalent of USD 1250. Its director is Zheng, Hu Xin. As separately conveyed to BIS, these companies are related to multiple additional companies in Hong Kong, mainland China and Singapore. According to e-mail correspondence with Ms. Luo, Jie, Action Global and Corezing are business partners and the boss of J&T Electronic is a friend of Ms. Luo, Jie. ¶5. Background research on Win Sino reveals that it is a freight forwarder and logistics provider (more information at www.winsino.com). Corporate background on the company has been sent separately to OEA. It does not appear that Win Sino and the companies referenced above are related at the corporate level. Win Sino is located in a multistory warehouse and offices building in a warehouse district of Hong Kong. It is collocated with Oriental Distribution, another freight forwarding company. The interior of Win Sino is approximately 500 square feet in size with space for multiple cubicles and two small offices. ¶6. On October 9, 2009, ECO, ICE representative Steven Leisure and FCS Commercial Assistant Carrie Chan visited Win Sino and interviewed Mr. Joe Tam, Win Sino's Marketing Manager. ECO was initially slated to meet with Ms. Flora Lee, who is listed on documentation as being responsible for various orders. However, according to Mr. Tam, Ms. Lee's English is not very good so Mr. Tam would be the responsible person to answer questions. From time to time, Mr. Tam conferred with Ms. Lee before answering questions. Ms. Chan provided translation assistance to Mr. Tam as his English was also limited. ¶7. PSV 01210070 and ITN 20081126080393 As to this shipment for ultimate consignee Hong Kong J&T Electronics, Mr. Tam stated that Win Sino had no delivery receipt or similar documentation to share with the ECO. Mr. Tam stated Win Sino had not met Mr. Benny Zhou who is listed as the point of contact for this shipment in the applicable order documentation nor do they know who he is (nor do they recognize the phone number listed on the airway bill). Tam stated that a customer named Ivy provided them with an airway bill number to alert them that the item was coming. ECO believes this individual to be Ms. Luo, Jie referenced above. Mr. Tam later confirmed that Ivy is actually Ms. Luo, Jie (hereafter, she is described as either Ms. Luo, Jie or Ivy). According to Mr. Tam, Ms. Luo, Jie represents many companies although Mr. Tam stated that he does not know the company names since they only see the cargo and not the underlying purchase orders or invoices. ¶8. Mr. Tam further stated that Win Sino does not have a written agreement with a Ms. Luo, Jie to accept packages on her behalf. Mr. Tam stated that Ms. Luo, Jie pays Win Sino monthly by wire transfer for their services. Win Sino receives approximately HKD 200 per shipment. Mr. Tam stated that Win Sino receives approximately one shipment per week on Ms. Luo Jie's behalf. Mr. Tam further stated that Win Sino has been working with Ms. Luo, Jie for approximately one year. Mr. Tam claimed not to have a phone number or business card for Ms. Luo Jie. Mr. Tam further stated that she had approached the previous marketing manager (before Mr. Tam) for a quotation and it was in this manner that Ms. Luo, Jie became Win Sino's customer. Mr. Tam stated that Ms. Luo, Jie speaks Cantonese and is likely a mainland Chinese national. ¶9. One contact number provided for Benny Zhou of J&T Electronics is a mainland China number. Consistent with ECO practice, no calls were made to mainland China to attempt to reach Mr. Zhou. Calls to Hong Kong J&T Electronics at a different number (2389 2981) were answered by a corporate secretarial service. That service confirmed that Hong Kong J&T Electronics is a customer but messages left for J&T with this service were not returned. ¶10. EUC request 01210069 and ITN 20081231019678 As to a second shipment to J&T Electrics, Mr. Tam provided a commercial invoice attached to an e-mail chain. That e-mail chain includes several names as copied parties including Peace Wong, Wallace Lo, Eric Lim, Thomas, and Ivy-Corezing (ivy@corezing.com). The e-mails made reference to a Fedex shipment with tracking number 792145339599 which corresponds to the Fedex tracking number for this shipment. The subject line of this e-mail states 38th.......USA --.Winsin ---. Iran. One such e-mail is addressed to oceanoperation and the text of the message starts with, Dear Flora, which is the Flora Lee of Win Sino referenced above. The correspondence reflects the structure of shipments detailed by Mr. Tam above (whereby Win Sino accepts shipments for Ivy (aka Ms. Luo, Jie). ¶11. Mr. Tam stated that Mr. Peace Wong is the director of Win Sino and that Wallace Lo works for Win Sino. Mr. Tam claimed to be unable to procure the e-mail addresses of the person named Thomas in the e-mail or Eric Lim who is also copied on the e-mail (ECO does not believe this statement to be credible). ¶12. Mr. Tam also claimed ignorance as to why the e-mail chain referenced a shipment to Iran. He stated that Win Sino only passes goods to Ivy. In fact, Ivy does not actually come to Win Sino. Rather, a courier introduced by Ivy comes to collect the packages. Mr. Tam stated that Win Sino never ships items for Ivy. When pressed as to how it is possible that Win Sino would accept multiple shipments for a virtual stranger without exchange of documentation of any kind, Mr. Tam stated that the relationship was based on trust. ¶13. As to the courier, Mr. Tam stated that the courier had been introduced to Win Sino by Ms. Luo, Jie herself and had been the courier in all of its shipments. Mr. Tam stated that he assumes that Ms. Luo, Jie received the shipments since she has never complained about not receiving any particular shipment. ¶14. When asked how Win Sino is able to track shipments for Ms. Luo, Mr. Tam stated that Win Sino tracks those shipments by checking the airway bill or comparable number. This is why Win Sino was able to confirm receipt of the shipments that were the subject of the meeting (by phone, Ms. Lee of Win Sino had confirmed receipt of several shipments). When asked whether Win Sino could therefore pull all shipments destined for Ms. Luo, Jie, Mr. Tam stated that there was some problem with this and that data had been lost from Ms. Lee's computer. Therefore, this would not be possible. ¶15. EUC 01210071/ITN 20090213060650 and EUC 01210072/ITN2009119038469 As to these two shipments destined for Corezing (but shipped to Win Sino),Mr. Tam confirmed that Win Sino had received these shipments. ECO has requested a follow-up meeting to attempt to obtain information on the final disposition of these two shipments but has, to date, been unable to arrange a meeting. ¶16. By separate e-mail correspondence, Ms. Luo Jie provided additional information concerning these two shipments (she declined to meet with the ECO citing extensive travel through China). According to Ms. Luo, Jie's e-mails, both items were destined to Sichuan Chengdu LingSheng Co. In the first case (EUC 01210071),the items were destined for use in a high gain LNA amplifier module and multiplier module. In the second case (EUC 01210072),the items were destined for use in the signal transmission and power supply of telecommunication equipment. Ms. Luo, Jie also provided purported purchase orders that will be forwarded to OEA separately. ECO did not find Ms. Luo, Jie's information or documentation to be credible. Open source research did not reveal any web presence for Sichuan Chengdu LingSheng Co. ¶17. EUC 01210073/ITN 20090716035455 As to this shipment destined for Action Global, Mr. Tam stated that Ivy had also brought this order to Win Sino. Mr. Tam stated that he did not know Alvin Stanley (the point of contact on the order) or Action Global. Mr. Tam stated that Win Sino had received this package addressed to Action Global and that it had gone out two days later. Mr. Tam stated that he did not know whether it had gone to Ivy or not. Mr. Tam declined to provide the name of the courier that had picked up the package. When asked to track the shipment through Win Sino's records, Mr. Tam stated that the data had recently been lost on the company's computers and so could not be received. ¶18. ECO attempted, on several occasions, to set up a meeting with Action Global. Correspondence from Rose at Action Global suggests a web site for this company, namely www.actionsmt.com. The Action Global web site states that Action Global is a global supplier of quality used and refurbished SMT (surface mount technology) equipment. Rose stated in her correspondence that the company was winding up and that she was therefore unable to meet with the ECO. She offered to provide relevant shipping documentation but never produced such documentation. To date, ECO has been unable to arrange a meeting or obtain further information from Action Global. ¶19. EUC 01210079/ITN20090622004990, EUC 01210080/ITN20090805013323, EUC 01210081/ITN20090713024615 These three shipments were likewise destined to Corezing and apparently shipped to Win Sino. ECO did not raise these three shipments with Win Sino at the October 9, 2009 meeting. Mr. Tam of Win Sino spoke with Commercial Assistant Carrie Chan after that meeting and stated that he was unable to find documentation for two of the three shipments. By separate e-mail, Ms. Luo, Jie confirmed receipt of the three shipments. The three shipments were also purportedly for Sichuan Chengdu LingSheng Co. In the case of the shipment from EUC 01210079, Ms. Luo, Jie wrote that the purported end use was for a port of microwave product or microwave. According to Ms. Luo, Jie, the shipment from EUC 01210080 was for use in the adhesion of metal cases bonding. In the third case (EUC 01210081),Ms. Luo, Jie wrote that the end use was to produce a multi-layer PCB. ¶20. ECO has attempted, for several weeks to set up a meeting with Peace Wong, Director of Win Sino without success. ECO has likewise not had any luck in setting up a follow-up meeting with Mr. Tam. ¶21. ECO believes Corezing, Action Global, J&T Electronic and Win Sino to be a unsuitable recipients of U.S. origin technology. ECO recommends a close review of all shipments to these companies and their respective addresses.