Identifier
Created
Classification
Origin
09HONGKONG526
2009-03-20 07:36:00
UNCLASSIFIED
Consulate Hong Kong
Cable title:  

EXTRANCHECK: POST SHIPMENT VERIFICATION: RICH LONG

Tags:  BMGT BEXP HK ETRD ETTC 
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VZCZCXYZ0003
RR RUEHWEB

DE RUEHHK #0526 0790736
ZNR UUUUU ZZH
R 200736Z MAR 09
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 7200
RHMFIUU/HQ BICE WASHINGTON DC
UNCLAS HONG KONG 000526 

USDOC FOR 532/OEA/MNICKSON/ADYSON
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: RICH LONG
LOGISTICS, LTD

REF: A) USDOC 00153

UNCLAS HONG KONG 000526

USDOC FOR 532/OEA/MNICKSON/ADYSON
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: RICH LONG
LOGISTICS, LTD

REF: A) USDOC 00153


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 Rich Long Logistics, Ltd., O/B
Uni Shine Marine Co. Ltd., 6/F Wah Tat Industrial Center, 8-10
Wahsing Street, Hong Kong (Rich Long). The items in question for
this PSV are outboard marine propulsion engines and a bow thruster
system exported to Rich Long on or about February 28, 2007. While
the applicable export control documentation does not list an export
control classification number (ECCN),it is likely that these items
can be shipped license free to virtually all destinations and
end-users worldwide except certain sanctioned countries and
restricted entities and individuals. The exporter was Wesmar
Western Marine Electronics of Woodinville, Washington.


3. According to the Hong Kong Companies Registry, Rich Long has
been in existence since 2001. Its paid up share capital is the Hong
Kong equivalent of USD 12500. The Hong Kong Companies Registry
lists two Hong Kong residents as directors, namely Kao, Shih Yi and
Lin, Chien Kuo Gery.


4. A review of the company's web site (www.Rich Longlogistics.com)
reveals that Rich Long is a logistics services company with
operations in Hong Kong, Taiwan and mainland China. It provides a
range of services including warehousing, customs operations,
insurance, global tracking and computerization, among others.


5. On February 26, 2009, ECO accompanied by Commercial Assistant,
Carrie Chan, visited Rich Long and met with Ms. Carmen, an account
manager. She provided background on the Rich Long consistent with
the information on the company's web site. From ECO's observation,
it appears that approximately 20-25 staff work at the company's
office. Ms. Carmen stated that Rich Long provides a range of
freight forwarding and related services for the China market. When
asked, Ms. Carmen did not appear to know anything about Hong Kong
Strategic Commodities licenses and ECO assumes the company does not
apply for licenses. Note: Only items on Hong Kong's strategic
commodities control list would require a license for import into
Hong Kong or export from Hong Kong. ECO informed Ms. Carmen that
U.S. export controls apply to U.S. origin items and subsequently
provided her with additional information about those controls.

6. As to the specific transaction in question, Ms. Carmen stated
that she was unable to locate the underlying documentation for this
shipment. She stated that shipping documentation is kept on hand
for one year and then shipped to the company's warehouse in the
mainland. She further stated that the customer and ultimate
consignee, Uni Shine Marine, is a regular customer of Rich Long. It
manufactures boats in Zhuhai, mainland China. Ms. Carmen stated
that she is unaware of Uni Shine's customers. A web search of Uni
Shine reveals that it is apparently an affiliate or subsidiary of
Taiwan firm Her Shine Marine which, among other things, builds
yachts in partnership with Jefferson Marine in Jeffersonville,
Indiana. ECO has no reason to doubt that the items were actually
shipped to Uni Shine.


7. Based on the information noted above, ECO believes the items did
reach the buyer listed on the applicable export documentation
(namely Uni Shine Marine Co. Ltd.). ECO is less sanguine about the
suitability of Rich Long to be the recipient (as logistics provider)
of controlled U.S. origin technology. ECO can make no
determination as to the suitability of the apparent ultimate
consignee Uni Shine Marine Co. Ltd.