Identifier
Created
Classification
Origin
09HONGKONG527
2009-03-20 07:36:00
UNCLASSIFIED
Consulate Hong Kong
Cable title:  

EXTRANCHECK: POST SHIPMENT VERIFICATION: WT

Tags:  BMGT BEXP HK ETRD ETTC 
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VZCZCXYZ0004
RR RUEHWEB

DE RUEHHK #0527 0790736
ZNR UUUUU ZZH
R 200736Z MAR 09
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 7201
RHMFIUU/HQ BICE WASHINGTON DC
UNCLAS HONG KONG 000527 

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: WT
MICROELECTRONICS CO., LTD

REF: A) USDOC 00130

UNCLAS HONG KONG 000527

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: WT
MICROELECTRONICS CO., LTD

REF: A) USDOC 00130


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 WT Microelectronics Co., Ltd.,
9/F Shield Industrial Center 8, Hong Kong (WT). The item in question
for this PSV is one C-DDS synthesizer evaluation board exported to
WT on or about May 8, 2008. On the applicable shippers export
declaration (SED),the item is classified as EAR99, meaning that, if
properly classified, it could be exported/reexported license free to
virtually all destinations and end-users worldwide. Internal
documentation from the exporter states that the item in question is
classified under export control classification number (ECCN) 3A002.
This ECCN is one of a group of ECCNs that do not require a license
for export/reexport to Hong Kong but may require a license to
mainland China. The exporter was Analog Devices of Norwood,
Massachusetts.


3. According to the Hong Kong Companies Registry, WT has been in
existence since 1998. Its paid up share capital is the Hong Kong
equivalent of USD 100 million. The Hong Kong Companies Registry
lists several Taiwanese nationals as directors.


4. A review of the WT's web site (www.wtmec.com) reveals that WT
specializes in the distribution of electronic components. It is a
Taiwan based company with offices throughout the Asia pacific
region.


5. On February 23, 2009, ECO visited the company at the address
noted above and met with Kevin Lau, Associate Manager. He stated
that the Hong Kong operation of the company operates primarily as a
warehouse and back-office support operation for the company's
operations. WT does not have local, Hong Kong, customers. Mr. Lau
stated that WT applies for Hong Kong export licenses when their
suppliers tell them that the items in question may be subject to
control. Mr. Lau also stated that, from time to time, he checks the
Hong Kong Trade and Industry (TID) Department web site that lists
items subject to Hong Kong strategic trade control. Mr. Lau
stressed that the company complies with applicable export control
rules and obtains licenses where required. In this particular
instance, Mr. Lau stated that he checked the TID web site and
determined that the item does not require a license for export from
Hong Kong (Note: if correct, this would mean that it is unlikely
that this item would require a U.S. export license for
export/reexport to mainland China).


6. Mr. Lau stated that the customer for this item was Beijing
Joinsemi. He stated that this company is also an electronics
reseller (www.joinsemi.com). Mr. Lau stated that he believed the
end-user of the item was an observatory in China but was not sure of
the exact name. By subsequent e-mail, Mr. Lau stated that he had
received information from Joinsemi, namely that the end-user was a
graduate student working at the Yunnan Astronomical Observatory
Chinese Academy of Science. That student was using the item to
conduct certain tests.


7. ECO recommends that BIS review the underlying documentation of
this transaction (as well as the technical specifications of the
item) to determine whether a license was required for shipment of
this item to mainland China. Based on the facts in hand, ECO
believes WT to be a reputable recipient of U.S. origin technology
(as reseller).