EXTRANCHECK: POST-SHIPMENT VERIFICATION: CROMPTON GREAVES

UNCLAS NEW DELHI 000488

SIPDIS

USDOC FOR 532/OEA/HINES/GAINES
USDOC FOR 3131/USFCS/OIO/ANESA/KREISSL
USDOC FOR 4530/MAC/ANESA/OSA
ICE HQ FOR STRATEGIC INVESTIGATIONS
STATE FOR EB/ESP

E.O. 12958: N/A
TAGS: BEXP ETRD ETTC IN
SUBJECT: EXTRANCHECK: POST-SHIPMENT VERIFICATION: CROMPTON GREAVES
LIMITED, BHOPAL, INDIA


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


2. On March 3, 2009, Export Control Officer (ECO) Paul Cushman and
FSN Shailendra Srivastava conducted two Post-Shipment Verifications
(PSV) at Crompton Greaves Limited (CGL).


3. BIS requested the PSVs at CGL, located at Mandideep in Bhopal.
CGL was listed as the ultimate consignee for 6 Auto Recharging
Dehydrating Breathers (ARDB) supplied by High Voltage Supply of
Dallas, Texas and 24 electrical fans supplied by Krenz & Company of
Germantown, Wisconsin. Export License: No License Required. ECCN:
EAR99.


4. ECO and FSN Srivastava met with Mr. Sushil Karwa, Deputy Manager,
and Mr. L. Srinivasan, Executive Assistant, in the CGL reception
area.


5. CGL representatives were not familiar with BIS regulations and
this was the first visit by BIS officials to their facility.
Despite being advised in advance of the documentation sought by the
BIS team, Karwa was unable or unwilling to provide any documents
relating to these importations. However, he did agree to locate the
documents and forward copies to FSN Srivastava later that week.


6. Karwa explained that the Auto Recharging Dehydrating Breathers
and the electrical fans had been installed in large power generation
transformers manufactured by CGL. The ARDBs are used to remove
moisture from air introduced into the transformer. The electrical
fans are used to remove excess heat from the transformer radiators.
Karwa stated that the entire consignment had already been exhausted
in the manufacturing process.


7. Over the following two weeks, FSN Srivastava repeatedly contacted
Karwa and requested the promised documentation. Initially, he said
that he was busy with end-of-year requirements and once free, he
would forward the documents. On March 13, 2009, he said that he was
waiting for authorization from the CGL general manager. On March
17, 2009, Karwa stated that he could not provide the documents
because following the BIS visit, he had been visited by "Indian
Bureaucrats" who were investigating the purpose of the BIS visit and
the validity of ECO Cushman's Indian visa. FSN Srivastava sensed
that Karwa was being deceptive. He explained that the BIS program
in India is sanctioned by the Ministry of External Affairs and
encouraged Karwa to have the bureaucrats contact him. Karwa
rebuffed this offer and when asked, refused to identify the
bureaucrats' agency.


8. Crompton Greaves Limited, headquartered in Mumbai, is a
multinational private sector enterprise. Established in 1937, CGL
designs, manufactures, and markets electrical products. The Power
and Transformer Division in Bhopal was established in October 1995
and employs approximately 75 personnel. A private security force is
on duty at the facility around the clock.


9. Recommendation: At the time of this visit, Crompton Greaves
Limited did not appear to be a reliable recipient of controlled
technology. The CGL representative appeared to be deceptive and was
generally uncooperative.
WHITE