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