BLUE LANTERN LEVEL 3: END-USE CHECK ON UNLICENSED

UNCLAS STATE 107940

SIPDIS
HONG KONG FOR JOHN J. VERSOSKY
POL

E.O. 12958: N/A
TAGS: ETTC KOMC HK
SUBJECT: BLUE LANTERN LEVEL 3: END-USE CHECK ON UNLICENSED
EXPORT TO ELECTRO COMPANY

REF: BLUE LANTERN GUIDEBOOK 2006


1. This is an Action Request. See paragraphs 2-4.


2. The Department's Office of Defense Trade Controls
Compliance (PM/DTCC) requests post's assistance in conducting
a end-use check on the unlicensed export of International
Traffic in Arms Regulations (ITAR)-controlled annunciators to
Hong Kong. Post is requested to complete this Blue Lantern
check within 45 days.


3. Reason for request: The Department has received
information that in June 2009, a US company, Space Coast IC,
exported annunciators to Electro Company (EC) in Hong Kong
without the required export license from the Directorate of
Defense Trade Controls (DDTC). Furthermore, it is believed
that said export of annunciators was then re-exported by

Electro Company to an unknown foreign consignee.

(COMMENT: Annunciators are position symbol indicators that
are electro-mechanical instruments, typically used in the
cockpit of an aircraft, which indicate specific functions
occurring, as per the symbol or word, for example, that is
displayed on the indicator. END COMMENT)


4. ACTION: The Department requests that Post contact Electro
Company officials to make inquiries into the subject export
transaction and the ultimate end-use of the annunciators.
Post should also conduct a site visit, if possible, to assess
the company's reliability as a recipient of United States
Munitions List (USML) articles as well as an assessment of
the company's on-site security and operations. If a site
visit is not possible, please inform the PM/DTCC case officer.

The following points are provided for guidance:

--Can EC confirm that it received a shipment of annunciators
from Space Coast IC, a company in the United States, on or
around June 2009?

--For what purpose were the annunciators purchased?

--Who is the ultimate end-user of the annunciators and what
is their ultimate end-use? Can EC provide documentation that
verifies the end-use/end-user, such as a contract or purchase
order?

--Where are the annunciators currently located?

--Does EC understand the restrictions on USML items,
especially the prohibition against unauthorized re-transfer
and re-export?

--When was the company established and who are its
principals?

--What is the nature of its business -- what type of items
do they handle, does the company serve as a broker?

--What type of organizations are among its typical customers
and where are they located?


5. Details of the transaction:

Electro Company Purchase Order No. EC0311-SCI

QUANTITY/COMMODITY:

58 - Annunciator, Part No. 924066-1C, Alternate Part No.
6250043, NSN 6350010222657.

Serial Nos: 1495, 1885, 2218, 2251, 2357, 2362, 2451, 2658,
2675, 2687, 2711, 2859, 3253, 3260, 3274, 3319, 3340, 3352,
3430, 3628, 3873, 3881, 3908, 3916, 3929, 3931, 3943, 3947,
3950, 3954, 3965, 3969, 3972, 3974, 3975, 3994, 3996, 3997,
4011, 4113, 4155, 4165, 4930, 4932, 4976, 5009, 5027, 5039,
5059, 5065, 5070, 5079, 5082, 5089, 5096, 5449.

VALUE: 14,500 USD

SELLER:

Space Coast IC, Inc.
1221 Admiralty Boulevard
Rockledge, FL 32955
Tel: 321-574-0488
Fax: 321-574-0443
POC: Klaus Negele

FOREIGN CONSIGNEE:

Electro Company
DD-114, Lot 362, Kam Tin Road
Kam Tin Pat Hueng N.T.
Kowloon, Hong Kong
POC: Sharon Kwong

FOREIGN END-USER:

Unknown


6. Please slug reply for PM/DTCC - BLUE LANTERN COORDINATOR
and include the words "Blue Lantern" and the case number in
the subject line. POC is Meredith Sundlof. Phone:
202-663-3455; Email: SundlofME@state.gov; SIPRNET:
SundlofME@state.sgov.gov. The Blue Lantern Guidebook (ref)
is available as a PDF file at
http://www.intelink.sgov.gov/wiki/Blue Lantern End-Use
Monitoring Program.


7. Department is grateful for post's assistance in this
matter.
CLINTON