VZCZCXYZ0003
RR RUEHWEB

DE RUEHHK #0837 1290107
ZNR UUUUU ZZH
R 080107Z MAY 08
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 4820
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 000837 
 
USDOC FOR 532/OEA/LHINES/ADYSON 
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT 
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: POST-SHIPMENT VERIFICATION: FABRICATORS 
INTERNATIONAL LIMITED 
 
REF: A) USDOC 01527 
 
¶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) was 
requested to conduct a post-shipment verification (PSV) at 
Fabricators International Limited (Fabricators), Unit 2509, 
Metropole Square, 2 On Yiu, Shatin, Hong Kong (Fabricators).  The 
items in question are 4000 un-mounted chips exported to Fabricators 
on or about August 23, 2007 and valued at approximately USD 2,900. 
The items are classified under Export Control Classification Number 
(ECCN) 3A001.  This ECCN is controlled for National Security (NS) 
and Anti-Terrorism (AT) reasons. The exporter was Global Access 
Unlimited, Inc. of Largo, Florida. 
 
¶3. A review of Hong Kong Companies Registry reveals that Fabricators 
was registered in 1976 and has registered capital of the Hong Kong 
equivalent of USD 40,000.  Its directors are U.S. nationals James L. 
Gaza, Stephen Morris McClure, Stuard Burr Oakes, John Paul Petrillo 
and Hong Kong resident Wong, Wai Man. 
 
¶4.  Fabricators is part of the International Components Corporation 
group of companies.  International Components Corporation (ICC) 
designs and manufactures power supplies, battery solutions and 
chargers (more information on the company may be found at 
www.iccus.com). Elpac Power Systems (Elpac) (the bill-to company on 
the Global Access Unlimited invoice provided to ECO by OEA) is also 
a subsidiary of International Components Corporation.  In sum, all 
of the parties to the transaction that is the subject of this PSV 
are corporate affiliates of each other. 
 
¶5.  On April 28, 2008, ECO and Commercial Assistant Carrie Chan 
visited Fabricators and met with Mr. Ice L.K. Chan, Assistant 
Administrator and Personnel Officer.  She stated that Fabricators in 
Hong Kong has no manufacturing capacity but acts merely as a 
shipping logistics center for the mainland China production 
facilities of International Components Corporation (including 
Elpac).  She further stated that neither Fabricators nor Elpac sell 
any of the components they receive, as components.  Rather, they act 
as contract manufacturers.  It is typically the contracting company 
that designates the input suppliers for the company's end products. 
She further stated that Fabricators will likely reduce its presence 
in Hong Kong and only retain its warehouse there.  She is due to be 
laid off shortly. 
 
¶6.  When asked about the shipment in question, Ms. Chan stated that 
she was unable to locate the shipment based on the information 
provided by the ECO (including an invoice and information about the 
date of shipment).  She showed the ECO documentation from other 
similar shipments that included the airway bill.  ECO was informed 
by OEA that the exporter was unable to locate the applicable airway 
bill and therefore could not provide that information to the ECO. 
As a result, ECO was unable to verify the shipment.  Based on a 
totality of the circumstances, ECO believes these items most likely 
ended up at Fabricators's mainland production affiliate. 
 
¶7.  Ms. Chan conceded that Fabricators does not obtain Hong Kong 
import and export licenses for the applicable items. If classified 
correctly by the exporter, these items would likely require a 
license for import into and reexport from Hong Kong.  ECO requests 
that OEA conduct a commodity classification of the items to 
determine whether the exporter classified these items properly.  If 
so, ECO may reach out to Hong Kong authorities regarding this 
apparent violation of Hong Kong law. 
 
¶8.  In addition, ECO recommends that the BIS Office of Export 
Enforcement conduct an outreach to the exporter to determine why it 
failed to retain the appropriate records of the export as required 
by the Export Administration Regulations. Also, ECO recommends that 
OEA determine whether the items qualify for license free shipment to 
mainland China since some subparagraphs of ECCN 3A001 would require 
such a license if exported to mainland China in this way. 
 
Cunningham