VZCZCXYZ0002
RR RUEHWEB

DE RUEHHK #2147 3310857
ZNR UUUUU ZZH
R 260857Z NOV 08
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 6315
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 002147 
 
USDOC FOR 532/OEA/LHINES/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: SHARE HK LTD 
 
REF: A) USDOC 06569 B) USDOC 05607 C) HK 03088 (2007) D) HK 00913 
(2008) 
 
 
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) attempted 
to conduct a post shipment-verification (PSV) at Share Hk. Ltd., 
Flat A, 8/F King Yip Pty Bldg, 59 King Yip Street, Kwun Tong, Hong 
Kong (Share). The items in question are semiconductors 
(TIS5962-9679001NXB, DM: SMQ320C32PCMM50) exported to Share on or 
about April 5, 2008 and valued at USD 8500.  On the applicable 
shippers export declaration (SED), these items are classified under 
export control classification number (ECCN) 3A001 and, if properly 
classified, would be controlled for national security (NS) reasons. 
These appear to be items that may be shipped license-free to Hong 
Kong but would, in virtually all circumstances, require a license 
for shipment to mainland China.  The exporter was Rochester 
Electronics of Newburyport, Massachusetts. 
 
¶3.  According to the Hong Kong Companies Registry, Share was 
registered in July 2003.  Its paid in capital is the Hong Kong 
equivalent of USD 2500.  Its directors and shareholders are listed 
as mainland nationals Jiang, Hu (mainland passport number 
G00909507), Xia, Qiu Min (mainland passport number G06780470) and 
Xia, Zehghui (mainland passport number G06689017).  The corporate 
secretary is listed as HKRTP Limited (this is the corporate 
secretary for companies that were the subject of other unfavorable 
PSVs including those referenced in reftels B and C). 
 
¶4.  As detailed further below, Share appears to be related to Wing 
Lee (China-Hong Kong) Trading Co. Ltd. (Wing Lee), the subject of a 
previous unfavorable PSV described in reftel D.  Specifically, the 
bill-to information in the Rochester transaction documentation 
provided by OEA is Wing Lee at Wing Lee's addressed noted in reftel 
¶D.  Additionally, the contact name for the order in that 
documentation (Xu, Hui) corresponds to the contact name in the Wing 
Lee transaction documentation.  As discussed further in reftel D, 
Wing Lee is related to a range of additional Hong Kong and mainland 
companies. 
 
¶5.  The Rochester End Use/Ultimate Consignee Statement, purportedly 
completed by the end-user of the items lists Galaxy Elec. Technic 
Limited as the end user of the items.  The end use is listed as 
medical devices (CT and MRI).  According to the Hong Kong Companies 
Registry, Galaxy Elec. Technic Limited has been in existence since 
¶1998.  Its paid up share capital is the Hong Kong equivalent of USD 
¶1250.  Hong Kong identity card holders, Chong, Min Min (H340781(2) 
and Tsui, Kin Chit (H340780(4) are listed as directors.  A web 
search for this company reveals that it appears to sell DVD players. 
 In addition, a range of companies use this same address. 
Commercial Assistant Carrie Chan reached Mr. Tsui, a representative 
of Galaxy, by phone.  Mr. Tsui stated that Galaxy did not order 
these items from Share but they were told to receive the item on 
Share's behalf.  Ultimately, according to this representative, the 
items never arrived. 
 
¶6.  Based on the information noted above, ECO believes that Share is 
an unsuitable recipient of U.S. origin controlled technology.  ECO 
recommends that BIS reach out to Rochester to determine what 
information it had on hand when it shipped the items.  Further, ECO 
requests that OEA confirm the 3A001 classification of the shipment 
so that ECO may reach out to Hong Kong TID concerning a potential 
violation of Hong Kong's export control rules in connection with 
this shipment.  Finally, ECO recommends that Share be added to the 
BIS Unverified List and/or Entities List.