VZCZCXYZ1037
RR RUEHWEB

DE RUEHHK #3714 2580935
ZNR UUUUU ZZH
R 150935Z SEP 06
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 8637
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 003714 
 
SIPDIS 
 
USDOC FOR 532/OEA/LHINES/DFARROW 
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: PRE-LICENSE CHECK: Brink's Hong 
Kong Limited 
 
REF: A) USDOC 04706 B) EXP.LIC. D362247 
 
¶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), conducted a pre-license 
check at Brink's Hong Kong Limited, 1022W First Floor, 
Kwai Chung Container Terminal 3, New Territories, Hong 
Kong (Brink's Hong Kong). The purpose of the visit was 
to determine the suitability of Brink's Hong Kong to be 
the recipient of 28 tactical police riot helmets and 
100 harnesses/chin straps that are the subject of 
export license application D362247.  The items (ECCN 
0A979) are valued at USD $11,220 and are controlled for 
crime control (CC) reasons. The license applicant is 
Galls Incorporated, 1340 Russell Cave Rd., Lexington, 
KY 40505 (Galls). 
 
¶3. Brinks Hong Kong is the wholly owned subsidiary of 
Brink's, Incorporated in the United States and Brink's 
Hong Kong has been in operation in Hong Kong since 1979 
(www.brinks.com.hk). 
 
¶4.  On August 29, 2006, the ECO visited Brink's Hong 
Kong at the address above and met with Joseph Chu, 
Assistant Human Resources and Administration Manager. 
Mr. Chu stated that guard employees are issued helmets 
for use in performing their duties. Employees typically 
keep the helmets in their employee lockers when they 
are not using them but Mr. Chu stated that there is no 
specific requirement that employees keep the helmets at 
the Brink's facility after hours. 
 
¶5. Mr. Chu stated that the work of Brink's Hong Kong 
security crews sometimes takes them into mainland China 
and that the helmets go with those crews. 
Additionally, Mr. Chu volunteered that this latest 
order replaces some prior helmets also ordered from 
Galls in October 2004 (Galls is the primary supplier of 
this type of equipment to Brink's Hong Kong).  Mr. Chu 
further stated that old helmets are destroyed when they 
are no longer useable since they include the Brink's 
logo and Brink's is keen to avoid such helmets falling 
into the wrong hands. 
 
¶6.  This ECO recommends BIS ascertain whether the 2004 
shipment of helmets required a license and, if so, 
whether such license was obtained.  Note:  Reftel A 
states that Brink's Hong Kong does not have a licensing 
history with BIS. 
 
¶7.  Brink's Hong Kong was very forthcoming during the 
PLC visit.  Mr. Chu provided information on the 
intended use of the items and on past shipments of the 
same (or similar) items. Additionally, the items are 
appropriate for the intended end-user and stated end- 
use.  However, the ECO discovered additional facts 
during the course of the PLC visit that should be 
addressed, as appropriate, during the licensing 
process.  In particular, as noted above, Brink's Hong 
Kong expects that its employees will be taking the 
helmets into China from time to time as their duties 
take them there.  Additionally, it appears Brink's Hong 
Kong received a shipment of comparable helmets in 
October 2004 for which a license may have been required 
but not obtained by Galls.  As a result, the ECO 
recommends that this PLC be considered to be Limited. 
Cunningham