VZCZCXYZ0001
RR RUEHWEB

DE RUEHHK #4550/01 3280309
ZNR UUUUU ZZH
R 240309Z NOV 06
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 9569
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 004550 
 
SIPDIS 
 
USDOC FOR 532/OEA/LHINES/DFARROW 
USDOC FOR 3132/FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT 
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: BMGT BEXP HK ETTC
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: 
HANGLI INTERNATIONAL HOLDINGS 
 
REF: A) USDOC 04721 
 
¶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 Bureau of 
Industry and Security (BIS), Export Control Officer 
(ECO) Philip Ankel conducted a post shipment 
verification (PSV) at Hangli International Holdings 
(Hangli) on November 9, 2006. This PSV concerned a 
solid state recorder system DSRS 400B exported by 
Ampex Data Systems of Redwood City, California 
(Ampex), classified as 7A994 and valued at $295,214. 
This 7A994 item is most likely controlled only for 
anti-terrorism (AT) reasons. 
 
¶3. An extract from the Hong Kong Companies Registry 
provides that Hangli has been registered as a company 
in Hong Kong since May 1996.  The registered address 
matches the address where the check was conducted. 
Hangli's Hong Kong corporate registration lists one 
director by Chinese passport number and without Hong 
Kong identification card number (PRC national Ai Ping 
Song).  One director is listed by reference to a Hong 
Kong I.D. card number(Ping Sung). 
 
¶4.  On November 9, 2006, the ECO visited Hangli at 
Room 901, Keen Hung Commercial Building, 80 Queen's 
Road East, Hong Kong and met with Ping Sung, Director. 
Ms. Sung noted that Hangli had recently moved from the 
location listed as Hangli's address in Reftel A 
because rents had increased substantially at that 
location.  The ECO walked by the former offices and a 
new tenant is now at that location.  The current 
Hangli office is quite modest (one large room).  A 
meeting with Ms. Sung had been requested in early 
October but delayed for some time as Ms. Sung had been 
on travel visiting Ampex in the United States as well 
as in Zhuhai, China for the Zhuhai air show. 
 
¶5.  Ms. Sung was open and cooperative during the PSV. 
Ms. Sung stated that Hangli is a trading company with 
offices in Zhuhai, mainland China and Hong Kong.  Ms. 
Sung showed the ECO a certificate stating that Hangli 
is the exclusive distributor for Ampex products in 
Hong Kong and China. Ms. Sung stated that Hangli is 
likewise a distributor for U.S. companies Herley 
(Herley.com) and Orbit.  Promotional material provided 
by Ms. Sung states that Hangli can provide a complete 
set of software and hardware devices utilized in 
manufacturing, scientific research and testing by 
civilian or military manufacturers as well as research 
institutes in aviation, aerospace, ship building, 
vehicles and oil prospecting.  The cover of the 
promotional materials includes a military helicopter 
and fighter aircraft (as well as a civilian airliner). 
When asked by the ECO whether Hangli's customers 
include the military, Ms. Sung stressed that the item 
that is subject of the check is used only for testing 
purposes. 
 
¶6.  In reference to the transaction that was the 
subject of the check, Ms. Sung provided copies of two 
airway bills.  The first airway bill referenced the 
shipment from Ampex to Hangli.  The second, dated July 
21, 2006, referenced the onward shipment of the item 
to Shenyang Aircrafts Industry Group, No. 1 Lingbei 
Street, P.O.328-27, Shenyang China.  A web search 
reveals that Shenyang Aircraft Corporation produces, 
among a wide range of items, Chinese fighter aircraft, 
but also produces parts for Boeing planes pursuant to 
agreements between Shenyang Aircraft Corporation and 
Boeing. 
 
¶7.  The items in question were classified by the 
exporter as 7A994 and could therefore, absent EPCI 
concerns or misclassification, be exported or 
reexported to China.  BIS may wish to reach out to the 
exporter to determine why it chose to list Hangli as 
the ultimate consignee and Hong Kong as the country of 
ultimate destination when the underlying Ampex 
Purchase Contract lists the end-user as Shenyang 
Aircraft Corporation located in mainland China. 
 
¶8. It is apparent to the ECO that Hangli is a trading 
company that does not engage in production or 
 
 
manufacturing of any kind.  Ms. Sung was open and 
cooperative and her answers were consistent with the 
information in documents provided by BIS.  Therefore, 
in accordance with guidance on reporting of PSVs where 
the items cannot be physically inspected, the ECO 
recommends that this PSV be classified as Limited. 
Cunningham