VZCZCXYZ0002
RR RUEHWEB

DE RUEHHK #0808/01 0800931
ZNR UUUUU ZZH
R 210931Z MAR 07
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 1024
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 000808 
 
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: POST SHIPMENT VERIFICATION: 
ADVANCE TECH INTERNATIONAL 
 
REF: A) USDOC 00993 
 
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), accompanied by Commercial 
Assistant, Sandy Lai, conducted a post shipment 
verification (PSV) at Advance Tech International Ltd. 
(Advance Tech), 16/F, 200 Gloucester Rd., Wanchai, 
Hong Kong. The items in question are 21 monolithic 
integrated circuits valued at USD 4,410.  The export 
control classification number (ECCN) for these items 
is listed on the applicable DHL Air Waybill for the 
shipment as 3A001.b2b.  Items properly classified as 
3A001.b2b generally do not require a license for 
export to Hong Kong but may require a license for 
export/reexport to mainland China.  The exporter is 
TLC Precision Wafer Technology of Minneapolis, 
Minnesota (TLC). 
 
¶3.  According to the Hong Kong Companies Registry, 
Advance Tech has been in existence since 1992. 
According to the Companies Registry, Fullmark 
(Corporate Services) Nominees Limited is the sole 
director of the company.  The CompanyQs authorized 
and paid-up capital is the equivalent of 
approximately USD 1,200. Rixomax (HK) Limited is 
collocated at the same address and shares the same 
director.  According to that companyQs web site 
(www.ricomax.com), Ricomax is a global product 
trading company specialized in the trade of various 
consumer goods.  A Hong Kong Trade Development 
Council profile on both companies lists Mr. Miron 
Yakuel as director in both companies. 
 
¶4.  The ECO, accompanied by Commercial Assistant 
Sandy Lai, visited Advance Tech at the address 
referenced above on February 16, 2007 and met with 
Michael Cheung and Jose Lam.  Messrs Cheung and Lam 
provided background on Advance Tech and its business 
and the proposed end-use of the items.  They stated 
that their manager had hoped to meet but was out 
sick.  They stated that Advance Tech is involved in 
data communications R&D projects including work on 
wireless modems.  Advance Tech has 8-10 employees in 
Hong Kong, primarily working on accounting and 
procurement related matters.  They stated that there 
is no relationship between the activities of Ricomax 
and Advance Tech except that they share office spaceand an internet domain (their business cards use te 
Qricomax.comQ domain).  By follow-up e-mail, M.Cheung clarified that Anat Yakuel is the Qmajo 
shareholderQ of both Ricomax and Advance Tech. 
¶5.  When asked about the proposed use of the item, 
Mr. Cheung provide the ECO a document entiled QLast 
MileQ.  That document (without any corporate 
identification or logo of any kind) states that the 
Qgoal of this start-up is to provide a fixed wireless 
V&VoIP (voice and video over IP) connectivity from 
rural towns to dense populated metropolitan areas. 
Mr. Cheung stated that Advance Tech is in the R&D 
phase of this project and uses one engineer stationed 
in Mainland China as well as freelance engineers in 
mainland China to complete the R&D on an Qas-needed 
basis.  It has no production or other operation in 
mainland China although one Advance Tech engineer is 
based in the mainland.  Advance TechQs practice is to 
hand carry components to the mainland to provide to 
the engineers for their R&D work.  If the R&D project 
is successful, the company intends to sell the 
project to investors.  Mr. Cheung stated that Advance 
Tech is only working on this project for now. 
Previously, the company worked on another R&D project 
that failed and was discontinued.  As to this 
project, they are still ordering components for the 
project in order to finalize it. 
 
¶6.  Mr. Cheung showed the ECO what appeared to be the 
circuits (there were 50 in total) in a small box.  In 
addition, Mr. Cheung subsequently provided the ECO 
(by e-mail attachment), two DHL Air Waybills (No. 759 
8065 812 and 7598065801 dated August 11, 2006 and 
 
 
September 8, 2006 respectively).  By that same e- 
mail, he also provided a copy of an invoice from TLC 
indicating that a total of 50 of the items had been 
sold to Advance Tech.  It appears this PSV was 
requested only on the September 8, 2006 shipment. 
 
¶7.  The QLast MileQ document provided by Advance Tech 
lists the most important components for the project. 
 Those components include the items that are subject 
of this check. They also include 50 Agilent HMMC-3040 
mixers, 100 Triqunit TGA-1073A pre-amplifiers, 100 
Triqunit TGA-1141 amplifiers, 50 Alpha ATN 3580-20 
attenuators, 100 Hittete HMC329 mixers, 100 UMS CHA- 
2098b amplifiers and 50 UMS CHA-2095a amplifiers. 
All of these items, except the UMS items, are listed 
as being supplied from the United States.  Mr. Cheung 
stated that Advance Tech had already received 
virtually all of the items in question. The ECO 
recommends that commodity classifications of these 
items be obtained to ascertain whether licenses were 
required to export these items to Advance Tech. A 
TriQunit data sheet on the TGA 1141 states that one 
of the primary applications of this item is use in 
military radar systems. 
 
¶8. The ECO provided Messrs Cheung and Lam with 
information about U.S. export controls and further 
recommended that the company research further whether 
Hong Kong export control laws may be implicated by 
the import and export of these items (the ECO 
believes they likely are).  The ECO stressed that it 
is important that the company understand U.S. export 
control requirements and provided contact information 
both in Hong Kong and at BIS headquarters where such 
information could be obtained.  It did not appear 
that the company was aware of U.S. export control 
requirements prior to the ECOQs visit. 
 
¶9.  While Advance Tech cooperated with the PSV and 
provided the requested information concerning the 
final disposition of the items, based on the totality 
of the facts referenced above, the ECO recommends 
that this PSV be classified as Unfavorable. 
Cunningham