VZCZCXYZ0001
RR RUEHWEB

DE RUEHHK #0900/01 0880654
ZNR UUUUU ZZH
R 290654Z MAR 07
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 1131
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 000900 
 
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: 
DORADO CO. (HK) 
 
REF: A) USDOC 02348 
 
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 Vice Consul Tyler 
Warren, conducted a post shipment verification 
(PSV) at Dorado Co. (HK) (Dorado), 51 Jordan Road, 
Room 402, Kowloon, Hong Kong.  The items in 
question are dielectric resonator oscillators 
exported to Dorado on or about January 20, 2007 
and valued at USD 22,950.  On the applicable 
shippers export declaration (SED), these items are 
classified as EAR99.  Items properly classified as 
EAR99 may be exported/reexported to virtually all 
destinations and end-users worldwide, license 
free.  The exporter was Herley-CTI of Whippany, 
New Jersey (Herley). 
 
¶3.  Dorado is not included in the Hong Kong 
Companies Registry as it is not an incorporated 
entity.  According to the Hong Kong Inland Revenue 
Department Business Registration Office, Dorado is 
registered at the address noted above.  It is a 
sole proprietorship and has been in existence 
since 1984. The owner is Mr. Kelvin Kwok. 
According to information obtained from the Hong 
Kong Trade Development Council (TDC) web site, 
Dorado is a representative of high-tech electronic 
companies in the United States and United Kingdom 
and sells electronic equipment to customers in 
Hong Kong and mainland China.  It has two 
employees. 
 
¶4.  The ECO and Vice Consul Warren visited Dorado 
at the address referenced above on March 22, 2007 
and met with Kelvin Kwok, Managing Director.  The 
office is modest in size, typical for a small 
trading company in Hong Kong.  Mr. Kwok provided 
background on Dorado. Consistent with the 
information noted above, Mr. Kwok stated that 
Dorado is his company and is a reseller of high- 
tech equipment into Hong Kong and mainland China. 
He has been in this type of business for quite 
some time. 
 
¶5.  Mr. Kwok was quite familiar with U.S. export 
controls noting that he routinely provides end-use 
information to Herley.  He claimed that all of his 
customers are commercial companies in Hong Kong 
and mainland China.  He expressed his opinion that 
U.S. export controls are overly stringent and out 
of date. 
 
¶6.  With respect to the shipment that was the 
subject of the PSV, Mr. Kwok provided the 
applicable documentation reflecting that the items 
had been received by Dorado and subsequently 
resold to Tung Pang Group Limited in Hong Kong.  A 
review of the applicable shipping documentation 
from Herley and supplied by Mr. Kwok indicated 
that the end-user of the items is the Nanjing 
Radio Factory.  Mr. Kwok noted that while the 
customer is Nanjing Radio Factory, he trades with 
Tung Pang Group, an agent for Nanjing Radio 
Factory.  According to the Hong Kong Companies 
Registry, Tung Pang Group has nominal (equivalent 
of USD 1,200) share capital.  Its director is 
mainland Chinese national Defa Ziu.  According to 
the Companies Registry, Defa Qiu is also director 
of Suntek International (HK) Limited (established 
in 2005).  During the visit, another shipment of 
the same type of items arrived at the office.  Mr. 
Kwok showed the ECO and Vice Consul Warren the 
items and the underlying shipping documentation. 
It listed Nanjing Radio Factory and Nanjing 
Research Institute as end-users. 
 
¶7. At the time visited, Dorado appeared to be a 
suitable recipient of the commodities shipped (as 
reseller) since Dorado cooperated with the PSV and 
provided all requested information concerning the 
 
 
final disposition of the applicable items.  Dorado 
is likewise familiar with and stressed its intent 
to comply with U.S. export control rules.  At the 
same time, the ECO was not able to inspect the 
subject items as they had already been delivered 
to Dorado's customer.  Consistent with guidance on 
reporting of PSVs where the items cannot be 
physically inspected, the ECO recommends that this 
PSV be classified as Limited. 
Cunningham