VZCZCXYZ0003
RR RUEHWEB

DE RUEHHK #1731/01 1790254
ZNR UUUUU ZZH
R 280254Z JUN 07
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 2124
RHMFIUU/HQ BICE WASHINGTON DC
RUEHGP/AMEMBASSY SINGAPORE 3554

UNCLAS HONG KONG 001731 
 
SIPDIS 
 
USDOC FOR 532/OEA/MNICKSON-DORSEY/LLAUCIUS 
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR 
WILLIAM ZARIT 
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS 
SINGAPORE FOR FCS 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: BMGT BEXP ETRD ETTC HK
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: 
SIMAL INTERNATIONAL PTE LTD. 
 
REF: A) USDOC 04424 
 
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), 
Regional Export Control Officer Philip Ankel (ECO) 
conducted a post shipment-verification at Simal 
International Pte. Ltd., 16 Ayer Rajah Cresent No. 
04-05 H, Tempco Technomin, Singapore (Simal).  The 
items in question were 48 integrated circuits 
exported to Simal on or about March 2, 2007 and 
valued at USD 7,632.  On the applicable shippers 
export declaration (SED), the items were 
classified as 3A001 and are most likely controlled 
for national security (NS) reasons.  The exporter 
was Etronica LLC of Huntington, New York. 
 
¶3.  According to the Singapore companies registry, 
Simal has been in existence since 1989.  Its paid- 
up share capital is the Singapore equivalent of 
USD 200,000.  Singapore nationals, Mr. Surendran 
S/O Supramaniam and Mr. Krishnamurthy Vaidyanathan 
are listed as directors. 
 
¶4.  On June 22, 2007, the ECO met with Mr. 
Surendran S/O Supramaniam, Director (Suren on his 
business card) and Mr. Krishnamurthy Vaidyanathan, 
Managing Director (Vaidy on his business card). 
Mr. Supramaniam and Mr. Vaidyanathan stated that 
the company had been in existence since 1992 and 
is owned and run by the two of them.  They stated 
that they are primarily a "sourcing" company, 
meaning that they receive inquiries for certain 
items and attempt to source those items for their 
customers.  They stated that they typically work 
with government entities in Singapore as the 
payment risk is limited.  Their business focuses 
on CPUs and other computer products as well as 
spot sales of various mechanical parts (valves, 
hoses, etc.).  Simal's customers are primarily 
based on Singapore but Simal also sells to 
Malaysia, Indonesia and India.  Simal has seven 
staff in Singapore as well as sales agents (who 
operate on a commission basis) in India and 
Indonesia. 
 
¶5.  As to the specific items in question, 
documents provided by Simal indicate that the 
customer was Bharat Electronics Limited.  Mr. 
Supramaniam stated that Bharat Electronics is in 
the communications field and provides various 
equipment to the Indian military.  A visit to the 
company's web site (www.bel-india.com) reveals 
that Bharat Electronics was established in 1954 to 
meet the electronics needs of the Indian defense 
services. 
 
¶6.  When the discussion turned to Indian 
government entities on BIS's Entity List, Mr. 
Supramaniam and Mr. Vaidyanathan stressed that 
they are well aware of this list and generally do 
not do business with these entities.  At the same 
time, they keep the lines of communication open 
given that some low level items may be sold to 
some of these entities (without a license).  Mr. 
Supramaniam and Mr. Vaidyanathan went on to stress 
that when they deal with customers in India, they 
inform the supplier of the known end-user and 
comply with whatever requirements the supplier 
might have (whether end-user certificate or other 
informational requirements).  The ECO stressed 
that Simal has an independent obligation to comply 
with U.S. export control laws and cannot rely 
solely on the U.S. suppliers to determine whether 
a license is required or some other restriction 
exists with respect to its customers.  The ECO 
further stressed that while some Entity List 
companies may receive EAR99 items, end-use and 
end-user controls remain on those and other 
potential customers.  Mr. Vaidyanathan stated that 
he cannot know everything about all potential 
 
 
customers to which the ECO responded that the BIS 
website contains valuable know your customer and 
similar guidance.  Mr. Vaidyanathan and Mr. 
Supramaniam both stressed that they are keen to 
comply with U.S export control laws and they want 
to avoid any issues that may jeopardize the 
continued good standing of their business.  They 
further stressed that they have no business with 
the state sponsors of terrorism countries (Iran, 
Syria, Sudan, Cuba and North Korea). 
 
¶7.  At the time visited, Simal appeared to be a 
suitable recipient of the commodities shipped (as 
reseller) since Simal cooperated with the PSV and 
 
provided all requested information concerning the 
final disposition of the applicable items.  At the 
same time, the ECO was not able to inspect the 
subject items as they had already been delivered 
to Simal'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