VZCZCXYZ0005
RR RUEHWEB

DE RUEHHK #2204 2350900
ZNR UUUUU ZZH
R 230900Z AUG 07
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 2695

UNCLAS HONG KONG 002204 
 
SIPDIS 
 
USDOC FOR 532/OEA/LHINES/DFARROW 
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT 
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS 
 
BEIJING FOR FCS JEANETTE CHU 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: AMBIT MICROSYSTEMS 
(ZHONG SHAN) 
 
REF: A) USDOC 05155 B) HK 04113 
 
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) attempted 
to conduct a post shipment-verification at Ambit Microsystems 
(Zhongshan), C/O Soonest Express, 4th Floor, Unit 4008-4018E, ATL 
Logistics Centre B, Berth 3 Kwai Chung Container Terminals, Kwai 
Chung, New Territories, Hong Kong (Ambit).  The items in question 
are various semiconductors exported to Ambit on or about April 24, 
2007 and valued at USD 137,000.  On the applicable shippers export 
declaration (SED), these items are classified as 3A001 and, if 
properly classified, would be controlled for national security (NS) 
reasons.  The exporter was Triquint Semiconductor (Triquint) of 
Hillsboro Oregon. 
 
¶3.  According to the Hong Kong Companies Registry, Ambit 
Microsystems is not registered in Hong Kong.  A company with a 
similar name, Ambit Broadband Co. Limited was established in 
September of 2006.  Taiwanese passport holders Chu, Hsien Sheng and 
Lin, Yuan Hao are listed as directors.  That company has nominal 
issue share capital (USD 1,000) but no paid-up share capital. 
Soonest Express (Soonest) is a Hong Kong freight forwarder 
previously referenced in Reftel B. 
 
¶4.  As in the case referenced in Reftel B, ECO attempted to obtain 
information about the shipment by contacting Soonest.  Soonest 
requested a tracking number for the shipment so that it could 
retrieve the applicable documentation.  ECO was unable to obtain 
such a tracking number from OEA and so did not obtain additional 
information from Soonest.  Nonetheless, from the documentation OEA 
provided (including Triquint invoices and shipping documents), it is 
very likely that the items in question transshipped Hong Kong on 
their way to Ambit's production facility in Zhongshan, Guangdong, 
mainland China. 
 
¶5. Ambit is a subsidiary of FOXCONN (www.foxconn.com), which is a 
leading manufacturer of computer components including motherboards 
as well as various electronic components for consumer goods 
including mobile phone handsets and notebook computers. FOXCONN 
supplies components for leading U.S. companies including Apple 
Computers, Invidia, etc. FOXCONN is a Taiwanese company with a 
significant China presence (more than 20 locations throughout 
China), and is the registered trade name of Hon Hai Precision 
Industry Group.  FOXCONN acquired Ambit in 2004.  One of FOXCONN's 
facilities in mainland China was the subject of a favorable PSV by 
Beijing ECO on June 7, 2007 (reference BIS license D368885). 
 
¶6.  The ECO notes that in certain circumstances, items that fall 
into the applicable ECCN (3A001) may be exported or reexported to 
mainland China without a license, particularly where they are 
destined for civil use.  However, in other circumstances, 3A001 
items require a license to mainland China regardless of end-use. 
This difference is dependant on the ECCN subcategory into which the 
applicable items fall.  While the ECCN subcategory was not included 
in Triquint's Shippers Export Declaration (SED), Triquint's invoice 
states that some of the items in question are classified under ECCN 
3A001.c.2.  This subcategory does not appear to require a license if 
exported to Hong Kong but would appear to require a license if 
exported/reexported to mainland China.  The ECO recommends that BIS 
conduct a commodity classification for these items to conclusively 
determine their control status.  Nonetheless, in light of the 
apparent violation of licensing requirements for these items based 
on Triquint's own commodity classification, the ECO recommends that 
this check be classified as Unfavorable.