VZCZCXYZ0004
RR RUEHWEB

DE RUEHHK #0001/01 0020323
ZNR UUUUU ZZH
R 020323Z JAN 08
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 3773
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 000001 
 
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: VICTORY WAVE 
HOLDINGS 
 
REF: A) USDOC 09765 B) HK 02563 C) HK 03094 
 
¶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), conducted 
a post shipment verification (PSV) at Victory Wave Holdings, Unit 
2401A Park-In Commercial Centre, 56 Dundas Street, Kowloon, Hong 
Kong (Victory Wave). The items in question are isolators exported to 
Victory Wave on or about September 27, 2007 and collectively valued 
at approximately USD 9,600.  The items are likely not on the 
Commerce Control List (EAR99) and are therefore likely only 
controlled to restricted destinations and to restricted 
end-users/uses.  Mica Microwave of Manteca, California was the 
exporter. 
 
¶3.  As further detailed in reftel B, Victory Wave is related to Hong 
Kong company Centre Bright.  Centre Bright is included in the BIS 
Unverified List of companies where the U.S. government has been 
unable to complete a PSV or pre-license check (PLC) for reasons 
outside of the control of the U.S. government.  Victory Wave is 
further related to Exodus Microelectronics Company Limited, Echelon 
Microsystems Limited and Omniway Technology Limited.  In particular, 
Hong Kong resident, Wong, Yung Fai is a director of Victory Wave, 
Exodus, Echelon and Omniway.  As further noted in reftel B, the 
registered addresses of Victory Wave, Exodus, Omniway and Echelon 
are all locations of SBC International, a business registration 
services provider. 
 
¶4.  On November 30, 2007, the ECO, accompanied by Commercial 
Assistant Carrie Chan, met with Mr. Wong at the Victory Wave 
registered address (which is also one of the offices of SBC 
International). The meeting occurred in a small conference room of 
SBC.  ECO surmises that Mr. Wong does not have an office at this 
address but rather uses the services of SBC for corporate 
registration purposes and to hold meetings, when a meeting space is 
needed.  Mr. Wong stated that he did not have a business card to 
exchange with the ECO. 
 
¶5.  Mr. Wong stated that Victory Wave is a new company established 
in 2007.  It is involved in various communications projects.  Some 
of those projects are in Shanghai.  He stated that he has two 
partners in this company, both of whom are located in the mainland. 
The Hong Kong office operates only as a procurement base for the 
projects in the mainland.  He stated that some procurement is also 
conducted from Shanghai. Mr. Wong further stated that the SBC 
premises are his offices and when he is in Hong Kong, he uses these 
premises to conduct his business. 
 
¶6.  With respect to this particular shipment, Mr. Wong stated that 
Victory Wave procured these items on behalf of a Shenzhen company, 
Shenzhen Hongdu Industry Co.  Victory Wave's Shanghai partners had 
referred that company to him.  The items were for use in what he 
described as a communication project.  Mr. Wong declined to provide 
any additional information about the end use. 
 
¶7.  As noted in reftel C, Mainland Chinese entity Hongtu Group is 
the holding company for a range of companies with similar names to 
Shenzhen Hongdu Industry Co. including Shenzhen Hongtu Hangyang 
Technology Co. Ltd.  Those companies are involved in a range of 
activities including the distribution of hard to find and military 
electronic components and ICs. 
 
¶8.  When asked about Centre Bright, Mr. Wong stated that he is aware 
of the company and that it is also a sourcing company.  He stated 
that he has no direct contact with this company.  When asked whether 
he is familiar with Exodus, Omniway and Echelon, Mr. Wong stated 
that he knows nothing about these companies.  He stated that Victory 
Wave is his only company in Hong Kong.  When the ECO presented Mr. 
Wong with Hong Kong Company Registry printouts showing that he is 
the director of each of these companies, Mr. Wong conceded that he 
is the director of these companies.  He stated that these companies 
are the companies of his friends.  He further stated that they are 
not related to Centre Bright. 
 
¶9.  When asked to explain why he is the director of several 
companies in Hong Kong, Mr. Wong stated that each of the companies 
is set up to support different projects with different partners. 
When asked to describe those projects, Mr. Wong would only state 
that the projects involved system integration and refused to provide 
further details. 
 
¶10.  Mr. Wong stated that his mainland partners send customers to 
him that he services through the Hong Kong companies.  He stated 
that Hong Kong has a reputation for quality with mainland Chinese 
buyers and he therefore sells product into mainland China through 
 
 
Hong Kong.  He further stated that Victory Wave is the primary 
vehicle for sourcing items outside of China.  With respect to the 
additional companies, Mr. Wong stated that those companies source 
items in mainland China for resale into mainland China.  He further 
stated that those companies never source items from the United 
States.  Note:  In fact, based on information provided by OEA, it is 
clear that at least Exodus also sources various components from the 
United States. 
 
¶11.  In light of the recent registration and business practices of 
Victory Wave, Exodus, Echelon and Omniway, ECO strongly suspects 
that these companies have been established to circumvent the listing 
of Centre Bright on the BIS Unverified List.  ECO recommends that 
OEA conduct a thorough review of shipments to these companies as 
well as shipments to the addresses of those companies.  ECO further 
recommends that OEA consider a review of shipments to all of the 
Hong Kong addresses of SBC International as ECO suspects that 
additional procurement entities may be using SBC addresses as their 
business premises (www.sbc.com.hk).  ECO also recommends that 
Victory Wave, Exodus, Echelon and Omniway be added to the Unverified 
List. 
 
 
Cunningham