VZCZCXYZ0003
RR RUEHWEB

DE RUEHHK #0119 0180850
ZNR UUUUU ZZH
R 180850Z JAN 08
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 3905
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 000119 
 
SIPDIS 
 
USDOC FOR 532/OEA/LHINES/ADYSON/SSILVER 
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: ASIA LINK (HONG 
KONG) LTD. 
 
REF: A) USDOC 10521 
 
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 (PSV) at Asia Link (Hong 
Kong) Ltd., Room 1022, 10/Floor, No. 1 Hung To Road, Kwun Tong, 
Kowloon, Hong Kong (Asia Link).  The items in question are 
navigation parts for civil aircraft, a course deviations indicator 
and antennas and parts for radar, radio navigational aids exported 
to Asia Link on or about September 11, 2006, June 8, 2007 and 
January 15, 2007.  Certain of the items are classified under Export 
Control Classification Number (ECCN) 7A994 and are controlled for 
anti-terrorism reasons (AT).  The exporter was Garmin International 
of Olathe, Kansas. 
 
¶3.  A Hong Kong Companies Registry search reveals that Asia Link has 
been in existence since 2001.  It has less than 1 USD in paid-up 
share capital.  Its director is Li, Yanan with Hong Kong 
identification number P983393(9).  Li, Yanan is not a director in 
any other company in Hong Kong. An Internet search reveals that Asia 
Link is a distributor of Garmin (the exporter) in Hong Kong and acts 
as a supplier of GPS devices in Asia.  An Internet company profile 
of the company lists a second address, namely, Room 504, Nam Wo Hong 
Building, 148 Wing Lok Street, Sheung Wan, Hong Kong. 
 
¶4.  This second address is also listed as the corporate address for 
a second Hong Kong company, namely HK Carcom Electronic Technologies 
Limited (Carcom). According to the Hong Kong Companies Registry, 
this company likewise has less than USD 1 in paid-up share capital. 
Its director is listed as CP Corporate Services Limited.  According 
to information on this company's web site (www.e-carcar.com), Carcom 
focuses on car audio/video, PMP/GPS, and Smart Phone design, 
development, manufacturing and marketing.  Its web site includes a 
range of GPS devices for automotive applications.  This company also 
has a Shenzhen office. 
 
¶5.  Commercial Assistant Carrie Chan and ECO attempted, on several 
occasions, to schedule the PSV with Asia Link.  Over the course of 
several weeks, Asia Link representatives steadfastly refused to meet 
with the ECO.  Eventually, Asia Link representatives provided 
documentation purporting to confirm receipt of the January 2007 and 
June 2007 shipments.  Asia Link declined to provide information 
about the September 2006 shipment citing business reasons.  Asia 
Link also refused to provide any details about the end user or end 
use of the items in question.  The Asia Link representative stated 
that the shipments were destined for mainland China but declined to 
provide additional information.  Commercial invoices provided by 
Asia Link (and also OEA) list Beijing Unistrong Science and 
Technology as the buyer of the items.  This company is a reseller of 
a range of GPS devices with offices throughout mainland China. 
 
¶6.  ECO recommends that OEA conduct a review of shipments destined 
to Asia Link and Carcom as well as all shipments to the addresses of 
those companies.  ECO also recommends that Asia Link be added to the 
BIS Unverified List (a public compilation of companies where BIS has 
been unable to satisfactorily complete a PSV or pre-license check 
(PLC) for reasons outside of the control of the U.S. government).