VZCZCXYZ0009
RR RUEHWEB

DE RUEHHK #0820 1270210
ZNR UUUUU ZZH
R 060210Z MAY 08
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 4798
RHMFIUU/HQ BICE WASHINGTON DC
RUEHGP/AMEMBASSY SINGAPORE 3842

UNCLAS HONG KONG 000820 
 
USDOC FOR 532/OEA/MNICKSON /DMUSLU 
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: 
MICRO-COMM ASSOCIATES PTE LTD 
REF: A) USDOC 01394 
 
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 (PSV) at Micro-Comm 
Associates Pte. Ltd., No. 10 Ubi Crescent, Singapore (Micro-Comm). 
The items in question are 62 ADC-30720 A/D converters exported to 
Micro-Comm on or about November 6, 2007 and November 12, 2007.  The 
items are classified under Export Control Classification Number 
(ECCN) 3A001 and are controlled for national security (NS) reasons. 
The exporter was Mesa MW Corporation of Gilbert Arizona. 
 
¶3.  According to the Singapore companies registry, Micro-Comm was 
registered in 1999 and its registered share capital is the Singapore 
dollar equivalent of approximately USD 180,000.  Its directors are 
Indian Nationals Rajesh Mishra, Satya Prakash Mishra, Singapore 
Permanent Resident Shukla Sunita and Singapore citizen Rm Muthaiah. 
Rajesh Mishra, Satya Prakash Mishra and Shukla Sunita are also the 
shareholders of the company. 
 
¶4.  A review of the company's web site (www.microcommassociates.com) 
reveals that the company is primarily a electronics components 
reseller. 
 
¶5.  On April 22, 2008, the ECO, accompanied by a representative of 
Singapore Customs visited the company and met with Ms. Sunita 
Shukla, Director and S.P. Mishra, Director.  Mr. Mishra provided a 
business card listing him as the Regional Vice President of the 
Indo-American Chamber of Commerce and another card listing him as 
the Managing Director of Kaytronics Exim Pvt. Ltd. in Bangalore 
(Kaytronics).  Mr. Mishra was quick to point out to the ECO that he 
has attended several BIS events in India where quite senior 
representatives of BIS had participated including Under Secretaries 
Juster and Mancuso as well as Office Director, Steve Goldman.   He 
stated that he is well aware of U.S. export controls and was 
actively working in India to improve U.S. - India relations.  He 
also informed the ECO that this was the second PSV that this company 
had received from BIS and that he had previously been visited by 
Special Agents Holzer and Higgins in 2005. 
 
¶6.  Mr. Mishra also provided the ECO with additional information 
about the various companies that are affiliated with Micro-Comm and 
Kaytronics.  In particular, Kaytronics (www.kayindia.com) is the 
parent company of Micro-Comm in Singapore and the exporter, Mesa 
Microwave, in Arizona (Mesa).  All companies are disclosed at the 
Kaytronics web site.  Mesa acts as the procurement mechanism for 
Kaytronics (it was previously named Kaytronics) and Micro-Comm.  Mr. 
Mishra was quick to stress that all of his customers know the 
destination of the items in question.  He has set up this type of 
structure to allow him to procure and pay for items in the United 
States that he can subsequently ship through Singapore.  His niche 
is in providing various products to Indian state entities and 
obtaining payment for those items (the mechanics of which can be 
quite complicated).  Total turnover for all of the companies was 
approximately USD 5 million in 2006. 
 
¶7.  As to the particular items in question, Mr. Mishra stated that 
those items had been procured on behalf of Bharat Electronics for 
use in communications equipment for the Indian military (electronic 
countermeasures).  Mr. Mishra stated that he knows this customer 
well and that it is not involved in missile or nuclear related 
programs.  He further stated that the items in question are quite 
old and obsolete.  He noted that the Indian military often continues 
to use older equipment and therefore requires such older/obsolete 
components.  Mr. Mishra provided the ECO with tax invoices (with 
original stamp of Bharat Electronics) indicating delivery, on 
November 14, 2007, of the 62 converters that are the subject of this 
PSV.  Those converters were delivered to the representative office 
of Bharat Electronics in Singapore. 
 
¶8.  Mr. Mishra stated that he occasionally receives orders for 
shipment to China.  Typically, he stated, when he requests 
End-use/user statements from those purported buyers, further 
correspondence ceases. 
 
¶9.  At the time visited, Micro-Comm appeared to be a suitable 
recipient of the commodities shipped since Micro-Comm cooperated 
with the PSV, provided ECO with access to documents showing final 
disposition of the items and operates a line of business consistent 
with the use of the items.  Also, Micro-Comm is quite familiar with 
U.S. export controls and expressed its commitment to comply with 
them.