VZCZCXYZ0000
RR RUEHWEB

DE RUEHHK #0843/01 1290837
ZNR UUUUU ZZH
R 080837Z MAY 08
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 4826
RHMFIUU/HQ BICE WASHINGTON DC
RUEHGP/AMEMBASSY SINGAPORE 3850

UNCLAS HONG KONG 000843 
 
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: 
TECNOMIC PROCESSORS PTE LTD 
REF: A) USDOC 01397  B) USDOC 02727 C) HK 03094 (2007) D) USDOC 
 
05482 (2005) 
 
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 Tecnomic Processors 
Pte. Ltd., 138 Cecil Street, No. 10-01 Cecil Court, Singapore 
(Tecnomic). The items in question are six field programmable gate 
arrays exported to Tecnomic on or about September 7, 2007.  The 
items are classified under Export Control Classification Number 
(ECCN) 3A001A.2.C and are controlled for national security (NS) 
reasons.  The exporter was Actel Corporation of Mountain View, 
California. 
 
¶3.  According to the Singapore companies registry, Tecnomic was 
registered in 1988 and its registered share capital is the Singapore 
dollar equivalent of approximately USD 650,000.  Its directors are 
Indian National Mr. Suresh Kumar Saradadevi Krishna Pillai, 
Singapore Permanent Resident Mr. Rajan Natrajann and Singapore 
Permanent Resident Mr. Ravi Krishnamoorthy.  The sole shareholder is 
Metchem Engineering S.A. of Zurich, Switzerland. 
 
¶4.  A review of the company's web site (www.tecnomic.com) reveals 
that the company markets itself as a value-added distributor for 
electronic components, telecom building blocks and IT & 
infrastructure related products in the Indian sub-continent, South 
East Asia and South Korea.  The company shares a telephone number in 
Singapore with Dexcel Electronics Designs Pte. Ltd, its affiliate 
located at a different address (www.dexceldesigns.com). 
 
¶5.  On April 23, 2008, the ECO, accompanied by a representative of 
Singapore Customs visited the company and met with Mr. Suresh Kumar, 
Director of Business Development, Mr. Rajan Natrajan, Director and 
Ms. Lee, Meng Huey, Head of Logistics.  Mr. Kumar provided an 
overview of the Tecnomic's activities, which are broken into three 
primary areas, namely electronic components distribution, telecom 
platform sales and system integration.  The business is evenly 
divided between these three business lines.  The company has staff 
in several ASEAN countries and a total headcount of approximately 
¶70.  It is a distributor of Intel and Avergo and others.  Typically 
new customers come to the company through various promotion 
activities although the company does receive some Internet generated 
orders. 
 
¶6.  The company is collocated with another company called Fuyo 
Capital.  According to Mr. Natrajan, Fuyo Capital and Tecnomic share 
common owners but are engaged in unrelated businesses. 
 
¶7.   As to the particular items in question, Mr. Natrajan stated 
that those items had been shipped to Free Components Co. Ltd., Rm 
1702, Grand City Plaza, Nos. 1 Sai Lau Kok Road, Tsuen Wan, Hong 
Kong.  The Bill To address on the invoice provided by Mr. Natrajan 
included an additional address for Free Components, namely Unit 
2401A, 24/F, Park-In Commercial Center, 56 Dundas Street, Mongkok, 
Hong Kong.  The Ship To address on the original Purchase Order 
provided by Mr. Natrajan stated that the items should be shipped to 
Xing Hang Yuan Limited, at the 1702 Grand City Plaza address noted 
above.  Free Components is the subject of a pending PSV referenced 
in Reftel B.  Free Components is also linked to two additional 
unfavorable PSVs referenced in Reftels C and D as well as a pending 
administrative enforcement action relating to unauthorized reexports 
from Taiwan to Xing Hang Yuan.  Ms. Lee provided a FedEx airway bill 
showing shipment to Free Components on September 13, 2007. 
 
¶8.  As the conversation turned to a more in-depth discussion of the 
shipment in question, Messrs. Natrajan and Kumar asked, on several 
occasions, whether the reexport to Hong Kong was a problem.  They 
referred to the applicable ECCN entries in the EAR they had printed 
from the BIS web site and noted that the items could ship NLR to 
Hong Kong. They appeared well versed in the requirements of the EAR 
(although the ECO cannot say whether they were familiar with the EAR 
prior to ECO's request for a meeting or became familiar thereafter). 
 
 
¶9.  The company stated that it had done business with Free 
Components two to three times per year in the past.  They understood 
that this company was a consolidator for other customers.  In a 
previous instance, Tecnomic representatives understood that the 
customer was located in India. As a result, they assumed that future 
shipments were also destined for India.  Therefore, in the Purchase 
Order to Actel, they stated that the country of destination for the 
parts was India.  When the ECO pointed out that the contact phone 
 
 
 
numbers for Free Components and Xing Hang Yan Limited were mainland 
China numbers, Tecnomics representatives had no specific response 
beyond the fact that the items had been shipped to Hong Kong.  Note 
that these items (if properly classified by the exporter) may 
generally be exported and reexported to Singapore, India and Hong 
Kong license free but likely require a license to mainland China. 
By separate e-mail, the company forwarded three additional orders 
for the identical items it had filled for Free Components and Xing 
Hang Yuan for a total of 32 items. ECO will forward these documents 
by separate e-mail to OEA. 
 
¶10.  At the time visited, Tecnomic did not appear to be a suitable 
recipient of the commodities shipped since those items had most 
likely been diverted from Singapore to end-users in Mainland China 
in probable violation of the EAR.  Tecnomic's actions in relation to 
the applicable items illustrate either a lack of understanding of 
U.S. export controls or the intent to circumvent U.S. export 
controls (or some combination of the two). ECO recommends a thorough 
review of all shipments to Tecnomic and Free Components (and its 
addresses note above) to determine whether additional shipments are 
worthy of scrutiny.  Additionally, ECO recommends that the BIS 
Office of Export Enforcement conduct an outreach to the U.S. 
exporter to determine what information the exporter had in hand when 
it completed the underlying export to Tecnomic (and to determine 
whether it has made shipments directly to Free Components or Xing 
Hang Yuan Limited or received inquiries from those companies).