VZCZCXYZ0002
RR RUEHWEB

DE RUEHHK #1507 2280235
ZNR UUUUU ZZH
R 150235Z AUG 08
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 5567
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 001507 
 
USDOC FOR 532/OEA/LHINES/ADYSON 
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: BOSCH SECURITY 
SYSTEMS LTD 
 
REF: A) USDOC 03399 
 
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 post shipment-verifications (PSV) at Bosch Security 
Systems Ltd., 12/F Metropole Square, 2 On Yiu Street Shatin, Hong 
Kong (Bosch). The items in question are 1000 semiconductors exported 
to Bosch on or about March 31, 2006 and valued at USD 20,790. On the 
applicable shippers export declaration (SED), these items are 
classified as EAR99 and, if properly classified, can be 
exported/reexported to virtually all destinations and end-users 
(except certain sanctioned countries and restricted end-users/uses). 
 The exporter was Rochester Electronics of Newburyport, 
Massachusetts. 
 
¶3.  According to the Hong Kong Companies Registry, Bosch has been in 
existence since 1994.  Its paid up share capital is the Hong Kong 
equivalent of USD 300,000.  U.S. nationals Eric Behlke George and 
Christopher Paul Gerace and German national Uwe Glock are listed as 
directors.  Bosch in Hong Kong is part of the Bosch Group, an 
international global supplier of automotive and industrial 
technology, consumer goods and building technology.  The Group has 
more than 270,000 employees.  Bosch in Hong Kong provides a range of 
products in the security field including intrusion systems, motion 
detectors and fire alarms as well as analog and digital video 
systems and components (www.boschsecurity.com.hk). 
 
¶4.  Commercial Assistant Carrie Chan attempted for some time to 
arrange a time to conduct the PSV.  Eventually, Ms. Chan was able to 
speak with Mr. Jack Watt at Bosch who explained that the Bosch Hong 
Kong operation is now only a sales office and it does not have 
information about past shipments (that came through Bosch when the 
Hong Kong operation still handled logistics matters for the Bosch 
China operation).  Since the time of the shipment in question, Bosch 
has outsourced its logistics operations in Hong Kong to DHL. 
 
¶5.  Steven Wong of DHL was able to locate and provide to ECO copies 
of documentation regarding the shipment in question.  That 
documentation confirmed that the items in question had been received 
by Bosch's warehouse in Hong Kong.  According to Mr. Wong, the 
documents confirming subsequent reexport to mainland China for use 
in Bosch's manufacturing process were lost when Bosch's logistics 
operations were outsourced to DHL.  ECO finds Mr. Wong's explanation 
to be credible. 
 
¶6.  At the time visited, Bosch appeared to be a suitable recipient 
of the subject commodities as it cooperated with the PSV and is 
involved in production of various products that likely make use of 
electronic components such as the ones that were the subject of this 
PSV.