VZCZCXYZ0001
RR RUEHWEB

DE RUEHHK #2320 3650013
ZNR UUUUU ZZH
R 300013Z DEC 08
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 6537
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 002320 
 
USDOC FOR 532/OEA/LHINES/ADYSON 
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR PATRICK SANTILLO 
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: EXODUS 
MICROELECTRONICS CO. 
 
REF: A) USDOC 06824 B) USDOC 06825 C) HK 00001(2008) D)HK 00966 
(2008) 
 
1.Unauthorized disclosure of the information provided below is 
prohibited by Section 12C of the Export Administration Act. 
 
¶2. As per reftel A and B requests 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 Exodus 
Microelectronics Co., Unit 9B, Nathan Commercial Building, 430-436 
Nathan Road, Kowloon, Hong Kong (Exodus). The items in question for 
the check referenced in reftel A are semiconductors exported to 
Exodus on or about August 18, 2006 and valued at USD 5,200.  The 
items in question for the check referenced in reftel B are 
semiconductors exported to Exodus on or about May 31, 2005 and March 
23, 2005 with a combined value of USD 4,060.  All of these items are 
classified under export control classification number (ECCN) 3A001 
and, if properly classified, would be controlled for national 
security (NS) reasons.  These appear to be items that may be shipped 
license-free to Hong Kong but would, in virtually all circumstances, 
require a license for shipment to mainland China. The exporter was 
QP Semiconductor of Santa Clara, California. 
 
¶3.  As further detailed in reftels C and D, Exodus is related to a 
range of other problematic companies in Hong Kong including Victory 
Wave, Echelon Microsystems Limited and Centre Bright, among others. 
These companies are, in turn, related or conduct business with a 
range of problematic mainland China companies.  Based on information 
received from an industry source, ECO believes that the directors 
and shareholders of Exodus, Centre Bright, Victory Wave and Echelon 
are all members of the same family (parents and adult son).  A 
review of the Hong Kong Companies Registry reveals that Exodus 
Microelectronics Company Limited was established in March 2003 and 
had paid-up share capital of HKD 10,000 (the Hong Kong equivalent of 
USD 1250).  The registered office of the company is listed as Unit 
6B, Block 1, International Center, 2-8 Kwei Tei Street, Shatin, Hong 
Kong. 
 
¶4.  As detailed further in reftel C, Mr. Wong, Yung Fai is the 
director of Victory Wave.  He is also a director of Exodus.  During 
the PSV of Victory Wave, Mr. Wong, Yung Fai claimed that Exodus 
never sources items from the United States. That claim is clearly 
false. 
 
¶5.  A web search reveals that Exodus does not appear to have its own 
web presence.  It is, however, listed as a partner of Centre Bright 
(referenced above).  In the description of Exodus listed on the 
Centre Bright web site, Exodus is listed as being a provider of 
military grade semiconductors.  Another company's web site lists 
Exodus as a partner (www.elnec.sk) and the Exodus link on that 
company's web site links to the Centre Bright web site. 
 
¶6.  FCS Commercial Assistant Carrie Chan attempted, on several 
occasions, to set up a meeting with representatives of Exodus.  When 
made aware of the purpose of the ECO's proposed visit, the staff 
person answering the phone hung up.  ECO subsequently sent a 
registered letter to Exodus requesting a meeting.  The Hong Kong 
Post Office confirms that the letter was rejected as undeliverable 
(no such company at the listed address.  ECO remains unable to 
schedule the PSV. 
 
¶7. Based on the information noted above, ECO believes that Exodus is 
a most unsuitable recipient of U.S. origin controlled technology. 
ECO recommends that BIS reach out to QP Semiconductor to determine 
what information it had on hand when it shipped the items.  Further, 
ECO requests that OEA confirm the 3A001 classification of the 
shipment so that ECO may reach out to Hong Kong TID concerning a 
potential violation of Hong Kong's export control rules in 
connection with this shipment.  Finally, ECO recommends that Exodus 
be added to the BIS Unverified List and/or Entities List.