VZCZCXYZ0000
RR RUEHWEB

DE RUEHHK #2321 3650013
ZNR UUUUU ZZH
R 300013Z DEC 08
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 6538
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 002321 
 
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: VICTORY WAVE 
HOLDINGS LTD. 
 
REF: A) USDOC 06826 B) HK 00001(2008) C)HK 00966 (2008) D) HK 02563 
(2007) E) USDOC 02564 F) USDOC 02565s 
 
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 Victory Wave 
Holdings Ltd., Unit 2401A, Park-In Commercial Centre, 56 Dundas 
Street, Hong Kong (Victory Wave). The items in question for this 
check are 8-bit D/A converters transferred to Victory Wave by Arrow 
Electronics on or about June 4, 2007 and July 12, 2007. 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.  The company that sold the items to 
Victory Wave was Arrow Asia, the Hong Kong branch office of Arrow 
Electronics in the United States. 
 
¶3.  As further detailed in reftels B-D, Victory Wave was the subject 
of a prior PSV and is implicated (directly or indirectly) in several 
additional unfavorable PSVs.  It is also related to several other 
problematic companies in Hong Kong including Exodus Microelectronics 
(the subject of reftels E and F), 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 the corporate information concerning Victory 
Wave has not changed since the date of the Victory Wave PSV 
referenced in reftel B. 
 
¶4.  FCS Commercial Assistant Carrie Chan attempted, on several 
occasions, to set up a meeting with representatives of Victory Wave 
at a range of contact numbers (including those provided by OEA).  No 
one answered at any of the applicable numbers.  ECO subsequently 
sent a registered letter to Victory Wave requesting a meeting.  The 
Hong Kong Post Office confirms that a representative of Victory Wave 
signed for the letter at the Park-in Commercial Centre address; 
however, ECO remains unable to schedule the PSV and has not heard 
further from Victory Wave. 
 
¶5. Based on the information noted above, ECO believes that Victory 
Wave is a most unsuitable recipient of U.S. origin controlled 
technology.  Further, ECO recommends that Victory Wave be added to 
the BIS Unverified List and/or Entities List.