VZCZCXYZ0000
RR RUEHWEB

DE RUEHHK #0395 0630900
ZNR UUUUU ZZH
R 040900Z MAR 09
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 7036
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 000395 
 
USDOC FOR 532/OEA/MNICKSON/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: CHINA INTL 
LOGISTICS CO LTD 
 
REF: A) USDOC 00125 
 
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) conducted 
a shipment-verification (PSV) at China International Logistics Co 
Ltd., 9/F Shing Yip Industrial Building, Kwun Tong, Hong Kong (China 
International). The items in question for this PSV are various 
integrated circuits exported to China International on or about 
September 23, 2008.  On the applicable shippers export declaration 
(SED), these items are classified under export control 
classification number (ECCN) 3A001 and, if properly classified, 
would be controlled for national security (NS) reasons.  The 
exporter was Unique Union Inc. of Buena Park,California. 
 
¶3.  According to the Hong Kong Companies Registry, China 
International has been in existence since 2004.  Its paid up share 
capital is the Hong Kong equivalent of USD 1250.  The Hong Kong 
Companies Registry lists Hong Kong resident Chan, Wai Yiu Wallain 
and mainland national When, Yung Eng as directors. 
 
¶4.  A web review reveals that China International is the Hong Kong 
affiliate of Shenzhen Wanshou Industry Co. Ltd. 
(www.wanshoushiye.cn).  Wanshou is an electronics trading and 
logistics company established in 2003.  It has a range of affiliates 
throughout China involved in varied activities such as 
telecommunications products trading and waste water management. 
 
¶5.  On February 25, 2009, ECO accompanied by Commercial Assistant, 
Carrie Chan, visited China International and met with Ms. Lee, 
shipping coordinator (no business card provided).  [Note: The Hong 
Kong offices of China International consist of a small 400 square 
foot room with a small cubicle and open space (for placing 
packages)].  Ms. Lee stated that China International operates purely 
as a warehouse for mainland clients.  In particular, it accepts 
shipments on behalf of mainland customers.  Those customers, in 
turn, appoint transport companies to pick up the shipments to take 
them to the mainland.  The company obtains its clients from 
referrals.  Ms. Lee stated that the company does receive shipments 
on behalf of Acromax (the buyer on documents provided by OEA). 
According to Ms. Lee, there have been three to four shipments since 
July of 2008.  When asked, Ms. Lee was entirely unfamiliar with 
export control rules. [Note:  To be fair, since China International 
apparently neither ships nor orders items, its overall 
responsibilities in this respect are quite limited.]. 
 
¶6.  As to the shipment in question, Ms. Lee stated that the company 
no longer had any documentation related to the applicable items. 
She explained that the shipment had occurred several months prior 
and such documents were typically retained at the company's 
warehouse in Shenzhen. 
 
¶7.  Based on the information noted above, ECO believes China 
International is not a suitable recipient of controlled U.S. origin 
technology.