VZCZCXYZ0002
RR RUEHWEB

DE RUEHHK #0513/01 0780645
ZNR UUUUU ZZH
R 190645Z MAR 09
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 7181
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 000513 
 
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: CHESTER VIEW LTD. 
 
REF: A) USDOC 07198 
 
¶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 post shipment-verification (PSV) at Chester View Ltd., 1/Fl Mau 
Lam Commercial Bldg, 16-18 Mau Lam Street, Hong Kong (Chester View). 
The items in question for this PSV are four pulse generators 
exported to Chester View on or about September 27, 2008.  On the 
applicable shippers export declaration (SED), the items are 
classified under export control classification number (ECCN) 3A002. 
This ECCN is one of a group of ECCNs that do not require a license 
for export/reexport to Hong Kong but may require a license to 
mainland China.  The exporter was Quantum Composers Inc., of 
Bozeman, Montana. 
 
¶3.  According to the Hong Kong Companies Registry, Chester View has 
been in existence since 2005. Its paid up share capital is the Hong 
Kong equivalent of USD 1250.  The Hong Kong Companies Registry lists 
Indian national, Mr. Anand Vardhan as director. 
 
¶4.  A review of the Chester View's web site (www.chesterviewltd.com) 
reveals that Chester View specializes in the manufacturing and 
distribution of a range of electrical and electronic test equipment. 
 It claims to be able to provide turn-key test solutions for defense 
and aerospace applications and states that Chester View customers 
are R&D and manufacturing companies in the defense, space, 
aeronautical, automobile, telecom and electronic sectors.  The web 
site does not include any phone or e-mail contact information. 
 
¶5.  Further web research reveals that the company is located at the 
address of Buttar HK Limited, a corporate secretarial service that 
appears to cater to Indian companies.  According to the Hong Kong 
Companies Registry, Mr. Vardhan is also a director in three other 
companies, namely Max Star Electronics Technology Limited (no 
apparent web presence), RSL-Electronics Limited (www.rsl.co.il) and 
Vincent Asia Pacific Limited (www.vincentasiapacific.com).  RSL 
Electronics is an Israeli developer and manufacturer of control 
diagnostics and prognostics systems for aerospace, marine and land 
applications.  The Israeli company claims widespread use in military 
applications worldwide. Vincent claims to have maintenance and 
repair facilities for BARCO in the Asia Pacific region (more on 
BARCO below). 
 
¶6.  It took over two months to finally arrange a meeting with Mr. 
Vardhan regarding this shipment. He claimed to be on extensive 
travel in the region and India.  It became clear that Mr. Vardhan 
does not reside in Hong Kong and it does not appear that the company 
has any other employees or physical location save for the modest 
offices of Buttar HK Limited. 
 
¶7.  On March 9, 2009, ECO visited the company at the address noted 
above and met with Mr. Vardhan, Director.  He stated that Chester 
View is a trading company set up in 2005.  He stated that he 
operates in Hong Kong because it is easier than operating out of 
India.  His primary market is India.  He also stated that Vincent 
and Max Link (referenced above) are dormant trading companies.  He 
has just begun a collaboration with RSL (he described this company 
as providing equipment to conduct diagnostics for wind energy 
turbines).  He does not sell to mainland China. 
 
¶8.  Mr. Vardnan stated that the customer for the items in question 
was BARCO (Belgian American Radio Company).  This company 
manufactures wall screens and monitors and the items are to be used 
in the testing of display systems (www.barco.com).  Mr. Vardnan 
states that the items were for use in India and he provided 
documentation confirming that the items had been transferred in Hong 
Kong to BARCO's designated freight forwarder.  Mr. Vardnan provided 
additional documentation confirming sale of additional units of the 
same product to Bharat Electronics in India (likely for military 
use). 
 
¶9.  Mr. Vardnan was open and cooperative during the interview and 
stressed his willingness to comply with U.S. export controls.  ECO 
provided by subsequent e-mail various additional information about 
U.S. export controls.  ECO found Mr. Vardnan to be credible in his 
explanations. 
 
¶10.  In light of various aspects of this PSV (no apparent Chester 
View Hong Kong physical location, delay in scheduling check, 
unorthodox shipping pattern), ECO hesitates to declare that Chester 
View is a suitable recipient of U.S. origin technology.  At the same 
time, ECO notes that Mr. Vardnan's statements were credible and ECO 
can find no evidence that any violations of the Export 
Administration Regulations occurred in connection with the 
transactions that were the subject of the PSV.  ECO requests that 
 
OEA conduct a review of the technical specifications of the items to 
determine whether a license was required for their shipment to Hong 
Kong and subsequent reexport to India.