VZCZCXYZ0004
RR RUEHWEB

DE RUEHHK #0527 0790736
ZNR UUUUU ZZH
R 200736Z MAR 09
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 7201
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 000527 
 
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: WT 
MICROELECTRONICS CO., LTD 
 
REF: A) USDOC 00130 
 
¶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 WT Microelectronics Co., Ltd., 
9/F Shield Industrial Center 8, Hong Kong (WT). The item in question 
for this PSV is one C-DDS synthesizer evaluation board exported to 
WT on or about May 8, 2008.  On the applicable shippers export 
declaration (SED), the item is classified as EAR99, meaning that, if 
properly classified, it could be exported/reexported license free to 
virtually all destinations and end-users worldwide. Internal 
documentation from the exporter states that the item in question is 
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 Analog Devices of Norwood, 
Massachusetts. 
 
¶3.  According to the Hong Kong Companies Registry, WT has been in 
existence since 1998. Its paid up share capital is the Hong Kong 
equivalent of USD 100 million.  The Hong Kong Companies Registry 
lists several Taiwanese nationals as directors. 
 
¶4.  A review of the WT's web site (www.wtmec.com) reveals that WT 
specializes in the distribution of electronic components.  It is a 
Taiwan based company with offices throughout the Asia pacific 
region. 
 
¶5.  On February 23, 2009, ECO visited the company at the address 
noted above and met with Kevin Lau, Associate Manager.  He stated 
that the Hong Kong operation of the company operates primarily as a 
warehouse and back-office support operation for the company's 
operations.  WT does not have local, Hong Kong, customers.  Mr. Lau 
stated that WT applies for Hong Kong export licenses when their 
suppliers tell them that the items in question may be subject to 
control.  Mr. Lau also stated that, from time to time, he checks the 
Hong Kong Trade and Industry (TID) Department web site that lists 
items subject to Hong Kong strategic trade control.  Mr. Lau 
stressed that the company complies with applicable export control 
rules and obtains licenses where required.  In this particular 
instance, Mr. Lau stated that he checked the TID web site and 
determined that the item does not require a license for export from 
Hong Kong (Note:  if correct, this would mean that it is unlikely 
that this item would require a U.S. export license for 
export/reexport to mainland China). 
 
¶6.  Mr. Lau stated that the customer for this item was Beijing 
Joinsemi.  He stated that this company is also an electronics 
reseller (www.joinsemi.com).  Mr. Lau stated that he believed the 
end-user of the item was an observatory in China but was not sure of 
the exact name.  By subsequent e-mail, Mr. Lau stated that he had 
received information from Joinsemi, namely that the end-user was a 
graduate student working at the Yunnan Astronomical Observatory 
Chinese Academy of Science.  That student was using the item to 
conduct certain tests. 
 
¶7.  ECO recommends that BIS review the underlying documentation of 
this transaction (as well as the technical specifications of the 
item) to determine whether a license was required for shipment of 
this item to mainland China.  Based on the facts in hand, ECO 
believes WT to be a reputable recipient of U.S. origin technology 
(as reseller).