VZCZCXYZ0001
RR RUEHWEB

DE RUEHHK #0797 1200908
ZNR UUUUU ZZH
R 300908Z APR 09
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 7521
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 000797 
 
USDOC FOR 532/OEA/MHAMES/MCANNER 
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: TECHPRO TECHNOLOGY 
HK CO LTD 
 
REF: A) BIS e-mail request dated March 17, 2009 
 
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 Techpro Technology HK, Co., Ltd., 
14/F World Tech Center, 95 How Ming St., Kwun Tong, Hong Kong 
(Techpro). The items in question for this PSV are various 
transistors exported to Techpro on or about May 19, 2008.  On the 
applicable shippers export declaration (SED), these items are not 
classified meaning that they are likely EAR99 and eligible for 
shipment to virtually all destinations and end-uses/users worldwide. 
 The exporter was Richardson Electronics of La Fox, Illinois. 
 
¶3.  According to the Hong Kong Companies Registry, Techpro has been 
in existence since 2005.  Its paid up share capital is the Hong Kong 
equivalent of USD 1.  The Hong Kong Companies Registry lists Hong 
Kong resident Lau, Fei Fei as director.  The company does not appear 
to have a web presence. 
 
¶4.  On April 3, 2009, ECO accompanied by Commercial Assistant, 
Carrie Chan, visited Techpro and met with Ms. Ada Lau, the owner of 
the business.  Ms. Lau stated that Techpro is a small electronics 
trading company.  Techpro's buyers are typically other trading 
companies (90%)or factories.  Ms. Lau stated that other trading 
companies may use her trading company because she holds some stock 
and because she is willing to provide financing terms that larger 
suppliers may not be willing to provide to smaller, less established 
trading companies buyers.  While ECO found Ms. Lau to be credible 
during the in-person meeting, the business model Ms. Lau described 
is likely not very profitable in light of a range of online and 
larger resellers in the market.  Ms. Lau stated that she obtains 
customers from referrals and repeat business from existing 
companies.  ECO notes that the company is located in a very small 
office in a converted warehouse building. 
 
¶5.  Ms. Lau appeared familiar with Hong Kong export control rules 
and stated that she is prepared to abide by all applicable 
export/reexport regulations.  By separate e-mail, ECO provided Ms. 
Lau with BIS reexport guidance and other BIS web resources. 
 
¶6.  As to the shipment in question, Ms. Lau stated that the items 
were sold to a company called Ristar Ltd. in Hong Kong.  Ms. Lau 
provided an invoice and other documentation confirming receipt in 
Hong Kong by Techpro as subsequent resale to Ristar (at a very 
modest markup).  Ms. Lau stated that the items were going to be used 
in the production of cable television broadcast equipment.  She 
further stated that Ristar had purchased product from Techpro once 
before. 
 
¶7.  Ristar is also a Hong Kong company with Singapore passport 
holder Lim, Kok Tong as director.  It has only nominal share 
capital.  When Commercial Assistant Carrie Chan attempted to call 
the company (a mobile phone was listed), the number was no longer in 
service. The fax number of Ristar corresponds to the fax number of a 
corporate secretarial service in Hong Kong as does Ristar's address 
on the applicable Techpro invoice.  Attempts to reach Ristar though 
the company secretarial service proved to be successful.  Ristar 
representative (in Singapore), Joyce Lim, stated that Ristar had not 
purchased the items from Techpro.  Ms. Lim further confirmed that 
the purported purchase order provided by Techpro was false.  Ms. Lim 
provided a version of a Ristar purchase order to illustrate that 
Ristar's standard purchase order was different than the purported 
Ristar purchase order provided by Techpro. 
 
¶8.  Based on the information noted above, ECO believes Techpro is 
not a suitable recipient of U.S. origin technology.  ECO recommends 
a thorough review of past shipments to Techpro.