VZCZCXYZ0004
RR RUEHWEB

DE RUEHHK #1046 1610924
ZNR UUUUU ZZH
R 100924Z JUN 09
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 7798
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 001046 
 
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 SHIPMEN VERIFICATION: IMAX TECHNICS 
LIMITED (HK) 
 
REF: A) BIS e-mail request dated May 15, 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 post shipment verification (PSV) at Imax Technics Limited, Room 
902, Koon Fork Center, No. 9 Knutsford Terrace Street, Hong Kong 
(Imax). The items in question for this PSV are various integrated 
circuits exported to Imax on or about April 5, 2008.  On the 
applicable shippers export declaration (SED) the items are 
classified under export control classification number (ECCN) 3A001 
and, if properly classified, would be controlled for national 
security (NS) reasons.  Based on documentation provided by the 
exporter, it appears that these items are of the class that may be 
exported license free to Hong Kong, but would require a license for 
export or reexport to mainland China because of their ability to 
function at extreme temperatures (ECCN 3A001a2c). The exporter was 
Avnet of Chandler Arizona. 
 
¶3.  According to the Hong Kong Companies Registry, Imax has been in 
existence since 2001.  The company's paid up share capital is the 
Hong Kong equivalent of USD 1300. The Hong Kong Companies Registry 
lists Ms. Leung, Tor Mui (HK ID number G502057(2)) and Leung, Yuk 
Yung (HK ID number G612734(6)) as directors. 
 
¶4.  Web based research revealed that Imax appears to have a 
relatively limited web presence.  Its web page 
(www.imaxtechnics.com) does not appear to be operational.  The Hong 
Kong Trade and Development Council web site includes a reference to 
the company, noting that it is an exporter of electronic parts. 
 
¶5.  On June 1, 2009, ECO and Commercial Assistant Carrie Chan 
visited the company and met with Ms. Leung Tor Mui.  She provided 
background on Imax, in particular that it is a small electronics 
trading company that has been in operation for some time.  In fact, 
the company is located in a small, one room, office with space for 
two staff. 
 
¶6.  As to the items in question, Ms. Leung showed the ECO a purchase 
order listing For Shing Co. Ltd. as buyer for the items.  The 
purchase order was nearly all hand written with what appeared to be 
a stamped address at the top.  For Shing's address is listed as Rm. 
C, 4/F Lucky Horse Industrial Building, 64 Tong Mi Road, Hong Kong 
with telephone number 2375 5225 and fax number 2375 7229.  Mr. Wong 
is listed as the contact person.  Ms. Leung stated that For Shing is 
a usual customer&Z#QigQkxt\t that Imax had received no 
new orders from For Shing for the past six months.  When asked 
whether Imax had applied for an Hong Kong strategic commodities 
import license for this shipment, Ms. Leung stated that she did not 
recall. When apprised of U.S. export control rules in respect of 
these items, Ms. Leung indicated that she was not aware of those 
rules.  When asked whether she knew the end use/user of the items, 
Ms. Leung stated that she does not ask that of her customers unless 
her supplier (in this case Avnet) requires it. 
 
¶7.  ECO did not find Ms. Leung's answers to be credible.  ECO is 
aware that Imax has, in the past, applied for Hong Kong strategic 
commodities import licenses and confirmation of such licenses are 
typically kept with the underlying order documentation.  The fact 
that such documentation was not available suggests that Imax never 
obtained a license.  ECO likewise suspects that Imax is well aware 
of U.S. export control rules.  ECO sent links to relevant BIS 
information from the BIS web site to Ms. Leung. 
 
¶8.  According to the Hong Kong Companies Registry, For Shing Company 
Limited has been in existence since 1984.  Its paid up share capital 
is the Hong Kong equivalent of USD 1300.  Its directors are listed 
as Pok, Yu Ying (HK ID H371359(A)) and Wong, Hei Min (HK ID 
H359451).  For Shing's web presence is also quite limited.  A local 
SME web site lists the company as being located at Flat C, 5th 
Floor, Hanley Building, No. 68-80 Canton Road, Hong Kong. 
 
¶9.  Commercial Assistance Carrie Chan attempted to arrange a meeting 
with For Shing.  A Mr. Wong answered the phone and initially claimed 
that For Shing had returned the items to Imax (Imax denied this). 
Mr. Wong further stated that he had no documents available to 
confirm that statement.  During a subsequent call, Mr. Wong stated 
that the person responsible for the order had left the company and 
that he did not have any documents to share.  When asked for a 
meeting, Mr. Wong hung up the phone. 
 
¶10.  Based on the information noted above, ECO believes that Imax 
and For Shing are not reliable recipients of U.S. origin technology. 
 ECO recommends a thorough review of all shipments to Imax, For 
Shing and their respective addresses.