VZCZCXYZ0007
RR RUEHWEB

DE RUEHHK #1059/01 1620857
ZNR UUUUU ZZH
R 110857Z JUN 09
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 7815
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 001059 
 
USDOC FOR 532/OEA/MCANNER/MHAMES 
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: 
ASKEY TECH LIMITED; JOINTWAY ELECTRONICS LTD.; WINSUNY TECH (HONG 
KONG) LTD. 
 
REF: A) BIS EUC request e-mails dated May 26, 2009; B) HK 01087 
(2008) regarding Winsuny and Cam-IC; C) HK 00604 (2009) regarding 
Techwing, Askey and Jointway; D) HK 002146 regarding Cam-IC, Winsuny 
and Techwing 
 
 
¶1. Unauthorized disclosure of the information provided below is 
prohibited by Section 12C of the Export Administration Act. 
 
¶2. As per reftel A requests 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) attempted 
to conduct post shipment-verifications (PSVs) at three Hong Kong 
consignees, namely (1) Askey Tech Limited, Units 701-703, 7/F Shing 
Yip Industrial Building, 19-21 Shing Yip Street, Hong Kong (Askey); 
(2) Jointway Electronics Ltd. at the same address (Jointway); and 
(3) Winsuny Tech (Hong Kong) Ltd., Rm 1405 A, Chungkiu Commercial 
Building, 47-51 Shantung Street, Mong Kok, Hong Kong (Winsuny).  The 
items in question include a range of electronic components and, in 
one instance, acoustic beacons sent to these consignees by a range 
of U.S. exporters.  On the applicable shippers export declarations 
(SEDs), most of 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 exporters, in some instances, it 
appears that the applicable 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).  Each consignee 
(and related shipments) is considered in turn below. 
 
¶3.  As detailed in reftels B-D, Askey, Jointway and Winsuny are 
related to each other and to additional companies Cam-IC and 
Techwing Electronics Limited through common ownership or course of 
dealing.  Winsuny, Techwing and Cam-IC were the subject of prior 
unfavorable end use checks involving diversion of national security 
controlled commodities to mainland China (summarized in reftels 
B-D).  Additional information about all of these companies can be 
found in the applicable cables and is therefore not repeated 
herein. 
 
¶4.  Jointway Electronics Limited Shipments Summary:  The first 
shipment for these PSVs included an acoustic beacon exported to 
Jointway by Dukane Corporation of St. Charles, Illinois.  Dukane 
Corporation classified the beacon as falling under ECCN 6A991 which 
is controlled for anti-terrorism reasons (AT) and may be exported to 
Hong Kong and mainland China without a license unless end-use and 
end-user restrictions apply.  The second shipment involved 
electronic components exported to Jointway by SG Industries of 
Beverly, Massachusetts.  SG Industries classified the components 
under ECCN 3A001 which is controlled for national security (NS) 
reasons. 
 
¶5.  Jointway PSV Results:  Commercial Assistant Carrie Chan 
attempted, on multiple occasions to schedule a meeting with 
Jointway.  The Hong Kong Post Office confirmed that Jointway 
received the ECO's written request for a meeting.  While Ms. Chan 
was able to make an initial contact with the company and request a 
meeting, subsequent calls went unanswered.  ECO believes that as a 
result of the PSV detailed in reftel C, Jointway will not agree to 
meet with the ECO.  Should that change, ECO will inform OEA. 
 
¶6.  Askey Tech Limited Shipments Summary:  The first two shipments 
for these PSVs were sent by Azego Technology Services of Upper 
Saddle River, New Jersey while the third shipment was sent by Digi 
Key Corporation of Thief River Falls, Minnesota.  Digi-Key 
classified its shipments of electronic components under ECCN 3A001a5 
which is controlled for national security (NS) reasons and is of the 
class of items that may be exported license free to Hong Kong, but 
would require a license for export or reexport to mainland China. 
Azego classified its items as EAR99, meaning that those items may be 
shipped to virtually all end users (uses) worldwide license free. 
In its order documentation with Digi-Key, Askey claims that it is 
purchasing the applicable items for Techwing.  One Azego shipment is 
in response to a Techwing purchase order (listing the ship to 
address as Askey but at the Winsuny location) while the second order 
documentation lists, alternatively, Askey and Techwing as the 
purchaser.  ECO recommends a close review of this order 
documentation. 
 
¶7.  Askey PSV Results:  Commercial Assistant Carrie Chan attempted, 
on multiple occasions to schedule a meeting with Askey.  The Hong 
Kong Post Office confirmed that Askey received the ECO's written 
request for a meeting.  Ms. Chan calls to Askey went unanswered. 
ECO believes that as a result of the PSV detailed in reftel C, Askey 
will not agree to meet with the ECO.  Should that change, ECO will 
 
inform OEA. 
 
¶8.  Winsuny Tech Shipments Summary:  These PSVs involve five 
shipments by four exporters.  All shipments involve electronic 
components controlled under ECCN 3A001 and controlled for national 
security (NS) reasons.  Two shipments, from Rochester Electronics, 
involve electronic components classified under ECCN 3A001a2c.  That 
ECCN may be exported license free to Hong Kong but would require a 
license for shipment to mainland China. Rochester Electronics 
shipments have been the subject of multiple unfavorable end use 
checks involving a range of electronics resellers in Hong Kong.  ECO 
finds it noteworthy that the Winsuny order documents for these two 
shipments both list the Winsuny Hong Kong address as well as the 
Winsuny Shenzhen address.  Additional shipments of ECCN 3A001 
electronic components were made by CMB Components of Holbrook, New 
York, Electronic Expediters of Camarillo, California and Microram 
Electronics, Inc. of Oldsmar, Florida. 
 
¶9.  Winsuny PSV Results:  Commercial Assistant Carrie Chan 
attempted, on multiple occasions to schedule a meeting with Winsuny. 
 Initial calls were quite short and were but off after a few 
seconds.  Eventually, after several days of trying by Ms. Chan, the 
phone was listed as disconnected. The Hong Kong Post Office 
confirmed that Winsuny received the ECO's written request for a 
meeting. ECO believes Winsuny will not agree to meet with the ECO. 
Should that change, ECO will inform OEA. 
 
¶10.  All three consignees are unsuitable recipients of U.S. origin 
controlled technology.  ECO recommends that BIS reach out to the 
exporters to determine what they knew about the final destination of 
their shipments to Winsuny when those shipments were made.