VZCZCXYZ0010
RR RUEHWEB

DE RUEHHK #2329 3570004
ZNR UUUUU ZZH
R 230004Z DEC 09
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 9228
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 002329 
 
USDOC FOR 532/OEA/ 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: MAXLINK INDUSTRIES 
LTD. 
 
REF: A) BIS e-mail request 01210009 
 
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 Maxlink Industries Ltd., Unit 
710, Grand City Plaza, 1 Sai Lau Kok Road, Tsuen Wan, Hong Kong 
(Maxlink). The items in question for this PSV are two high 
performance, low power dual 8-bit, 1.5 GSPS A/D converters exported 
to Maxlink on or about February 26, 2009.  These items are likely 
classified under Export Control Classification Number (ECCN) 
3A001a5a1 and are controlled for national security (NS) reasons. 
This ECCN is eligible for shipment to Hong Kong license free but 
would, in virtually all circumstances, require a license for 
shipment to mainland China.  The exporter is Arrow Electronics of 
Reno, Nevada. 
 
¶3.  According to the Hong Kong Companies Registry, Maxlink has been 
in existence since 1998.  Its paid up share capital is the Hong Kong 
equivalent of USD 10.  The Hong Kong Companies Registry lists 
Canadian national, Long, Yangxin (PP#BA527589) as director.  Long, 
Yangxin is also a director in a range of other Hong Kong registered 
companies including ITSmart Limited, Maxlink Industries Limited, 
Maxlink Global Limited, Seatech International Asia Limited, Seatech 
International Holdings Limited, UniHz Holdings Limited and UniHz 
International Limited.  Long, Yangxin is the sole director in each 
of these companies except for Seatech International Asia Limited. 
In this company, U.S. nationals Blatt, Michael (PP#202083327) and 
Schneider, Bruce Howard (PP#017007730) are also directors.  Messrs. 
Schneider and Blatt are not listed as directors in any other Hong 
Kong registered companies. 
 
¶4.  Web research reveals that Maxlink is the Hong Kong logistics 
center for Seatech International (www.seatech-international.com). 
Seatech has offices in Milpitas, California as well as Shenzhen, 
China and Northolt, UK.  According to its website, Seatech 
International has its headquarters in the United States and is a 
leading independent distributor of semiconductors, electronic 
components, computer products and networking equipment.  UniHz 
Technologies Co., Ltd. has its own web site, namely www.unihz.com, 
where it states that this company is a leading intelligent 
transportation system supplier in China.  It is noteworthy that 
Maxlink is located in the same building (but different floor) as 
several additional companies of diversion concern including Free 
Components, ARI International and in the building next door to Huge 
Source, a third company of diversion concern. 
 
¶5.  On December 3, 2009, ECO and FCS Commercial Assistant Carrie 
Chan visited the company and met with Mr. Pak, salesperson.  The 
company is located in a warehouse and offices building and has space 
for several desks, a reception area and two small offices. 
According to Mr. Pak, Maxlink serves as warehouse and well as 
trading company for Seatech. 
 
¶6.  Mr. Pak stated that Seatech's China headquarters are located in 
Shenzhen and that some of the underlying documentation for this 
order (the customer purchase order, for example) is located in 
Shenzhen.  Seatech/Maxlink customers are located in mainland China, 
Thailand, Malaysia, Singapore and Korea.  Approximately fifty 
percent of the company's business is for local delivery while fifty 
percent is for international sale.  Mr. Pak stated that shipments to 
China are sent to manufacturers but he is not familiar with what is 
being made with Maxlink components.  When asked, Mr. Pak stated that 
Maxlink obtains HKTID import and export licenses for its products. 
When pressed, it became apparent that Mr. Pak was referring to 
another type of license.  Mr. Pak stated that he has only been with 
the company for two months. 
 
¶7.  As to the items in question, Mr. Pak provided documentation (an 
invoice) confirming that the items had been sold to the Harbin 
Institute of Technology (HIT) in mainland China.  According to 
online research, HIT is a larger university in Harbin that is known 
for its space and defense related research. 
 
¶8.  ECO explained the importance of complying with export controls 
and, by separate e-mail, provided Mr. Pak with information on BIS 
and HKTID controls. 
 
¶9.  ECO does not believe Maxlink is a suitable recipient of 
controlled U.S. origin technology.  ECO further recommends that BIS 
Office of Export Enforcement follow up with Seatech in the United 
States as the underlying documentation appears to indicate that it 
may be been aware that the items were destined for HIT when the 
transaction was completed.