VZCZCXYZ0022
RR RUEHWEB

DE RUEHHK #2338 3570703
ZNR UUUUU ZZH
R 230703Z DEC 09 ZDK
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 9243
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 002338 
 
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: PEACEFUL VISION 
 
REF: A) BIS e-mail request dated December 3, 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 Peaceful Vision, Ltd., Flat 
13, 8/F, Block A, Hunghom Commercial Center, 39 Ma Tau Wai Road, 
Hung Hom Hong Kong (Peaceful Vision). The items in question for this 
PSV are various field programmable gate arrays exported to Peaceful 
Vision on or about October 29, 2008.  These items are likely 
classified under Export Control Classification Number (ECCN) 
3A001a7a and are controlled for national security (NS) reasons. 
This ECCN is eligible for shipment to Hong Kong license free and 
eligible for license exception CIV (civil end use) to mainland 
China. The exporter is Nu Horizons International of Southaven, 
Massachusetts. 
 
¶3.  According to the Hong Kong Companies Registry, Peaceful Vision 
has been in existence since 1996. Its paid up share capital is the 
Hong Kong equivalent of USD 250,000.  The Hong Kong Companies 
Registry lists Cen, Guan Hua and Lu, Jin Feng (both likely Mainland 
nationals) as directors.  These two individuals do not appear to be 
directors in any other Hong Kong registered companies. 
 
¶4.  Web research reveals that Peaceful Vision is an electronics 
reseller (www.peacefulv.com).  The company website states that the 
company has several offices in mainland China as well as a European 
office in Zaventem, Belgium.  In addition, the company website 
provides that the company focuses on the military components 
business around the world with an emphasis on aircraft, weapons, 
ship and military industrial applications for domestic and 
international customers.  Based on additional web research, it 
appears that Peaceful Vision is related to additional companies, 
Heng Star International, Yiu Star International and Ying Ke 
Electronics (www.peaceful.icbuy.com). 
 
¶5.  On December 17, 2009, ECO and FCS Commercial Assistant Carrie 
Chan visited the company and met with Ms. Tong, salesperson.  Ms. 
Tong had no business card to provide to ECO.  According to Ms. Tong, 
Peaceful Vision is a trading company whose customers include other 
trading companies in Hong Hong and China.  The company has 
affiliates in other cities in China, including Shenzhen (where this 
transaction originated).  Ms. Tong stated that the company acquires 
components on behalf of customers based only on product numbers and 
that she was not familiar with the end-users or end uses of these 
items (or, for that matter, for most items Peaceful Vision 
acquires).  Ms. Tong stated that virtually all customers are located 
in Hong Kong and China although some have, in the past, been located 
in the Philippines, Singapore and the United States. 
 
¶6.  As to this particular order, Ms. Tong stated that she was 
unaware of the end use of the items. She also stated that she did 
not recall if Peaceful Vision had obtained the required Hong Kong 
TID import license for these items (ECO does not believe such 
license was obtained).  When asked about products in the military 
temperature range, Ms. Tong stated that reference to such products 
was done for trade promotion purposes (suggesting, ECO supposes, 
that the company does not actively deal in these products). 
Information independently obtained by ECO shows that Peaceful Vision 
acquired (in 2008), electronic components rated for operation in the 
military temperature range. 
 
¶7.  Ms. Tong provided a purchase order and invoice for this order 
listing the purchaser as Shenzhen Ke Ying.  She stated that this 
customer picked up the items at Peaceful Vision's Hong Kong offices. 
Ms. Tong did not clarify (as ECO subsequently surmised) that the 
customer is an affiliate of Peaceful Vision (the customer fax number 
is the same as the fax number for Peaceful Vision in Shenzhen).  Ms. 
Tong stated that Peaceful Vision's Shenzhen office had generated the 
Purchase Order directly to Nu Horizons.  As a result, Ms. Tong was 
unaware whether an end user statement had been provided to Nu 
Horizons in respect of this shipment. 
 
¶8.  By separate e-mail, ECO relayed export control information 
(including BIS and HKTID information) to Ms. Tong. 
 
¶9.  Based on the circumstances of the EUC, ECO cannot recommend that 
Peaceful Vision be considered a reliable recipient of U.S. origin 
controlled technology.  ECO recommends that BIS reach out to the 
exporter to determine what information it had on hand as to the end 
use and end user prior to shipment to Peaceful Vision (in light of 
Peaceful Vision's apparent focus on sales of military related ICs).