VZCZCXYZ0001
RR RUEHWEB

DE RUEHHK #0005/01 0040159
ZNR UUUUU ZZH
R 040159Z JAN 10
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 9305
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 000005 
 
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: Y&W ENTERPRISES 
 
REF: A) BIS e-mail request 01210095 dated November 5, 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 Y&W Enterprises Co, Room 603, 
Elite Industrial Center, 883 Cheung Sha Wan Road, Hong Kong (Y&W). 
The items in question for this PSV are various EEPROMs and dual port 
static ram exported to Y&W on or about February 18, 2009.  These 
items are likely classified under Export Control Classification 
Number (ECCN) 3A001a2c 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 
International of Reno, Nevada. 
 
¶3.  According to the Hong Kong Inland Revenue Department's Business 
Registration Office, Y&W has been in existence since 1995.  Yiu, 
Chung Tsap (HKID# C3169063) is listed as the sole proprietor. 
 
¶4.  Y&W markets itself on various web sites as an electronic 
components reseller. It does not appear to have an operational web 
site. 
 
¶5.  On November 18, 2009, ECO and FCS Commercial Assistant Carrie 
Chan visited the company and met with Ms. Chan, Manager.  According 
to Ms. Chan, Y&W is a trading company focused on various electronic 
components.  Its primary customers are other trading companies 
located in Hong Kong and mainland China although the company 
apparently also has customers in Singapore, the United States, India 
and West Germany.  Ms. Chan stated that other trading companies go 
to Y&W rather than directly to distributors like Arrow because, 
according to Ms. Chan, Y&W has better relationships with those 
distributors. 
 
¶6.  As to the particular order in question, Ms. Chan provided 
documentation confirming receipt of the items as well as invoices 
indicating further sale to other companies in Hong Kong (with 
corresponding customer chops confirming receipt of the items in the 
invoices).  As to the dual port static ram, Mr. Chan provided 
invoices showing sale of 1001 units to Hanford (HK) Ltd., 901-903 
Century Center, 44-46 Hung To Road, Hong Kong.  A Mr. Chan (phone 
numbers: 97420760 and 25911689) is listed as the contact person. 
Ms. Chan also provided an invoice showing sale of 200 dual port 
static ram to New White Industry Ltd. (phone:  852 6635 1162), room 
C-5, Wing Hing Industrial Building, 14 Hing Yip Street, Hong Kong. 
As to the EEPROMs, Ms. Chan provided an invoice showing sale to CME 
Enterprises, Rm. 622, 6/F, Kowloon Bay Industrial Centre, 15 Wang 
Hoi Road, Hong Kong (phone: 25420385 and fax: 25422941).  In three 
of the four cases, payment terms are listed as cash on delivery 
(COD).  Ms. Chan stated that she is unaware of the end uses or users 
of these items and seldom asks customers for this information. 
 
¶7.  When ECO explained that some items require export licenses, Ms. 
Chan initially stated that she was unfamiliar with export controls 
and had not heard about them before.  Later, when ECO showed Ms. 
Chan a copy of Y&W's Customer Certification of End Use and Export 
Compliance (a document required by the supplier, Arrow Electronics), 
Ms. Chan conceded that she was familiar with the document and that 
she had signed it.  She then stated that Y&W regularly receives 
documents with similar language from suppliers but that since Y&W 
only deals with local (Hong Kong) customers, it doesn't apply for 
licenses.  ECO then asked whether Y&W had obtained the obligatory 
Hong Kong import license for these items.  Ms. Chan stated that she 
was not sure but that Y&W sometimes applies for licenses.  Ms. Chan 
agreed to look for the import license and revert to ECO if she finds 
it.  ECO is confident Y&W did not receive a Hong Kong import license 
for these items.  ECO provided Ms. Chen with BIS's reexport controls 
guidance brochure and offered to answer any export control related 
questions Y&W might have going forward. 
 
¶8.  New White Background:  ECO was unable to find any corporate 
registry or other information for New White Industry Ltd. 
Commercial Assistant Carrie Chan left a message at the number listed 
on the New White invoice but no response has been received yet. 
According to Y&W's Ms. Chan, New White is a mainland Chinese company 
and its representative comes to Hong Kong from time to time. 
 
¶9.  Hanford Background:  According to the Hong Kong Companies 
Registry, Hanford has been in existence since 2000.  It has the Hong 
Kong equivalent of USD 35,000 in share capital.  Hong Kong 
residents, Chen, Qigang and Lu Wuliang are listed as directors. 
Chen, Qugang is also listed as a director in Kaplex Limited.  Lu, 
Wuliang is listed as a director in Forox (Hong Kong) Limited, Info 
Talent Technology Limited and Xoro Electronics (Hong Kong) Limited. 
 
 
¶10.  Hanford Visit:  On December 18, 2009, ECO and Commercial 
Assistant Carrie Chan visited Hanford (at the address noted above) 
and met with Mr. Charles Chen, Managing Director.  According to Mr. 
Chen, Hanford is an electronic components trading company that sells 
primarily to mainland China.  Its typical customers are other 
trading companies. It finds buyers and suppliers on web sites like 
IC Source and Partminer.com.  As to the items in question (dual port 
static ram), Mr. Chen stated that they had been sold to the China 
National Machinery Import and Export Corporation in Beijing.  He 
provided an airway bill confirming such shipment.  When asked for 
end use and end user information, Mr. Chen stated that he did not 
know the end user name.  He stated that he had been informed that 
these items were for use in fishing boat communications equipment. 
When asked why a fishing boat communication system would need a high 
temperature range communication system, Mr. Chen stated that he was 
not familiar with the system so didn't know for sure. Mr. Chen 
stated that he was unfamiliar with Hong Kong and BIS export control 
rules.  Subsequently, Mr. Chen stated that he sees export control 
language in U.S. exporter documentation.  In this case, he stated 
that he believed the items were common items and therefore not 
subject to a licensing requirement.  ECO provided Mr. Chen with 
BIS's reexport controls guidance brochure and offered to answer any 
export control related questions Hanford might have going forward. 
 
¶11.  CME Enterprises:  According to the Hong Kong Companies 
Registry, CME Enterprises (or China Machinery Electronic Enterprises 
Limited) has been in existence since 1992.  Its share capital is the 
Hong Kong equivalent of USD 125,000.  Its directors are listed as 
Chun, Chun John (HK ID# H359763(8), Chun, Lung Hing (HK ID# 
G128256(4)) and Mao, Oi Tak (HK ID# H359762(A)). Chun, Lung Hing is 
also a director in the following additional Hong Kong companies: 
CTC Computer Technology Limited (dissolved), Farwest Maritime 
International Limited, Taitian Science and Technology (Hong Kong) 
Limited and Xingrong Real Estate Company Limited.  Mao, Oi Tak is 
also a director in Farwest Maritime International Limited. 
According to the CME website (www.hkcme.com), the company was formed 
in 1982 by the Ministry of Aerospace Industry (the predecessor to 
the China National Space Administration and the China Aerospace 
Corporation).  The web site further states that CME's products come 
from a range of partners including specim (www.specim.fi) 
(commercial, research and military sensing tools), Souirau 
(www.souriau.com) (connectors for severe environments in space, 
defense and industrial applications), March Microwave B.V. and 
others.  To date, ECO has been unable to schedule a visit at CME. 
Should ECO succeed in scheduling a meeting at CME, he will inform 
OEA of the results. 
 
¶12.  ECO believes Y&W, Hanford, New White and CME Enterprises to be 
unsuitable recipients of U.S. origin controlled technology.  ECO 
recommends a close review of all shipments to these companies (and 
other affiliated companies noted herein) as well as their 
addresses.