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Cablegate: Extrancheck: Post Shipment Verification:

VZCZCXYZ0009
RR RUEHWEB

DE RUEHHK #0820 1270210
ZNR UUUUU ZZH
R 060210Z MAY 08
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 4798
RHMFIUU/HQ BICE WASHINGTON DC
RUEHGP/AMEMBASSY SINGAPORE 3842

UNCLAS HONG KONG 000820

USDOC FOR 532/OEA/MNICKSON /DMUSLU
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS
SINGAPORE FOR FCS

SIPDIS

E.O. 12958: N/A
TAGS: BMGT BEXP ETRD ETTC HK
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION:
MICRO-COMM ASSOCIATES PTE LTD
REF: A) USDOC 01394

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), Regional Export Control Officer Philip Ankel (ECO)
conducted a post shipment-verification (PSV) at Micro-Comm
Associates Pte. Ltd., No. 10 Ubi Crescent, Singapore (Micro-Comm).
The items in question are 62 ADC-30720 A/D converters exported to
Micro-Comm on or about November 6, 2007 and November 12, 2007. The
items are classified under Export Control Classification Number
(ECCN) 3A001 and are controlled for national security (NS) reasons.
The exporter was Mesa MW Corporation of Gilbert Arizona.

3. According to the Singapore companies registry, Micro-Comm was
registered in 1999 and its registered share capital is the Singapore
dollar equivalent of approximately USD 180,000. Its directors are
Indian Nationals Rajesh Mishra, Satya Prakash Mishra, Singapore
Permanent Resident Shukla Sunita and Singapore citizen Rm Muthaiah.
Rajesh Mishra, Satya Prakash Mishra and Shukla Sunita are also the
shareholders of the company.

4. A review of the company's web site (www.microcommassociates.com)
reveals that the company is primarily a electronics components
reseller.

5. On April 22, 2008, the ECO, accompanied by a representative of
Singapore Customs visited the company and met with Ms. Sunita
Shukla, Director and S.P. Mishra, Director. Mr. Mishra provided a
business card listing him as the Regional Vice President of the
Indo-American Chamber of Commerce and another card listing him as
the Managing Director of Kaytronics Exim Pvt. Ltd. in Bangalore
(Kaytronics). Mr. Mishra was quick to point out to the ECO that he
has attended several BIS events in India where quite senior
representatives of BIS had participated including Under Secretaries
Juster and Mancuso as well as Office Director, Steve Goldman. He
stated that he is well aware of U.S. export controls and was
actively working in India to improve U.S. - India relations. He
also informed the ECO that this was the second PSV that this company
had received from BIS and that he had previously been visited by
Special Agents Holzer and Higgins in 2005.

6. Mr. Mishra also provided the ECO with additional information
about the various companies that are affiliated with Micro-Comm and
Kaytronics. In particular, Kaytronics (www.kayindia.com) is the
parent company of Micro-Comm in Singapore and the exporter, Mesa
Microwave, in Arizona (Mesa). All companies are disclosed at the
Kaytronics web site. Mesa acts as the procurement mechanism for
Kaytronics (it was previously named Kaytronics) and Micro-Comm. Mr.
Mishra was quick to stress that all of his customers know the
destination of the items in question. He has set up this type of
structure to allow him to procure and pay for items in the United
States that he can subsequently ship through Singapore. His niche
is in providing various products to Indian state entities and
obtaining payment for those items (the mechanics of which can be
quite complicated). Total turnover for all of the companies was
approximately USD 5 million in 2006.

7. As to the particular items in question, Mr. Mishra stated that
those items had been procured on behalf of Bharat Electronics for
use in communications equipment for the Indian military (electronic
countermeasures). Mr. Mishra stated that he knows this customer
well and that it is not involved in missile or nuclear related
programs. He further stated that the items in question are quite
old and obsolete. He noted that the Indian military often continues
to use older equipment and therefore requires such older/obsolete
components. Mr. Mishra provided the ECO with tax invoices (with
original stamp of Bharat Electronics) indicating delivery, on
November 14, 2007, of the 62 converters that are the subject of this
PSV. Those converters were delivered to the representative office
of Bharat Electronics in Singapore.

8. Mr. Mishra stated that he occasionally receives orders for
shipment to China. Typically, he stated, when he requests
End-use/user statements from those purported buyers, further
correspondence ceases.

9. At the time visited, Micro-Comm appeared to be a suitable
recipient of the commodities shipped since Micro-Comm cooperated
with the PSV, provided ECO with access to documents showing final
disposition of the items and operates a line of business consistent
with the use of the items. Also, Micro-Comm is quite familiar with
U.S. export controls and expressed its commitment to comply with
them.

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