Cablegate: Extrancheck: Post Shipment Verification: Wing Lee Trading
DE RUEHHK #0913/01 1410533
ZNR UUUUU ZZH
R 200533Z MAY 08
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 4915
RHMFIUU/HQ BICE WASHINGTON DC
UNCLAS HONG KONG 000913
USDOC FOR 532/OEA/LHINES/ADYSON
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS
E.O. 12958: N/A
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: WING LEE TRADING
REF: A) USDOC 00801
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 Wing Lee (China-Hong Kong)
Trading Co. Ltd., Factory Unit No. 10, 2/Fwang Hoi, Kowloon Bay
Industrial Center No 15, Kowloon, Hong Kong (Hong Kong Wing Lee).
The items in question are semiconductors exported to Hong Kong Wing
Lee on or about October 18, 2007 and collectively valued at
approximately USD 3,572. The items are classified under Export
Control Classification Number (ECCN) 3A001 and are controlled for
national security (NS) reasons. Rochester Electronics of
Newburyport, Massachusetts was the exporter.
3. A review of the Hong Kong Companies Registry reveals that Hong
Kong Wing Lee has been in existence since 2003. It has paid-up
share capital is the Hong Kong equivalent of USD 25,000. Its sole
director and shareholder is Xie, Xiaoping. The Registry lists his
mainland identification card number as 432902670208877. Xie,
Xiaoping is also a director in Jiatai International (Hong Kong)
Industrial Limited. The registered address of Wing Lee is also the
address of China Star Logistics, Ltd. This company (established in
2004) has the Hong Kong equivalent of USD $125,000 in paid-up
capital and its sole director is Hong Kong resident Tsang, Kui Long
(HK ID number H090469(6)).
4. ECO attempted to conduct web based research on Hong Kong Wing
Lee but was unable to locate a web presence. However, Shenzhen Wing
Lee Import Export Trading Company exists in Shenzhen (Shenzhen Wing
Lee). As noted below, this company is related to Hong Kong Wing
5. A further web search of the contact details provided to ECO by
OEA revealed that a number of companies in mainland China and Hong
Kong use Wing Lee's telephone number as their contact telephone
number. These companies are discussed in greater detail below. They
include Shenzhen Newwoo Electronics Co. Ltd., Hong Kong Juno
Limited, Juster Electronic Limited and Shenzhen Meixinsheng Co.
6. FCS Commercial Assistant Carrie Chan attempted, on several
occasions, to schedule the PSV. Often, the phone rang without
answer. In other instances, the person on the line (a Mr. Wong)
stated that there was no purchasing activity in Hong Kong and it
would therefore be pointless to meet to discuss the transaction.
Mr. Wong, at one point, suggested that ECO meet on Saturday or
Sunday so as not to disturb the business of the company. After
close to two months of attempts, Mr. Wong agreed to meet.
7. On April 28, 2008, ECO and Commercial Assistant Carrie Chan
visited the company and met with Mr. Wong. The company is located
in an older industrial/warehouse building. Its offices consisted of
one room filled with various collapsed boxes, two old desks, two
phones and a fax machine. There is no signage on the door
indicating the name of the office tenant. A second staff person was
in the office during the meeting but she was not introduced.
8. Mr. Wong (full name Wong, Tak Hung) did not have a business card
to share with the ECO. He stated that the company accepts delivery
of certain items on behalf of many clients. When those items
arrive, Mr. Wong or his colleague calls the client who then sends
someone to pick up the package. All shipments are destined for
mainland China. Mr. Wong stated that Mr. Xie is the owner of the
company as well as the principal in Shenzhen Wing Lee. Mr. Wong
claimed to be unsure of the names of his customers but did stress
that the Hong Kong operation makes no orders and issues no invoices.
All of the day-to-day operations of the company are conducted from
Shenzhen Wing Lee. Mr. Wong stated that he knows nothing about the
operations of Shenzhen Wing Lee. He also claimed ignorance about the
activities of the various companies listed above that use his office
phone number as their contact details on the web (Shenzhen Newwoo
Electronics Co. Ltd., Hong Kong Juno Limited, Juster Electronic
Limited and Shenzhen Meixinsheng Co. Ltd.). After some prompting,
Mr. Wong stated that he had heard of Junotech and Meixinshen). He
stated that he assumed these companies use his company's phone
number to give the appearance that they have an actual Hong Kong
presence. He further stated that he assumed that these were the
customers of Shenzhen Wing Lee. When asked about the exporter,
Rochester Electronics, Mr. Wong stated that he had heard the name
and had likely received shipments from the company.
9. When asked about the shipment in question, Mr. Wong stated Hong
Kong Wing Lee had not issued the order (notwithstanding that the
header on the Purchase Order lists the Hong Kong Wing Lee address in
Hong Kong). He further stated that Hong Kong Wing Lee had not paid
for the items and that he knew nothing about the particular order.
When asked whether he might have documentation confirming delivery
of the items, he stated that he did not and that these had likely
already been thrown out (the office was in some disarray but ECO did
observe certain binders with documents predating the date of the
shipment in question). ECO did not find Mr. Wong's explanations or
claims of ignorance to be credible.
10. When pressed about how the business works in practice, Mr. Wong
stated that he has the company stamp for 5-6 companies. He uses
these to stamp delivery documents. Mr. Wong disclosed the names on
two company stamps. They are HK Juno Limited and Ronin Investment
Limited (discussed below). When asked whether Hong Kong Wing Lee
had any additional business premises in Hong Kong, Mr. Wong stated
that it did not. A visit to the registered address of Hong Kong
Wing Lee revealed that it has an additional office (collocated with
China Star Logistics Limited).
11. RECOMMENDATIONS: ECO recommends that OEA conduct a thorough
review of all shipments to Hong Kong Wing Lee and Shenzhen Wing Lee
as well as a range of related companies in Hong Kong and mainland
China discussed below. ECO recommends a check of all shipments to
the addresses of those entities as well. ECO further recommends
that BIS conduct a closer review of the transaction documents
provided by Rochester Electronics as these reveal potential
wrongdoing by Rochester employees during the order process.
12. Ronin Investment Limited: This company has been in existence
since 1993. Its directors are mainland Chinese national Cao, Gang
(ID number 510002710403031) and Hong Kong resident Tso, Yung (HK ID
P355129(A)). As noted above, Mr. Wong of Hong Kong Wing Lee accepts
shipments on behalf of this company.
13. Newwoo Electronics (HK) Limited and Shenzhen Newwoo Electronics
Co. Ltd. Shenzhen Newwoo's web site (www.newwoo.com) states that
this company is a high-tech agent specialized in EMC Shielding
Materials (electromagnetic shielding), EMI filter, frequency control
and microwave products. This company's contact number is the same
as Hong Kong Wing Lee's contact phone number. The Hong Kong entity
was registered in 2005 and has the Hong Kong equivalent of USD 1250
in share capital. Its directors are listed as mainland nationals
Sheng, Danhua (passport number G09579352) and Ye, Fang (passport
number G10337884). The Hong Kong address is listed as 7/F, Kin On
Commercial Building, 49-51 Jervois St., Sheung Wan, Hong Kong.
14. Hong Kong Juno Limited and Shenzhen AOLSTER Industry Co, Ltd.
The web site for these related companies (www.jstsemi.com) states
that these companies (part of Junotech) are engaged in the trading
of various power components including high voltage bipolar
transistors. According to the web site, Junotech also has a
temporary agency in the United States. The Hong Kong contact number
is the same as the Hong Kong Wing Lee phone number although its
address is different (Rm., 704B, 7/F, Hing Wah Centre 82084 To Kau
Wan Road, Kowloon, Hong Kong). According to the Hong Kong Companies
Registry, Hong Kong Juno Limited has been in existence since 2004
and has the Hong Kong equivalent of USD 1250 in paid-up share
capital. Its directors are mainland national Chen, Liwei (no
passport number given) and Hong Kong resident Po, Yu (HK
Identification number P555108(4)). Mr. Wong has the company stamp
for this company in order to accept deliveries on its behalf.
15. Shenzhen Meixinsheng Co., Ltd. This company's Hong Kong
contact number is the same as Hong Kong Wing Lee. According to its
web site (www.szmxs.com), the company is a professional components
supplier for mobile phone and digital products. The Hong Kong
Companies Registry has no listing for this company.
16. Juster Electronic Limited is located in Hong Kong and Suzhou,
mainland China. The Hong Kong address of this company is the same
as the address for Shenzhen Meixinsheng (described above).
According to this company's web site, it is an agent for various
electronics components. Juster Electronic Limited in Hong Kong was
registered in 2002 and has the Hong Kong equivalent of USD 1250 in
paid-up share capital. Its sole director is listed as mainland
national Sun, Junhong (passport number G21164299).
17. Rochester Electronics: A close review of the transaction
documentation provided by OEA reveals several points worthy of
further follow-up by the BIS Office of Export Enforcement. The
Rochester Packing Slip for this shipment lists the items in question
as falling under ECCN 3A001.A.2.C. This ECCN may be shipped to Hong
Kong license free but ECO believes it would likely require a license
for shipment to mainland China. ECO notes that Rochester has
authorized distributors in Hong Kong but this particular order
apparently went from Wing Lee Hong Kong to Rochester's offices in
Shanghai. Notwithstanding that Mr. Wong stated that Hong Kong Wing
Lee generates no purchase orders, all Rochester documentation lists
Hong Kong Wing Lee as the purchaser and Consignee. Internal
Rochester correspondence (from Zoe Feng in Shanghai) lists Hong Kong
Wing Lee as the customer. Based on further e-mail correspondence,
Ms. Feng subsequently stated that the ultimate end user is Hong Kong
Ascend Medical Co., Limited located at 7/F Kin On Commercial
Building, 49-51 Jervis Street, Sheung Wan, Hong Kong. ECO notes that
this address is the same address as Newwoo (listed above) and is
located at the offices of a corporate secretarial service. A
separate End Use Statement purportedly provided to Rochester
Electronics by Hong Kong Wing Lee (listing Liu, Ling as the
signatory) lists Hong Kong Wing Lee as the end-user. Mr. Wong
stated that he does not recognize the name Liu, Ling.
18. In light of the facts noted above, ECO recommends that OEA
conduct a thorough review of shipments to a range of companies as
well as shipments to the addresses of those companies. ECO Further
recommends that Hong Kong Wing Lee be added to the Unverified List.
Finally, ECO recommends that BIS OEE consider investigating the
circumstances surrounding the receipt by Rochester Electronics of
this order and the company's subsequent shipment of the items.