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Cablegate: Extrancheck: Post Shipment Verification: Li

VZCZCXYZ0008
RR RUEHWEB

DE RUEHHK #3660/01 2560606
ZNR UUUUU ZZH
R 130606Z SEP 06
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 8578
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 003660

SIPDIS

USDOC FOR 532/OEA/LHINES/DFARROW
USDOC FOR 3132/FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS

SIPDIS

E.O. 12958: N/A
TAGS: BMGT BEXP HK ETTC
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: LI
YIN (HONG KONG) TECHNOLOGY LIMITED

REF: A) USDOC 01597

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 Bureau of
Industry and Security (BIS), Export Control Officer
(ECO) Philip Ankel conducted a post shipment
verification (PSV) at Li Yin (Hong Kong) Technology
Limited (Li Yin Hong Kong) on August 25, 2006. This
PSV concerned gold plated nickel wire exported by
California Fine Wire Company of Grover Beach,
California (California Fine Wire) classified under
ECCN 1C002 and valued at $3,438. ECCN 1C002 is
controlled for national security and anti-terrorism
reasons.

3. Li Yin Hong Kong does not have a separate business
location in Hong Kong. The phone number listed on the
incoming cable (a number in China) was used to obtain
a contact number in Hong Kong. Contact with Li Yin's
Hong Kong number produced a meeting with Vincent Chu,
General Manager of Lucky Door Industries Ltd. (Lucky
Door Hong Kong). Mr. Chu's business card and the
incoming cable list an office on the 12th floor of the
applicable address. The meeting was held on the third
floor in office number nine.

4. Mr. Chu stated that Lucky Door Hong Kong is the
Hong Kong sales and marketing location for a factory
in mainland China that produces various carrying cases
unrelated to the items that are the basis for the
check (www.luckydoor.com.hk). The meeting was held in
the conference room of Lucky Door's Hong Kong
operation, the walls of which were lined with cases
like those referenced in the web site for Lucky Door
listed above.

5. Mr. Chu stated that, in addition to distributing
the production of the China Lucky Door factory, Lucky
Door Hong Kong acts as a freight forwarder and Hong
Kong presence for 20-30 mainland Chinese companies.
In that capacity, Lucky Door Hong Kong receives and
forwards shipments, pays the applicable import/export
taxes and maintains the corporate registration of its
customers. Mr. Chu did not disclose the names of
other companies for which Lucky Door Hong Kong
provides such services. Lucky Door Hong Kong has
acted in this capacity for at least ten years on
behalf of Li Yin Hong Kong. Mr. Chu noted that he
processes 30-40 shipments per month destined for Li
Yin in China and 45-60 shipments out of China through
Hong Kong on Li Yin's behalf. This shipment was the
first received from California Fine Wire. Mr. Chu
demurred when asked about other U.S. suppliers for Li
Yin.

6. Mr. Chu produced the most recent business
registration documents of Li Yin Hong Kong. It is
registered at the address of Lucky Door Hong Kong (the
third floor location) and has been in existence since
1994. According to its web site (www.dgliyin.com),
the mainland Chinese company Li Yin Technology is
located in Dongguan City and has 30,000 square meters
of factory space. It produces a range of products
including HDD coils, DVD coils, DVD rick coils, hard
disk drives, transformers and other products. It
claims several major customers including Sanyo, Sony &
Dell.

7. As to the specific items that were the subject of
the check, Mr. Chu provided documentation indicating
that he had received the applicable shipment from
FedEx and had subsequently sent it along to mainland
China. The ECO requests guidance on whether the
applicable items are included on any of the applicable
export control regime lists so that he may reach out
to Hong Kong authorities regarding Hong Kong licensing
requirements related to this shipment (if applicable).

8. At the time visited, the consignee (Li Yin
Technology (Hong Kong) Limited appeared to be an
unsuitable recipient of the commodities shipped since
it has no Hong Kong production facility and acts
merely as the purchasing agent for a mainland Chinese
company. The items in question were not in Hong Kong


at the time of the check and had already been
transshipped to China. The ECO recommends that this
PSV be classified as Unfavorable.

Cunningham

© Scoop Media

 
 
 
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