Cablegate: Extrncheck: Pre-License Check: C.A.D. (Hk) Limited
DE RUEHHK #3089 3610310
ZNR UUUUU ZZH
R 270310Z DEC 07
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 3738
RHMFIUU/HQ BICE WASHINGTON DC
UNCLAS HONG KONG 003089
USDOC FOR 532/OEA/LHINES/JSONDERMAN
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT
BICE FOR OFFICE OF STATEGIC INVESTIGATIONS
E.O. 12958: N/A
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRNCHECK: PRE-LICENSE CHECK: C.A.D. (HK) LIMITED
RF: A) USDOC 10573 B) D388272
1. Unauthorized dislosure of the information provided below is
prohbited by Section 12C of the Export Administration ct.
2. As per reftel A request and at the direcion of the Office of
Enforcement Analysis (OEA) of the USDOC Bureau of Industry and
Security (BIS), Export Control Officer Philip Ankel (ECO), conducted
a pre-license check at C.A.D. (HK) Limited (C.A.D. HK), Room 2209,
22F, Mega Trade Centre, 1 Mei Wan Street, Tsuen wan, N.T., Hong
Kong. The purpose of the visit was to determine the suitability of
C.A.D. to be a recipient of conductive nickel spheres (CNSs) that
are the subject of export license application D388272. The items
(ECCN 1C240) are valued at USD $34,000 and are controlled for
nuclear nonproliferation reasons (NP). The license applicant is
Novamet Specialty Products of Wyckoff, New Jersey.
3. A Hong Kong Companies Registry check of C.A.D. reveals that
there are two C.A.D. companies registered in Hong Kong. They are
C.A.D. HK and C.A.D. International Company Limited (C.A.D.
International). C.A.D. HK has no paid-up share capital and its sole
director is listed as Trump China Investment Inc., a BVI registered
company. C.A.D. HK was registered in January 2007. C.A.D.
International has the Hong Kong equivalent of USD 1,200 in share
capital and lists Hong Kong residents Chan, Kam Kwan, Wo, Kwing Ho
and Wu, Kwing Yan as directors. Those individuals are not listed as
directors in any other companies in Hong Kong.
4. On December 20, 2007, ECO, accompanied by Commercial Assistant,
Carrie Chan, visited C.A.D. at the address listed above and met with
Mr. Wu, Kwing Yan, Marketing Manager (also a director of C.A.D.
International). The office was clearly quite recently occupied and
there was no signage reflecting C.A.D. at the entrance of the
offices or in the building lobby. According to Mr. Wu, C.A.D. HK is
affiliated with Zhongshan Light Time Company in Zhongshan China. A
certificate on the wall of Mr. Wu's office states that both C.A.D.
HK and Zhongshan Light Time Company have been certified as ISO 9001
and ISO 14,001 qualified.
5. As explained by Mr. Wu, the beneficial owners of both the
factory in China and C.A.D. HK are the same although the companies
are run as separate entities. ECO suspects that such an arrangement
exists for tax optimization purposes. C.A.D. HK's mainland factory
produces heat seal connectors and zebra connectors for use in LCD
monitors and other electronic applications. In this particular
instance, Mr. Wu stated that C.A.D. HK is purchasing these
particular CNSs because they are superior to the larger size CNSs
they presently use (and which they procure in mainland China). Mr.
Wu noted that the company also uses CNSs made from silver but these
are quite a bit more expensive that those made of nickel.
6. When asked about the existence of C.A.D. International, Mr. Wu
replied that this company is no longer in existence and that the new
C.A.D. HK had been created as part of a restructuring of C.A.D.'s
international operations. More specifically, C.A.D. has entered into
a marketing agreement with an agent in Malaysia (Radysis Asia) and
the name C.A.D. HK is meant to avoid confusion about the geographic
focus of the Hong Kong operation. ECO subsequently visited the
office address of C.A.D. International and verified that C.A.D.
International no longer occupies that location.
7. The ECO found Mr. Wu's explanations credible and generally
consistent with information independently obtained by the ECO. ECO
is not in a position to make any conclusions about the mainland