Cablegate: Extrancheck: Post Shipment Verification: Maxlink Industries
DE RUEHHK #2329 3570004
ZNR UUUUU ZZH
R 230004Z DEC 09
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 9228
RHMFIUU/HQ BICE WASHINGTON DC
UNCLAS HONG KONG 002329
USDOC FOR 532/OEA/ MCANNER
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR PATRICK SANTILLO
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS
E.O. 12958: N/A
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: MAXLINK INDUSTRIES
REF: A) BIS e-mail request 01210009
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 Maxlink Industries Ltd., Unit
710, Grand City Plaza, 1 Sai Lau Kok Road, Tsuen Wan, Hong Kong
(Maxlink). The items in question for this PSV are two high
performance, low power dual 8-bit, 1.5 GSPS A/D converters exported
to Maxlink on or about February 26, 2009. These items are likely
classified under Export Control Classification Number (ECCN)
3A001a5a1 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 of
3. According to the Hong Kong Companies Registry, Maxlink has been
in existence since 1998. Its paid up share capital is the Hong Kong
equivalent of USD 10. The Hong Kong Companies Registry lists
Canadian national, Long, Yangxin (PP#BA527589) as director. Long,
Yangxin is also a director in a range of other Hong Kong registered
companies including ITSmart Limited, Maxlink Industries Limited,
Maxlink Global Limited, Seatech International Asia Limited, Seatech
International Holdings Limited, UniHz Holdings Limited and UniHz
International Limited. Long, Yangxin is the sole director in each
of these companies except for Seatech International Asia Limited.
In this company, U.S. nationals Blatt, Michael (PP#202083327) and
Schneider, Bruce Howard (PP#017007730) are also directors. Messrs.
Schneider and Blatt are not listed as directors in any other Hong
Kong registered companies.
4. Web research reveals that Maxlink is the Hong Kong logistics
center for Seatech International (www.seatech-international.com).
Seatech has offices in Milpitas, California as well as Shenzhen,
China and Northolt, UK. According to its website, Seatech
International has its headquarters in the United States and is a
leading independent distributor of semiconductors, electronic
components, computer products and networking equipment. UniHz
Technologies Co., Ltd. has its own web site, namely www.unihz.com,
where it states that this company is a leading intelligent
transportation system supplier in China. It is noteworthy that
Maxlink is located in the same building (but different floor) as
several additional companies of diversion concern including Free
Components, ARI International and in the building next door to Huge
Source, a third company of diversion concern.
5. On December 3, 2009, ECO and FCS Commercial Assistant Carrie
Chan visited the company and met with Mr. Pak, salesperson. The
company is located in a warehouse and offices building and has space
for several desks, a reception area and two small offices.
According to Mr. Pak, Maxlink serves as warehouse and well as
trading company for Seatech.
6. Mr. Pak stated that Seatech's China headquarters are located in
Shenzhen and that some of the underlying documentation for this
order (the customer purchase order, for example) is located in
Shenzhen. Seatech/Maxlink customers are located in mainland China,
Thailand, Malaysia, Singapore and Korea. Approximately fifty
percent of the company's business is for local delivery while fifty
percent is for international sale. Mr. Pak stated that shipments to
China are sent to manufacturers but he is not familiar with what is
being made with Maxlink components. When asked, Mr. Pak stated that
Maxlink obtains HKTID import and export licenses for its products.
When pressed, it became apparent that Mr. Pak was referring to
another type of license. Mr. Pak stated that he has only been with
the company for two months.
7. As to the items in question, Mr. Pak provided documentation (an
invoice) confirming that the items had been sold to the Harbin
Institute of Technology (HIT) in mainland China. According to
online research, HIT is a larger university in Harbin that is known
for its space and defense related research.
8. ECO explained the importance of complying with export controls
and, by separate e-mail, provided Mr. Pak with information on BIS
and HKTID controls.
9. ECO does not believe Maxlink is a suitable recipient of
controlled U.S. origin technology. ECO further recommends that BIS
Office of Export Enforcement follow up with Seatech in the United
States as the underlying documentation appears to indicate that it
may be been aware that the items were destined for HIT when the
transaction was completed.