VZCZCXYZ0000
RR RUEHWEB
DE RUEHHK #0227 0350849
ZNR UUUUU ZZH
R 040849Z FEB 08
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 4072
RHMFIUU/HQ BICE WASHINGTON DC
UNCLAS HONG KONG 000227
SIPDIS
USDOC FOR 532/OEA/LHINES/MCANNER
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS
SIPDIS
E.O. 12958: N/A
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: POST-SHIPMENT VERIFICATION: HIKARI
INTERNATIONAL LOGISTICS
REF: A) USDOC 00116
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 at Hikari International Logistics, 3/F,
Block D, 4-6 Tsing Tim St., Tsing Yi, Hong Kong (Hikari). The items
in question are three shipments containing fiber optic receiver
modules, lenses, prisms and mirrors, long wave length single mode
fiber optic transmitter modules and diodes exported to Hikari on or
about October 31, 2007. According to OEA, the items are classified
under Export Control Classification Number (ECCN) 5A991. This ECCN
is controlled for anti-terrorism (AT) reasons meaning that these
items require a license to a handful of terrorist sponsoring
countries and to certain restricted end-users/end-uses. The exporter
was PD-LD Inc. of Pennington, New Jersey.
3. According to the Hong Kong Companies Registry, Hikari has been in
existence since 2001. It has the Hong Kong equivalent of USD 1,200
in share capital. Hong Kong residents Chen, Ching Chi and Fu, Yuk
Kwan as well as Hikari International Logistics Limited are listed as
directors. According to the Hikari web site
(www.Hikari-International.com), Hikari is a US-Japanese-Hong Kong
joint venture. It specializes in third party logistics services.
4. On January 22, 2008, the ECO, accompanied by Commercial
Assistant Carrie Chan, visited Hikari and met with Mr. Kai Yiu Chui,
Project Manager and Ms. Helen Fu, Managing Director. Ms. Fu stated
that Hikari in Hong Kong provides primarily hub services to the
manufacturing facilities in mainland China of U.S., Japanese and
European multinationals. Its main business focus is in the
electronics inputs arena. In a typical scenario, its international
clients will arrange for inputs to be stockpiled at Hikari. Those
inputs are then relayed to the manufacturing site in mainland China
(typically Shenzhen) when they are needed based on a "call order"
from the production facility.
5. With respect to the shipments in question, Mr. Chui provided
documentation confirming delivery of the items to the Hikari
Warehouse on November 3, 2007. He provided further documentation
confirming that the items had been turned over to the end-user,
Solectron (Shenzhen) Technology Co. Mr. Chiu stated that, as is
typically the case, the items were handed over to the Solectron
appointed shipping company for delivery into Shenzhen. All
information provided by Mr. Chiu and Ms. Fu was consistent with
transaction documentation provided by OEA. Mr. Chiu and Ms. Fu were
not familiar with the end-use of the items although they stated that
Solectron (since acquired by Flextronics) produces
telecommunications devices in Shenzhen.
6. Ms. Fu stated that this type of logistics arrangement is quite
common in Hong Kong particularly for electronics manufacturers in
southern China. Note: As in this case, the logistics provider is
not necessarily familiar with the end-use of the applicable items.
Ms. Fu stated that logistics companies often have as clients the
Hong Kong offices of mainland Chinese companies. Mr. Chiu stated
that, from time to time, Solectron (now Flextronics) provides Hikari
export controls training. Also, when the shipping documents
indicate that a U.S. license is required, Hikari obtains the
applicable Hong Kong import/reexport license(s).
Cunningham