VZCZCXYZ0021
RR RUEHWEB

DE RUEHHK #4023/01 2840810
ZNR UUUUU ZZH
R 110810Z OCT 06
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHBJ/AMEMBASSY BEIJING 9528
RUEHC/SECSTATE WASHDC 8976
RHMFIUU/HQ BICE WASHINGTON DC UNCLAS HONG KONG 004023 
 
SIPDIS 
 
USDOC FOR 532/OEA/LHINES/DFARROW 
USDOC FOR 3132/FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT 
 
BEIJING FOR FCS JEANETTE CHU 
 
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS:        
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: NEW 
COSMOS (H.K.) LTD. 
 
REF: A) USDOC 05351 
 
 1. Unauthorized disclosure of the information provided 
below is prohibited by Section 12C of the Export 
Administration Act. 
 
 2. As per reftel A request ad at the direction of the 
Office of Enforcement nalysis (OEA) of the Bureau of 
Industry and Secuity (BIS), Export Control Officer 
(ECO) Philip Akel onducted a post shipment 
verification (PSV) t New Cosmos (H.K.) Ltd. (New 
Cosmos H.K.) on Ocober 10, 2006. This PSV concerned 
parts for massspectrometers exported by Brimrose 
Corporatin of Sparks, Maryland, classified as EAR99 
and valued at $26,399. 
 
 3. An extract from the Hong Kong Companies Registry 
provides that New Cosmos has been registered as a 
company in Hong Kong since March 1999.  The registered 
address matches the address where the check was 
conducted.  New Cosmos H.K.'s corporate registration 
lists three directors by their Chinese passport 
numbers and without Hong Kong identification card 
numbers (PRC nationals Jing Huang, Zhipeng Pei, 
Jinsong Wang).  One director is listed by reference to 
a Hong Kong I.D. card number(Qingpei Zhao). 
 
 4.  On October 10, 2006, the ECO visited New Cosmos at 
Room B, 32/F, United Centre, 95 Queensway, Hong Kong 
and met with Debbie Fok, Assistant General Manager. 
The New Cosmos office is located inside of the offices 
of China Legal Service (H.K.) Ltd. 
(www.chinalegal.com.hk) and there is no reference to 
New Cosmos on the exterior of the office or in the 
building registry.  The meeting occurred in a small 
conference room in the offices of China Legal Service 
(H.K.) Ltd.  Ms. Fok stated that New Cosmos has been 
in existence for about five years and has a 
representative office in Beijing (listed on Ms. Fok's 
business card as being located at Room 2004, Building 
B, Jianwai SOHO, 39 Dongsanhuanzhong Road, Chaoyand 
District, Beijing) (New Cosmos Beijing).  Ms. Fok 
stated that New Cosmos H.K. (and its Beijing 
representative office) acts as a trading company to 
obtain items from the United States and elsewhere on 
behalf of Chinese clients.  She stated that the main 
business area of focus is telecommunications.  She 
further stated that, to the degree a U.S. export 
license is required, this is the responsibility of the 
U.S. exporter. 
 
 5.  Ms. Fok confirmed that New Cosmos (H.K.) had 
received the items that were the subject of the PSV. 
She stated that the items were ordered by and for 
Tsinghua University in Beijing through New Cosmos 
 
SIPDIS 
Beijing.  A separate item that is the subject of a 
separate PSV cable was also destined for Tsinghua 
University.  The items were shipped to Hong Kong and 
not directly to Beijing at the request of Tsinghua 
University.  Once New Cosmos H.K. had received them, 
Ms. Fok called New Cosmos Beijing and a representative 
of Tsinghua University picked them up from New Cosmos 
H.K.'s offices.  Ms. Fok further stated that the 
exporter (Brimrose) was aware of the end-user of the 
items. 
 
 6. Ms. Fok was somewhat reluctant to provide any 
additional information about the transaction in 
question (and a related transaction that is the 
subject of a separate cable).  Fok declined to provide 
additional documentation on the destination of the 
shipment.  At the same time, the items in question 
were classified by the exporter as EAR99 and could 
therefore, absent EPCI concerns or misclassification, 
be exported or reexported to China.  BIS may wish to 
reach out to the exporter to determine why it chose to 
list New Cosmos (H.K.) as the ultimate consignee. 
 
 7. It is apparent to the ECO that New Cosmos H.K. and, 
most likely, New Cosmos, Beijing are trading companies 
that do not engage in production or manufacturing of 
any kind.  While Ms. Fok was reluctant to provide 
additional information about the shipment in question, 
her answers were not evasive or untruthful and were 
consistent with the information in documents provided 
by BIS.  Therefore, in accordance with guidance on 
reporting of PSVs where the items cannot be physically 
inspected, the ECO recommends that this PSV be 
classified as Limited. 
Cunningham