DE RUEHHK #1044/01 1640142
ZNR UUUUU ZZH
R 120142Z JUN 08
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 5055
RHMFIUU/HQ BICE WASHINGTON DC
RUEHGP/AMEMBASSY SINGAPORE 3874 UNCLAS HONG KONG 001044
USDOC FOR 532/OEA/MNICKSON-DORSEY /GCARDAK
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS
SINGAPORE FOR FCS
E.O. 12958: N/A
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION:
ACE PRESSUREWELD INTL
REF: A) USDOC 01398 B) USDOC 01399 C) USDOC 01340
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), Regional Export Control Officer Philip Ankel (ECO)
conducted three post shipment-verifications (PSVs) at Ace
Pressureweld Intl., 31 Senoko Loop, Singapore (ACE). The items in
question are as follows: one three inch CP 5000 valve, 50 Leybold
Dip 3000, 30 Diff-Therm Platen Htr., 30 Diff-Therm Platen Htr, 20
studs, 25 shafts, 720 O rings, 20 diodes, 100 latches and 60
modules. The items were sent in three shipments on October 25,
2007, August 15, 2007 and September 6, 2007. The items are most
likely not listed on the Commerce Control List (CCL) and are
therefore likely classified as EAR99 meaning that they may be
exported/reexported to virtually all destinations, end-users/uses
except sanctioned countries and proliferation or prohibited
end-uses/users. The exporters were Dalton Electric Heating of
Ipswich, Massachusetts, World Bridge Corporation of Gardena,
California and Maxon Corporation of Muncie, Indiana.
3. According to the Singapore companies registry, ACE was
registered in 1973 and its registered share capital is the Singapore
dollar equivalent of approximately USD 1.7 million. Its directors
are listed as Singapore citizens, Rocque Kaw Jit Khim (with
Singapore ID S0234983C), Kwan Kai Phang Willy (with Singapore ID
S0428041E) and Ong Moi Moi (with Singapore ID S1553451F). Messirs
Rocque Kaw Jit Khim and Kwan Kai Phang Willy are also the company's
4. A review of the company's promotional materials on EC21 (a
global B2B marketplace web site) reveals that the company markets
itself has a leading engineering company that has diversified to
become a distributor and trading house. It offers EDM wires, metal
plates, flanges, tubes, valves, drilling equipment, among others
(http://aceweld.en.ec21.com). The web information further states
that the company has been supplying customers in Myanmar, Kuwait,
India, Vietnam, Indonesia and Malaysia.
5. On April 22, 2008, the ECO, accompanied by a representative of
Singapore Customs, visited the company and met with Ms. Jane Ang,
Senior Manager, Ms. Nancy Ong, Executive Director and Mr. Willy
Kwan, Chairman. Mr. Kwan provided an overview of the ACE's
activities. He stated that the company was established in 1973 as a
engineering and machine shop for the oil and gas sector. In the
1980s, the company diversified and became a trading/sourcing
company. At the present time, the majority of its business is
related to importing and exporting various spare parts for the oil
and gas sector as well as for locomotive upgrades. Its customers
are in Myanmar, Indonesia, Australia, Europe, India and Vietnam. It
is also active in the pharmaceutical, paper and textiles sectors.
The Singapore office represents primarily the back room operations
of the company while sales are done overseas (ECO Note: the meeting
took place in a warehouse building under renovation in which there
are roughly 20 desks staffed with ACE employees).
6. Mr. Kwan also described the ACE's joint venture with U.K.
Company Romic Group (www.romic.co.uk). The back of Mr. Kwan's
business card lists the joint venture as Romic-Ace International
Pte. Ltd. Romic is involved in the refurbishment of railway
locomotives on behalf of the Iranian national railway company. A
Mr. Hugo from Canada overseas the supervision of the overhaul work
while a Mr. Robert Coleman of Romic signs the applicable agreements
with Iran on behalf of Romic-Ace International Pte. Ltd. In
addition, Romic-Ace also supplies certain oil and gas parts to Iran
although Mr. Kwan stated that the company does not receive many of
these types of requests.
7. ACE representatives provided information concerning the three
shipments that are the subject of the PSVs. As to the first
shipment (exported on or about September 6, 2007), Mr. Kwan stated
that these items (oil and gas equipment) has been shipped to
Polyacryl Iran Corp. in Holland (apparent web site
polyacril/index.htm). ECO reviewed the Purchase Order (JIRAI-20081)
and notes that it was signed by a Mr. Saghafian in Holland. The
items were shipped to Holland on September 27, 2008. Mr. Kwan
stated that an order for the items had been placed with the U.S.
exporter's office in Singapore (Maxon). Maxon is an occasional
supplier and, according to Mr. Kwan, it did not know the final
destination of the items when it supplied them to ACE.
8. As to the second shipment (from U.S. Exporter World Bridge), ACE
representatives stated that these items were railway parts destined
to Iran as part of a Romic-Ace service contract with Iranian
railways. By subsequent e-mail, the company provided a Bill of
Lading indicating shipment to consignee Bank Melli Iran, Hessabhaye
Dowlati Branch, Tehran. The notify address is listed as Iranian
Islamic Republic Raiways, No 436, 4th Floor, Shahid, Kalantary Bldg.
9. As to the third shipment (from U.S. Exporter Dalton Electric
Heating Co., Inc.), ACE representatives stated that the buyer was
Kath Associates (PVT) Ltd., 76-E Hill View Plaza, Blue Area,
Islamabad, Pakistan. ACE was unaware of the end-use of the items
that were shipped on September 14, 2007. ECO notes that the value
of the shipment is listed as FOB Singapore USD 60,000 while the
company apparently paid the supplier USD 11,489 for the items.
10. Mr. Kwan also provided the ECO with a letter from Singapore
Customs dated July 12, 2007. That letter makes reference to a
meeting between ACE and Singapore Customs and proforma invoice
Q7API-10229 dated April 12, 2007). That letter states that the
aluminium rods referenced in the proforma invoice may be controlled
for export from Singapore and that an export license is likely
required to export these rods. Mr. Kwan stated that the company had
cancelled this order. ACE provided ECO with an Irrevocable
Documentary Credit No.0394-40-18796 from the National Bank of
Pakistan in reference of this shipment.
11. ECO talked with ACE representatives at length about U.S. export
and reexport controls. Company representatives affirmed their
commitment to comply with U.S. export/reexport control rules. ECO
provided company representatives with extensive information about
U.S. controls including links to the BIS web site's information on
lists to check, the Commerce Control List, Know Your Customer
Guidance, Export Management Systems as well as information about
OFAC sanctions programs involving Myanmar and Iran.
12. At the time visited, ACE did not appear to be a suitable
recipient of U.S. origin controlled items since it is likely that
such items will be diverted to Iran or other potential buyers of
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