Question: My company is an IOR into Canada and the US (not NRI’s). We were looking to combine our Import SOP for Canada and the US into one document just to make it easier to maintain. We’d be sure to note processes specific to each country where applicable. For example, our OGA section would be […]
Question: We are a Customs broker. If our client changes their name but maintains the same EIN#, do we need to secure a new POA? Thank you for your reply. Answer 1: You may notice that the POA format prescribed by Customs in 19 CFR 141.32 does not even provide for a EIN, though I […]
Question: Hello compliance community, Do any members have a RACI they’d be willing to share? General to Trade Compliance responsibilities…hoping to leverage one covering import, export and sanctions compliance. And including trade operations, of course. Thank you in advance! Answer 1: A single one? No. I have MANY – the RACI is at the beginning […]
Question: Our US-based company has employees (not U.S. citizens) in different parts of the world in various branch offices. Our Purchasing department in the US would like to outsource document reviews to one of the foreign branch offices. Those employees would be reviewing the commercial invoices that are used for the import of goods into […]
Question: Hi there! Can someone please advise what the difference is between Customs compliance and Trade compliance? Is there a difference? I’m asking because my team is wanting to split up roles as Customs compliance and Trade compliance and in my eyes I looked at it as Trade compliance just including export compliance and customs […]
Question: Looking for insight regarding reporting structure. Our company structure is currently aligned as follows… the Quality Assurance Dept and Social Responsibility Dept that report into Legal; and the International Transportation Dept and the Trade Compliance Dept that report into Supply Chain. All 4 teams interact daily, as well, as work very closely with each […]
Question: The Act applies to “entities”, which are defined to include entities listed on a Canadian stock exchange, have a place of business in Canada, do business in Canada or have assets in Canada. For companies not listed in Canada, they are only deemed to be “entities” if they also meet at least two of […]
Question: Hello everyone! My company deals with South America business and wondering if you can recommend the best resources to learn about South America Compliance program. Thanks in advance for your insights. Answer 1: I would request a Country Commercial Guide published annually by the International Trade Administration. Here is an example for Brazil. It […]
Question: Does anyone have a guide or even template for writing a company policy compliance trade manual? Thank you Answer 1: https://www.bis.doc.gov/index.php/documents/compliance-training/export-management-compliance/1256-emcp-guidelines-november-2013/file Most companies would not share their EMCP outside of their company. BIS offers a decent template that needs to be tailored to your business. Do not just regurgitate these guidelines or the regulations. […]
Question: Has anyone seen a good explanation of Trade Compliance vs Import Operations. I have been discussing these terms with team members in order to clarify roles within the org structure. Many consider shipment resolution (addressing an issue that is causing a delay in customs entry or release). I define Trade and Customs Compliance as […]
QUESTION: I recall reading something somewhere about how centralized corporate trade compliance roles being allowed to provide trade compliance advice and carry out trade compliance functions for different business units that fall under the corporate umbrella but have different EIN/IRS/IOR #s only if that role was/is part of a Cost Sharing Agreement. Is that correct? If […]
*EXTERNAL SENDER* QUESTION: Is it common to incorporate the Ethics & Compliance role into the Trade Compliance role? My company wants to combine this role into mine (TC mgr) and I have no experience in this area. We don’t have a legal dept. nor we have a single attorney working here. If anyone has this […]
