Question: Our foreign subsidiary ,located in the UK, is asking if they can sell medical products that have no U.S. content to US embargoed countries and countries where there are limited restrictions. The parent company does have a controlling interest with the UK subsidiary . Based on my understanding of the EAR, […]
Question: Our foreign subsidiary ,located in the UK, is asking if they can sell medical products that have no U.S. content to US embargoed countries and countries where there are limited restrictions. The parent company does have a controlling interest with the UK subsidiary . Based on my understanding of the EAR, […]
Question: Here is the scenario – A US company builds and ships product to a company dealer in Singapore. It is labeled “ Made in The USA”. We sell thru a Trading Company so the sale is made at a transfer price and is invoiced to the dealer. Our sale is screened for DPL via […]
Question: Can anyone please provide a current list of countries embargoed by the U.S.? Only thing on OFAC’s website is a list of all embargo ever put in place. Just need list that reflect current embargoes.
Question:Does anyone have information of an embargo that was put into place withinthe last week on shipping to the Congo? I have checked several sites buthave not been able to find the information
Question:If a US company’s foreign subsidiaries utilize its US-based client/server running enterprise resource planning software , is this considered “facilitation of trade” if the foreign subsidiary does business with an OFAC cited country? No US product or technology is traded. No US citizen is involved in the sale. But US citizens would be responsible for […]
Question: An embargo was placed on Myanmar during the Clinton Administration; my question is, while I understand that the embargo is still in place, does this also mean that you cannot buy products from there and what about the purchase of agricultural products? I’ve attempted to contact the office of OFAC but to no avail. […]
According to the overview of the sanctions against Iran, ” U.S. persons may not approve, finance, facilitate or guarantee any transaction by a foreign person where that transaction by a foreign person would be prohibited if performed by a U.S. person or from the United States.” It stands to reason that a US person is […]
Can anyone shed light on your corporate policies about doing business with Syria and Iran? (also N Korea, Sudan, Cuba). I know the US laws – but do you allow you European and Asian divisions to deal with Syria and Iran?If so, is there any difference between your Syria dealings and your Irandealings? And do […]
A US company receives an e-mail, requesting information about their products from a company located in Iran through a general e-mail address (sales@xyzcompany.com, for example) located on XYZ Company’s website. This e-mail address is managed in the US, and the company is a U.S. Corporation, with global operations. The e-mail is then forwarded, by the […]
Many large European companies have operations in embargoed countries such as Iran, making these companies a potential risk to ship our product to their facilities there. Does anyone treat sales to these types of companies differently from companies that don’t have operations in embargoed or controlled locations? Does that obligation or practice change if you […]
Question: We are a manufacturing company and we are setting up a rep agency to handle accounts in the Middle East. We have listed the following countries on our contract with the following notation; Middle East: Syria*, Lebanon, Jordan North Africa: Egypt, Tunisia, Morocco Arabian Gulf: Saudi Arabia, UAE, Kuwait, Bahrain, Yemen, Iran*, Qatar & […]
