Export Compliance

Questions and answers about Export Compliance

  • Guidance on Identifying Routed Exports and EEI Filing Requirements

    Question: I’m seeking some clarification on a few aspects of export compliance. I would be interested in knowing how the members identify routed export transactions within your company.  Are these determined by the Incoterm used, or are there other methods to clearly define these transactions?  What type of operational guidance to you give to Logistics […]

  • Export Compliance Questionnaire

    Question: Hi, I’m trying to find a good example of an export compliance screening questionnaire that can be used for companies or for foreign individuals. Can someone please share an example of one or point me in the right direction? I’d really appreciate it! Answer 1: Here is what we use for our audits. hope […]

  • Export Control – Military End Use

    Question: Hello, Members I am trying to understand what steps I need to take when a customer indicates “Military End Use” on the End User Form.  I was given two conflicting pieces of information, and I would like to seek members’ help to sort this out. First thing first.   Our Item is subject to EAR, […]

  • Seeking Examples of ITAR Compliance Risk Matrices

    Question: I am currently working on developing an Export Control Matrix for my company to ensure ITAR compliance across various business segments, including Global Supply and Procurement, Engineering, and Business Development. We aim to align with DDTC guidelines and effectively manage our compliance risks. I have reviewed the DDTC ITAR Compliance Risk Matrix and created […]

  • Export Controls

    Question: Can anyone provide information on where to sign up for updates on Export Control and Regulations?   Looking for ways to stay updated.  Thank you. Asked by: Sylvia Perez – sylvia_perez@comcast.net Answer 1: There are probably dozens of newsletters out there that one can subscribe to.  I like the Bartlett Daily Bugle.  Bartlett Publications – […]

  • Tools of Trade under EAR740.9

    Question: We have Latin America employees based in Mexico that often have to travel to other countries within LATAM to do trainings, customer demos, trade shows etc.  The equipment originally comes from US into our Mexico office local product stock and are all EAR99 items.   My confusion is around the eligible items and what is “reasonable […]

  • US DOC BIS Requester List

    Question: Is anyone familiar with the new BIS sanction “Requester List”?  A service Provider’s Restricted Party Screening module has flagged multiple partners as 100% match, but there are no notes/explanations as to what the matches are for, there is only a spreadsheet listing company names, country, and date column with “March 2024”.   I checked a […]

  • Routed Export Transactions

    Question: If we are contracted to sell to a customer located overseas (the contract is between our US branch and a non-US Company), can we name the US branch of the foreign customer as the exporter of record to avoid doing a routed export transaction?   Or would the contract have to be between my Company’s […]

  • Syrian National

    Question: I work for a US company that has a branch in Saudi Arabia.  Currently our recruiter in Saudi is looking for some candidates to be hired in Saudi Arabia and one of them has Syrian nationality.  Since Syria is an embargo country we will need to apply for an export license, but what about […]

  • ECCN Load Ports

    Question: Does anyone here happen to know if Load Ports require a License and ECCN number? Answer 1: It will depend on the commodity in question; however, you should treat any delivery or shipment of goods to a port or terminal on behalf of a customer as an export, or a pending export.   Assuming that […]

  • Russia / Iran Sanctions – Common High Priority Items List – HS Codes

    Question: In recognizing increased focus by BIS on HS Codes identified in Common High Priority Items Lists since the Export Five memorandum in September 2023 and now Iran in the BIS Federal Register entry, Vol. 89, No. 78, Monday, April 22, 2024, more and more EAR99 items are eliciting further due diligence., a membership Q & […]

  • Restrictions

    Question: Where would you go to find out information on exporting from the US to Bangladesh? I’m trying to find out if there is any regulation/restrictions to ship leather skins from the US to Bangladesh. Answer 1: My first go-to is to reach out to your customer and ask what is required for importing into […]