Question: Personal or political opinions aside, what are the compliance risks associated with having a non-US based employee handle export compliance? Additionally, while it may not be a recommended practice, is there any rule/law prohibiting it? Thank you! Answer 1: The only regulatory thing to factor in is that AES filing cannot be done by […]
Question: I am having a conversation with a representative of our related entity in Czech Rep about who is the exporter of record in a multi-tiered sales transaction. Our related CZ entity sells the product to our US entity under FCA-CZ airport INCOTERMS. Then our US entity ships the product to an unrelated Indian company […]
Question: Hello: I have a question related to EEI/AES filing for shipments that are consolidated and shipped to one country and are cleared there for distribution to several customers throughout the EU. Would the consolidation be filed as 1 shipment or does each separate package within the consolidation require filing as needed? Thank you in […]
Question: Can anyone share your experience on how you identify whether the item is subject to EU dual-use item list (EC 428/2009)? From US export control perspective, we know EAR 734.3 specifically describe the scope and criteria for item subject to EAR, including all item in the US, all U.S. origin item wherever located, Foreign-made […]
Question: We’re listed as the “SHIP FROM/PICKUP LOCATION” on the commercial invoice for some goods that we know will be exported out of the U.S. by our domestic customer. Our customer acts as the Exporter of Record out of the U.S. Since we know the goods are leaving the U.S. what obligation do we have? […]
Question: Does the Department of Commerce make unannounced visits and if so what type of identification would they provide? A badge? What is the protocol for when they visit? Answer 1: Yes, they may make unannounced visits, and such a visit could be under a subpoena or search warrant. They will present formal ID (including […]
Question: As a company, we are 99% import and 1% export, of which 99% of the time is EAR99. But there is that one export that may require a license review, or, NLR reviews due to license exceptions, etc… Because of this rarity, I simply do not have a sufficient number of export events that […]
Question: My company “A” is trying to establish a direct shipment to our subsidiary company in Mexico “B” and their customers. It has been proposed that we use EXW but I am not entirely versed in which INCO terms are better than others. I have heard that it is IMPOSSIBLE to use EXW and that […]
Question: We are a US retail company with an export compliance process in which we perform denied party screening, classification, and other export compliance functions once a customer declares their intent to export the product after purchase in case we are viewed as the USPPI. We also waive the sales tax as part of this […]
Question: Drop Shipment question under the following scenario: Incoterm: EXW Factory A) US exporter of record / Seller B) Sold to party in Amsterdam C) Importer of record in Italy (customer of B) B has sold to C at a higher price than A sold to B. I understand that A is the US exporter […]
Question: I am working with a company that is interested in exporting its export-controlled design and production technology (entire manufacturing program) for ECCN 6A003 cameras to Japan. The ECCN 6E001 and 6E002 technical date/technology for the design and production of the 6A003 camera does not require a license for export to Japan, however for many […]
Question: So wondering how Members handle Compliance Risk and communicating the importance. I just recently (about a year) started a new company lower level position (not Management). Very heavy into Exports and a pretty good amount of Imports. I have many years of experience on the import/export side (20years) Import Heavy, some on the export […]
