Question: A question for the membership: We supply a part to our affiliate in Europe for their stock. They send that part to their customer who is on the US Entity List, which shows License Requirement – for all items subject to the EAR, and the license is presumption of denial. The part needs to […]
Question: Does our company need to complete the TMP license exception form for each employee that is traveling internationally, taking into account that they are visiting countries that are not restricted, and nothing on their work computers and cell phones will be restricted by the US government? Answer 1: First, there is no “TMP exception […]
Question: After running a Restricted Party Screening on a potential Customer in UAE, the results came back with country notes for risk regarding Financial Action Task Force. Is the associated risk with UAE reason to pause with doing business. Answer 1: The Financial Action Task Force (FATF) is an international policy-making and standard-setting body dedicated […]
Question: I need to provide guidance on the markings and the manufacturing partners claim it should be Made in USA. These items will ultimately be exported to other markets, and we want to only have 1 SKU for the supplier to make. Where are the regulations for minimum Export Marking requirements for the item, and […]
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 […]
