Question: Hello, We have a customer that wants to incorporate our EAR99 item into a product that will be used by a foreign military, but they will not complete an End-User Statement. However, they want to provide only a blanket “negative statement” stating they and their customer will not use the product or act contrary […]
Question: Hello, We’re working through the process of better streamlining our current End-User/End-Use Statement requirements and overall screening process. We’d like to understand how/when others in the membership have determined to require statements detailing full End-User and End-Use details from customers. Also how are you handling the PRC semiconductor and supercomputer requirements? More detailed questionnaires, […]
Question: 10 CFR 110.8 speaks to items that are US export controlled by the NRC. My question is NRC jurisdiction based. Specifically, if an item is on the NRC list as controlled for export, but it is not exported from the US, but is produced outside of the US and shipped direct to a non-US […]
Question: I work for a small corporation. We handle a variety of non-licensed goods. So, a recent situation appeared: export operations handling orders. – is this a conflict of interest? Where export department is handling foreign orders, taking on a sales role, and ensure export compliance. I see it as an issue since it just […]
Question: Have any of you see where you have a routed transactions and either the forwarder nor the forwarder’s chosen trucking company provide a completed truck bill of lading. In some cases, my company will create a truck BOL for the trucker but I don’t think that is a good idea and I feel we […]
Question: Under our parent company, a subsidiary (Company A) is the manufacturer and USPPI exporting products a couple times a month. I work for another subsidiary (Company B) which owns our Logistics division (Company C). Can an employee of Company C, file an EEI on shipments for Company A? If so, is a POA or […]
Question: A regular buyer in Saint Maarten places an order with the manufacturer in the USA. The buyer wants the manufacturer to ship the order to their freight forwarder in Miami, FL, who will then ship the order to a warehouse in Curacao. The buyer owns the business in Curacao and has permission from the […]
Question: I have products coming from the USMCA facility in Mexico my customer in Egypt is issuing a letter of credit requesting a certificate of origin countersigned by the local chamber of commerce and legalized by the local embassy My question here is do I issue a new COO stamped by the local Chamber of […]
Question: Dear members, I have been asked to by my company recently to write an export control process as part our compliance procedures, can any members help if there any written process to follow or slide appreciate your assistance. Asked by: Abdallah Elhaj – abdallah.elhaj@cerespower.com Answer 1: This is a big job. It is not […]
Question: So, we have a gyroscope that’s controlled by BIS for US export. Our question is this: what about the data generated by this gyroscope? The spreadsheets, the graphs…are THEY also controlled? Answer 1: Look at the “E” clauses within the ECCN category that would cover that gyroscope. Determine if the technical data is controlled […]
Question: My company recently acquired a manufacturer in the EU – Spain. Until this acquisition, we had a presence in the US only. My understanding is that the manufacturer in Spain is a wholly owned subsidiary, and will be managed by the US corporate office, so am I correct that the EU entity is subject […]
Question: Question: My client wants to issue a power of attorney (POA) authorizing us to prepare and sign a Shipper’s Letter of Instruction (SLI) on their behalf. Does anyone see regulatory or compliance issues with this? Background: I work for an international distribution company based in the US that ships to our US client’s international […]
