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 […]
Question: Does anyone in the membership have an ECCN classification checklist they would be willing to share? Answer 1: https://www.bis.doc.gov/index.php/export-control-classification-interactive-tool
Question: I’m planning to do some Export 101 level training for my company. For dual use, I want to give examples of commonly used items that are considered dual use that an average person might not think of having a dual use. For example, cell phones, steel pipes, PS3 consoles, cameras, etc. Please give some […]
Question: Scenario: A foreign-made machine was imported into the United States, used here for a few years, and then reexported to another country with a BIS license as dual-use product based on destination. Machine contains no US software, no US controlled parts, was not built from US technology. End user/end use are not red flags. […]
Question: We have a routed export customer. We do not allow EXW, so the terms are FCA warehouse. The customer is coming into our warehouse, we will load the LCL goods on the container. The customer will take ownership once they leave and they will unload that container and consolidate with other goods before they […]
Question: Do you report export shipments to subsidiaries of your company and do you only report shipments exported from the US? Answer 1: The License Exception ENC semiannual reporting requirement can apply to both exports from the US and to reexports from Canada. See 740.17(e)(1). Shipments to subsidiaries of US companies authorized under 740.17(a)(2) are […]
Question: I am new in an Export Compliance role. Is there a checklist and audit plan I can leverage? Answer 1: How are you going to audit if you are new to export? Your focus should be on getting some core basic education at a BIS/SIA seminar. Nonetheless, to get started, reference the BIS site […]
Question: Hello community, Need some input regarding export authorization. We had rented an equipment from a supplier in Kazakhstan for use locally in the country. Unfortunately, the equipment got damaged during the job and per contract we are responsible for repairing the unit before it is returned back to the owner. Repair can only be […]
Question: Does your company issue a Travel Certificate to employees traveling internationally with technical data on their laptop? If so, how much detail is included on the form. Would you mind sharing your templates? Answer 1: When controlled technical data/technology is being transported on a laptop or other company electronics to another country, we include […]
Question: An unrelated company shipped a Huawei product to us for R&D purposes. The 5A992.c item was not sold to us and now needs to return to Japan from the US. Understanding the Huawei sanctions, is it Ok to ship a product made by Huawei in a non-sale scenario? Answer 1: The designation by BIS […]
Question: We have a long standing distributor in Russia who uses their own agent to make all transportation arrangements from the U.S.A. to Russia. The product is EAR99, not included on the Luxury Goods list, and does not require a license based on §746. They have expressed their difficulty, to be expected, in finding transportation […]
