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 […]
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 […]
