QUESTION: If a company does not have an import-export (trade compliance) manuals what are the consequences with CBP and BIS? Are there penalties? Do I need to emphasize with management the need and/or requirement for these documents? Are corporate manuals and SOPs with brokers and freight forwarders mandatory? ************** Answers:No, they are not “mandatory”, and […]
QUESTION: I was auditing some export shipments to HK and found four shipments destined for the same customer, exported on the same day. The value of each was $500, making the total value $2,000. Less than the EEI filing threshold. In addition to the extra shipping and processing costs I am wondering if the reason […]
QUESTION: We make several hundreds of FCA, customer pick up shipments a month, all items that we sell are EAR99. We have a global ERP system and these orders are placed by the overseas customer service on the US branch plants, they also generate CI and SLI for their customer and coordinate cargo pick up […]
QUESTION: Where can I find the potential fines and penalties for not maintaining export documentation for five years as a USPPI? ========== Answers: There is one from 2009 where the yellow-red express carrier could not produce records that were within the five year statute resulting in a settlement agreement that was almost $10 million. Just […]
QUESTION: Would the membership share your best practices for SPL screening in compliance with U.S. export control? I came to realize that the language translations such as Chinese can be different than OFAC characters translation. For example, when I showed local Chinese some of the SDN list, the entities and or individual are non-existence in […]
QUESTION: One of our locations could not complete the EEI filing because the system went down. The product was shipped anyway with an EEI filing. Value of $3,500.00. How do we fix this? Do we self report? To whom? Will there be fines or penalties? ************** Add’l Answer: Some good answers below, follow their advice. […]
QUESTION: I have friends who have specialized in import trade compliance for 10 years, mostly in apparel/footwear and consumer products. They have dabbled in export TC but its very basic – screenings, record keeping, auditing export filings, all EAR99 product. Taken the online BIS training’s. Any knowledge of difficult export requirements is really theoretical. No […]
QUESTION: Our company doubled its size for the last 7 years while we did not increase number of Export Compliance personnel (EAR99 worldwide sales). I was wondering if you can share similar trend and if possible, how many people in export compliance you have per overall number of employees in your company. Ours is 1/4500. […]
QUESTION: Can anyone share how they set up their export recordkeeping program? What docs do you save? How do you save the info – electronic or hard copy? How do you set up the recordkeeping folder – by year/month/day? How do you set up the specific export file – ITN/AWB#/Customer/Date/Inv#? %%%%%%%%%% ANSWERS: What docs = […]
QUESTION: Can anyone provide guidance on filing a deemed export violation? %%%%%%%%%% ANSWERS: Suggest making an investigation to start with, and then determining if the violation is ITAR, EAR or other. You will will want to do an initial disclosure to State, Commerce or whoever else governs your items. Then once investigation has been completed, […]
QUESTION: I have nearly completed an Export Compliance Manual for the small manufacturing company that I work for. Our attorney wants $7500 to review the document. I know BIS will review it for free. The attorney says that if you ask them to review it, you are more targeted for audits. Does anyone know if […]
QUESTION: Is it ever relevant for export control purposes whether a person’s US citizenship is based on birth or on naturalization? Answers: No ( in the context of US jurisdiction/regulations) **************** No. Not all U.S. persons are U.S. citizens. A U.S. person is a U.S. person. The definitions of the different types of persons can […]
