QUESTION: Part 758 of the EAR states: …”all parties that participate in transactions subject to the EAR must comply with the EAR.” My question is, to what extent does the party that ships the product on behalf of the USPPI have responsibility to comply with the EAR. I do know that at minimum the shipper/forwarder […]
QUESTION: We are a freight forwarding company, and have several small aircraft parts manufacturers as customers. When doing an internal review, I noticed that some of them declare that their goods are EAR99. I even found some correspondence (when our employees questioned classification) where they were adamant that their products are not controlled and are […]
QUESTION: We are in the process of adding Export metrics to our Broker Scorecard and wanted to ask the trade if they are willing to share an example of what they measure. ========== Answer: similar to the import side of the equation: 1) timely EEI filing 2) accurate Sched B, ECCN info filed 3) […]
QUESTION: I am going on an Export Compliance Job Interview. It would take me from a mid-level employee to a more Senior level employee – not a manager. I feel I am prepared with questions to ask that are the regular job interview questions. I am not working on my interview questions for the […]
QUESTION: We have a US owned China entity that sells to a China customer. The China customer takes this US uncontrolled article and assembles it into their product and then sells to a US sanctioned, comprehensive embargoed country. No US content is in the item we sell, but we do have an expatriate living in […]
QUESTION: We are preparing an export shipment to Saudi Arabia. Our customer has provided a shipping label and commercial invoice and is asking us to use this paperwork. Upon review of the documentation we noticed some discrepancies and have asked the customer to correct. I am not comfortable using this paperwork and would prefer to […]
QUESTION: Are the EEI filings in ACE sufficient for export record keeping purposes or is the company required to save them separately with their other export records internally? *************** Answers: Because the EAR allows records to be stored electronically, the answer is YES. Essentially if you were requested to product the export records for a […]
Question: We are revising our statement of assurance for export control. Would members be willing to provide language used for their end user statement/statements of assurance that their customers sign? Does the document contain indemnification language? **************** ANSWER: Basic one attached –End use statement I have tweaked versions for China/Russia/Venezuela to accommodate military end use/end […]
Question: For some reason, I had it in my head that there were somewhere between 9 and 13 different denied parties lists but when I went to the BIS consolidated list, it shows only 6 (from all the depts..) lists. Am I missing something ? or are there 9-13 lists internationally? And if so, is […]
Question: Our affiliate in Mexico is planning on making direct purchase of fashion accessories from a U.S. vendor. Terms will be FCA U.S. port and they want the terms to be FCA Miami, FL, the location of our Distribution Center. The intention is then to consolidate these goods with the goods coming out of the […]
Question: In the event that the BIS or Dept. of Commerce / Census, OFAC or any of the agencies would want to conduct an export audit on your company, in your experience what do they approach you with for export reference? Is the ITN reference number from your AES filings the main reference point for […]
Question: Can any of the members advise the frequency of their export screening, how they determined/benchmarked the frequency, and whether they are using automation- no need to name the system/company. ========= Answers: DPL / Export screening at a transactional level on every shipment, whether domestic or export. Screens at time of shipment in our […]
