Question: Through a conversation I had recently with an Export Compliance person from another company, it was mentioned that they perform a bi-annual check of all their US and foreign subsidiary employees against the Restricted Party Listings issued by OFAC and BIS (they stated this requirement is outlined in UN resolution 1390, Part 2A, […]
Question: We are specifically be required to do a routed export transaction since ourcustomer requires that we have their forwarder hand the export out of thecountry.But we require that we file the AES EEI since we know it will be donecorrectly. The forwarder has agreed to this.Does someone have the properly wordsmithed Written Authorization thatpertains […]
Question: Those anyone in the membership have a presentation for export compliance awareness training for IT. I have been asked to provide awareness training to this group and a really have only the very basics. The training will take place on June 8. Any help will be greatly appreciated.
Question: My company sells machines for exports, but due to the size of our machines, they are exported in up to 7-8 shipments (some of the shipments are direct from foreign suppliers to our foreign customer). The issue is, we sell a machine, but ship components of the machine until the whole machine has shipped. […]
Question: Would the members consider access by US person employee to technical data or technology on the US company’s network via VPN from outside the country an export if no non-US persons are given access? (Is the data really leaving the US?)
Question: Can anyone help me find a quick way to get Russian Regulations either in English or Russian?
Question: The question sounds like it involves an FCA (customer’s forwarder) situation. In all cases, seems like the answer is that the customer’s forwarder needs to be filing EEI on the FPPI’s behalf. Perhaps I should pose the question, what about the INCOterm saying shipper is responsible for clearing for export? How does that impact […]
Question: We received product back from a UK customer that they wanted re-tested to a tighter specification. The product itself did not change form, fit, or function – it was simply re-tested (service). We considered this to be a repair, and were sending it back out under 9801.10.0000 with a declared value of the […]
Question: Anyone seeing a phrase like the following that I have showing up in an L/C from an EU subsidiary to a Pakistani customer?: “Transshipment is prohibited through Iran, Cuba, North Korea, Sudan, and Myanmar.” I cannot track down where this phrase is coming from, any thoughts? It appears to be an […]
Question: We currently supply to our Argentina distributors disposable masks with the schedule b of 6307909995. These are manufactured in Tunesia. Our Argentina distributor states we must provide the following for them to be able to import them into Argentina. A certificate of origin, original or copy, from Tunesia to the us here […]
Question: In a Routed Transaction, the USPPI [beneficiary] is obligated to provide certain data elements that will allow the FPPI [foreign buyer] or their designated freight forwarder to correctly file an EEI via AES. In our case, those elements are provided on our invoices and a Routed Transaction Shippers Letter of Instruction. This information is […]
Question: Is there anyone in the trade community that can advise if their export compliance program has went through an internal legal verification. I am in the process of developing an export compliance program for my company. The changes required to fully implement our program will be costly and time consuming. Prior to making […]
