Our company sells a product where consumers can get free downloads of applications off our internet site. (games, etc) Our IT security is concerned about “selling” to embargoed nations. My position is that internet transfers of FREE applicaitons do not constitute a sale and there is no controled technology involved so we have no issue. […]
A U.S. company is trying to export some used/refurbished machinery from one of their U.S. facilities to their Chinese joint venture in Shanghai. The company has been advised that China currently prohibits the import of used or refurbished equipment. We need to determine whether that information is accurate or not.
Can members comment on how they handle tax and duty payments on software downloads in Brazil from the US. There appears to be conflicting information on websites about whether or not these downloads would be subject to duty and taxes and how these duties would be paid. Also can downloads occur if the downloading entity […]
DATE COMPANY PENALTY ACTION March Randolph Engineering $12,000 unlicenced export to Iran, plus false SED -sunglasses March Serfilco $65,000previous fine of $118,000 violation of denial order against company for previous antiboycott violations * filters and pumps May Omega Engineering $313,000 criminal$50,000 to CFO10-16 months in prison unlicensed export to Pakistan via Germany despite license denial […]
Does anyone obtain an End Use Statement for their EAR99 exports to cover the bases of the General Prohibitions or would notes taken from verbal communications of the information be sufficient for recordkeeping?
Parent company in the U.S. awards the transportation business between Houston and Singapore to XYZ Freight Forwarder and signs a contract for the next two years and provides an export POA to the FF. Company Plant in Singapore (buyer) places one PO on its sister company in Houston, another PO on an unrelated supplier in […]
Can anyone recommend resources for determining if specific fruits and vegetables are allowed entry into the U.K.?
We have been seeing TAAs come from DDTC (State Dept.) that do not allow any subcontractors to have access to technical data or defense services under the TAA. This appears to be a recent change because older TAAs we have seen do not have this restriction. Instead, they permitted subcontractors of signatories to participate if […]
Has anyone heard any updates as to when new export regulations on Libya will finally go into effect?
Question: Does anyone require foreign subsidiaries to place the destination control statement, slightly modified to exclude the reference to being exported from the US, on their commercial invoices?
Question: Here is a hypothetical scenario: A joint venture company with 51% US ownership based in India sells product to a party in another country. The destination customer and country are not on any SDN, DPL, blocked party or embargoed list. The goods are sold on an FOB, Mumbai India basis. However, the goods are […]
We are implementing a new computer system that will allow us to automatically print all export shipping documents. Although we have always used a “Commercial Invoice” as our export invoice, we are being advised now that we should be using a “Proforma Invoice” as our export invoice because the commercial is not the invoice that […]
