QUESTION: We are receiving the following message from our screening software provider Malign PRC Companies on Major Indices My understanding of this message is U.S. persons cannot invest in entities under this warning and it is not a prohibition to export products to a party on this listing Is my understanding correct on this message? […]
QUESTION: Does anyone have experience in shipping a small amount (200cc; ~7 ounces) of used engine oil to Japan? I know EPA has regulations pertaining to this but I find it difficult to figure our what exactly I need to do to ship this? I would appreciate any practical experience and the exact regulatory reference […]
QUESTION: I am having a discussion with our Customs Broker as to the regulations for reporting the country of export on the 7501. If a shipment is bound for export and picked up for export from a company in Germany, but ends up sailing out of the Netherlands, due to that is where the forwarders […]
QUESTION: Can anyone tell us if the FEMA restriction on exporting PPE is still in place? ************* Answers: Yes it is; it was extended until June 30, 2021. Please see Federal Register Notice of Dec. 31, 2020 for more details. **************** FEMA restrictions on masks, surgical gowns, and medical gloves are still in place. Syringes […]
QUESTION: I am attempting to make sure we are not missing any of the dual use ECCNs in our ERP, this is painstaking! Has anyone created an Excel spreadsheet of the Wassenaar lists or any of the other three export control regimes that they might be willing to share so I can run an Excel […]
QUESTION: Goods are shipped directly from a maquila in Mexico to end customer’s forwarder in the US. (routed export). Goods are sold inter-company from the Mexican entity to the US entity, and the US entity in turn sells to the end customer. The US entity is clearly the USPPI, but the US entity never takes […]
QUESTION: Can someone share what a global export/sanctions “risk assessment” looks like (for a large US Headquartered Fortune 300 company, locations in 50 countries, exports from many global locations)? I understand that the answers/info filled in are company specific. I am just asking for a sample of what it physically looks like and what the […]
QUESTION: We are an EU based company registered in the US as foreign Importer of Recorder to import pharmaceuticals products. Now we would also like to export pharmaceuticals from the United States to Europe. Can a non-US based company act as an official Exporter of Record in the US? =========== Answers: NO We are your […]
QUESTION: We are a U.S. importer with almost all of our imports coming from related parties. I recently learned that our R&D teams request failed or damaged machinery or just parts of them to be returned to the plants “all the time”. Our quality team in the U.S. will ask the end users to send the equipment back […]
QUESTION: I know that EEI filings for exports to China, Russia or Venezuela of items controlled by ECCNs not listed in Supplement No. 2 to Part 744 will not be required until September 27, 2020. My question is: will items that are EAR99/NLR be subject to any EEI requirements to these three countries if their […]
QUESTION: What is considered a best practice in screening methodology? We are looking at an option that includes two concurrent screenings, the first is a batch screening on a nightly basis of all entities and the second is real-time screening per transaction at time of export I know this will be primarily be a business […]
QUESTION: My foreign military customer has nominated a freight forwarder to collect an item that requires a commerce license. The goods will be consolidated and sent under the name of the foreign military customer c/o the freight forwarder using strategic trade authorization – STA My company name will not appear on any of the shipment […]
