QUESTION: EAR 740.10(c)(2) talks about an annual/semi annual report to BIS for exports of 600 series items exported using RPL. But I find no mention of 600 series items in 743.4, which is where it points to. What gives? Is some sort of report due to BIS for 600 series/RPL usage or not? ========== […]
QUESTION: Would appreciate your guidance on the following: Background: Our client, an American citizen, is an individual who will be sending his wood kit home from Italy to New York. Overview: The individual and his wife purchased a wooden kit house from a company in China in September 2018. They worked with the […]
QUESTION: The Uyghur Forced Labor Prevention Act will become effective June 21,2022. In order to overcome the rebuttable presumption that your imported goods do not benefit from forced labor in the Xinjiang Uyghur Autonomous Region, evidence must be “clear and convincing”, and will likely include traceability across the entire value chain. Since CBP Importer Guidance […]
QUESTION: Can we purchase material from Russia in the USA? Material cleared US Customs before sanctions were imposed and it is with a distributor in the USA. Will this be considered an indirect connection with Russia making this transaction prohibited? %%%%%%%%%% ANSWER: till see russian vodka on store shelves. If the goods entered the commerce […]
QUESTION: Rarely happens but on occasion our 3PL will email to say they received a container with a broken seal. With low supply that takes so long to receive don’t want to turn it away. What are best practices for accepting a shipment with a broken seal? ************* Answers: I’ve been out of ocean freight […]
QUESTION: I work remotely and am the permit (national and local) holder for my company. My husband has a great opportunity in a new state. How will a move affect the permits and what do I need to do to keep everything compliant? Will it matter what port my license was issued through? ========== Answers: Is […]
QUESTION: Compliance Personnel – In the training you’ve attended, where in the Regulations does it correlate with If you have knowledge the product shipped is to an end user on a sanctioned or embargoed parties end item and with that knowledge you have committed a violation? **************** General Prohibition 10 ***************This is all covered in […]
QUESTION: Company A (US), as exporter and manufacturer of the 600 series items, exports to Company B (DE) under a BIS export license. Company B, re-exports to a Company C (NZ) under the authority of a BIA re-export license. Scenario 1: Does Company C (NZ) require a re-export license to return the items to […]
QUESTION: We have been contacted by BIS export enforcement inquiring about our shipments to RU and wanting to make sure we understand the rules currently in place. We have stopped all shipments as of end Jan. The contact and email from BIS seems to be an outreach more than a fishing expedition , but wondering […]
QUESTION: Routed Transactions. It has been our process that for each and every routed transaction that we have, we obtain from the client a statement that states they approve the transaction as “routed” via their freight forwarder. We also obtain a statement from the forwarder that they “accept the transaction as routed in accordance with […]
QUESTION: How are companies dealing with increased demurrage and detention charges from forwarders? We book port to door, and do not believe we should pay these added fees. It is the forwarders’ responsibility to manage the process, correct? Shouldn’t they bear the cost and not pass on to us? %%%%%%%%%% ANSWERS: Not all forwarders are […]
QUESTION: Going through a merger and got pulled in too late to a detention turned exclusion of merchandise for “insufficient proof” no forced labor in supply chain. The broker/import staff who responded to the detention order did not understand the extent of the request (or what a WRO is) and admittedly didn’t do a great […]
