QUESTION: We have a Russian customer that pays in advance for their order placed with our division in the EU (our HQ is in the US). According to Finance, we should be fine because if the bank blocks the payment, we won’t sell and not on the hook since we screen the customer and our […]
QUESTION: Do the Russia sanctions in place by OFAC restrict the future purchase of, or current ownership of stock in Russia sanctioned companies? %%%%%%%%%% Answer: This is a complex question as there are several different layers, or tranches – if you will, of sanctions with each having different impacts on the named sanctioned entities. Some […]
QUESTION: Due to the imposition of sanctions on Russia and Belarus we have a number of containers that are either in process of being shipped to Russia or are in transit that need to be turned around a come back to the US. I know we can return them without making entry because they are […]
QUESTION: We only manufacture EAR99 items. We have more than 15 plants in the US, do we need to screen visitors? We have a visitor check in process with temporary badges but currently not screening them. =========== Answers: Yes, even though you only manufacture EAR99 products some of these products can be considered dual use. […]
QUESTION: Can the membership please weigh in on how the new de minimis rules apply on EAR99 items produced outside of the US in US owned foreign plants, for products destined to Russia, no military end use or military end user? ============ Answer: I do not believe de minimis rules apply since there is no […]
QUESTION: We are receiving request from our customer to register with CargoX as ACI is now a requirement for all import/exports. Can someone confirm? It appears, as the exporter, we would upload the docs into CargoX ? How are other company handling this? ========== Answers: Yes, we’ve been doing this for about 6 months now. […]
QUESTION: I am hoping the team can provide me with advice on how to move forward with remaining in the EO (Empowered Official) role reporting to Sales and Development? This is a major conflict of interest and everything I have shown our leadership has fallen on deaf ears. The training and seminars I have requested […]
QUESTION: My company is a humanitarian group that ships pharmaceuticals and medical supplies throughout the world. A lot of our partners are small clinics who don’t always seem to have the ability to clear their country’s customs in a timely manner. We end up getting delays at customs, fees start adding up, etc. We currently […]
QUESTION: I would like to send a bottle of bourbon to a friend in Brighton England. Of course it’s a gift and I would want to ship it DDP. Please advise, I do not have a clue so tell me everything I need to do. ========== Answers: You answer is also dependent upon where the […]
QUESTION: I am trying to compile a list of questions to provide to senior leadership to (1) address prior to making an offer for an M&A and (2) a list of questions to pose post offer/acceptance to help ensure the company’s trade team is well advised of all potential risks for the M&A and able […]
QUESTION: How are members handling the Uyghur Forced labor research? Are you contacting all of your vendors to get a letter from them that they are not using forced labor from Uyghur? (or any for that matter). Are you sending out a letter to your vendors and storing in a database? Do you have a […]
QUESTION: Are there still sanctions for exporting to Venezuela? Can any company ship to Venezuela or do all items need export licenses? =========== Answers: Ah, yes. You have to make an export license determination for every export to Venezuela or anywhere. Most significantly, the government of Venezuela is blocked. Since many companies in VE […]
