QUESTION: I’m looking for best practices to perform a deeper drive in sanction party screening. In most cases, the party exercising the task at hand only has limited information (name of entity, address, tax ID) so, learning about company officers or subsidiaries require further research. How do you learn about these when all you have […]
QUESTION: Would the membership kindly share supplier due diligence questionnaires with respect to trade sanctions, FCPA, and forced labor? =========== Answer: Is this for large volume vendors only? If so, what value? You may want to approach this similar to an M&A due diligence perspective and then cut back on the line of questioning. You […]
QUESTION: I am a US company and I have an FTZ subzone. The vendor is in Italy. We want them to send goods to the States on consignment. We don’t want to take ownership of the goods until we need them. That vendor doesn’t have a US entity. What are my options? Can my FTZ […]
QUESTION: We have an inbound vessel containing 3 separate HBL’s with corresponding 3 separate MBL’s, all sent from the same foreign vendor, to the same US port, to the same consignee. We want to know if we are supposed to combine all 3 shipments into 1 entry, or if we are supposed to file 3 […]
QUESTION: I’m creating a 101 level presentation to give to employees about the import/export processes. I would like to give some general wisdoms/observations that I’ve learned over my career but are you are not normally taught in classes/seminars so they know what to do or avoid when dealing with imports/exports. Some of the examples I […]
QUESTION: For those of you in the oil-patch, how do you classify a production wellhead? 8481.80.9050? 8481.40.0000? Or somewhere in 8431? ************** Answers: Thank you for stipulating ‘production’ wellhead. Offshore is interpreted as subsea. A complete wellhead, having valves/fittings/tubes/pipes would have a use of controlling flow of liquids. A subsea wellhead’s valves are typically going […]
QUESTION: The importer received in error an unmanifested package as part of a consolidated entry from its affiliate company in Germany. The package should have been part of a different consolidation headed to Singapore. The goods in the package are worth about $4,000. 1) Can the goods be sent directly on to their final destination […]
QUESTION: Software is being developed by a non-U.S. company outside of the U.S. There are U.S. citizens employees, some in the EU, some in the U.S., working on the software. Does this mean there is some U.S. content in the software? Is the work of a U.S. citizen in the U.S. considered U.S. content? Is […]
QUESTION: Would anyone know the duration for a Fumigation Certificate? Our overseas vendor had the items fumigated in July, but then was unable to ship due to back-log at origin. They are wondering how long the certificate would be valid. Anyone know, or know with whom I should speak? ========== Answers: A fumigation certificate, also […]
QUESTION: Does anyone use Microsoft Forms for vendor solicitation (especially FTA, REACH, RoHS, Prop 65, Conflict Minerals)? What are some positives and negatives to taking this approach? %%%%%%%%%% ANSWERS: The trick is the record keeping and data maintenance by part number. There are reasonable products that can help you for these projects. Try looking at […]
QUESTION: Looking for guidance to provide company leadership on the impact of existing DDTC registration IF ownership were to change and equal greater than 50% by a Foreign entity? %%%%%%%%%% ANSWER There is not enough information here to provide solid guidance, but in general everything depends on what the potential organization will look like (structure, […]
QUESTION: I am wondering if anyone within the industry has any recommendations on how best to mitigate the challenge of not having containers available for pickup appointments. We have tried to call the trucking companies assigned the day prior to a scheduled pickup appointment to verify they are able to adhere to their appointment as […]
