Miscellaneous

MISCELLANEOUS

  • REPORTING REJECTED OFAC TRANSACTIONS

    QUESTION: Our foreign subsidiary was contacted by entity in South Korea for software request on behalf of an entity in Iran.  The request was denied and there was no direct involvement with the entity in Iran. Are we required to report this request under OFAC Rejected Transactions § 501.604 even though it was not a direct […]

  • Leaving a Trade Compliance Position

    QUESTION: Hello, how do you recommend handling having your name removed from the ACE portal and/or the C-TPAT portal once you and your employer have parted ways? I do not want to do anything that would either jeopardize my severance agreement nor harm the company, but I want my name off of the Gov’t programs. […]

  • ALKALINE BATTERY IMPORT

    QUESTION: In a package with an LED pen we would like to import to the USA. there will be a tiny Alkaline Manganese Dioxide battery in a blister pack under the platform of the box holding the pen.It is not installed in the pen but completely separate and not touching anything – completely sealed. This […]

  • AP INVOICE CODING

    QUESTION: When a freight forwarder / customs broker sends a freight invoice, who at your company handles the coding before it’s submitted to AP?  We receive invoices for international freight for export and import, but they can’t be sent directly to AP because they need to be coded so AP knows which account it hits. […]

  • NAICS and SIC Codes

    QUESTION: We were asked for an Industry Code as part of some type of registration. We researched our business and found the appropriate NAICS (formerly SIC) Code. However, when we look at it for other countries the same description has a very different SIC. Who in a company normally manages the SIC/NAICS determination? I would […]

  • Part 744.21 Military End User

    QUESTION: We are researching a Russian entity for possible sale to a power company/electric grid- of electronic equipment covered under Supplement 2 of Part 744.21 (3A992) for purely civilian use.  An online article was found where the company President was directly quoted as stating the company was in direct cooperation with the defense industry and […]

  • SCIP Database

    QUESTION: Has anyone heard of the SCIP database?  Is this going to stop all imports to the EU if you are not in it by Jan 1, 2021?  Can anyone provide any more information related to this? %%%%%%%%%% ANSWERS: SCIP is the database for information on Substances of Concern In articles as such or in […]

  • HS classification for UK imports 10-digits

    QUESTION: We were informed by our European broker that UK government published the notice last week that 10-digit HS codes will be required after Brexit for imports versus 8-digits for as informed before. Does anyone have a list of HS codes for the UK in the Excel format? %%%%%%%%%% ANSWERS: Before Brexit EU has always […]

  • Peru Customs Law

    QUESTION: US company temporary exports widgets to customer in Peru. Customer in Peru exports widgets back to US company after temporary use in country. Looking for the Peruvian Customs Law that cites a commercial invoice cannot be used as proof that the widgets left Peru. Other info: Peru temporary imports are electronically recorded on the […]

  • New to OFAC list

    QUESTION: We currently import from a company in China that was just put on the OFAC list for selling information to Venezuela.  Does this mean we can no longer import from this company? We are not allowed to transact business with them?  I can understand we can no longer export without a license but how […]

  • ECCN FOR QUALITY CONTROL AND MACHINE PARTS

    QUESTION: I was wondering if anyone could share a list of commonly overlooked, everyday, items that companies export that require an ECCN with the ICPA community.   I am thinking more along the lines of pharmaceutical and food processing machines and their parts – valves, mixers, motors, hoses, testing machines. like mass spectrometers, turbidimeters, penetrometers, instruments […]

  • ORIGIN VALIDATION FORMS

    QUESTION: Is anyone in the membership willing to share any forms used to solicit COO information from vendors? This would also include vendors validating parts that qualify for USMCA. ***************** Answers: We send the attached two forms to our suppliers when requesting country of origin information. We include instructions to use the USMCA form for parts […]