Miscellaneous

MISCELLANEOUS

  • COMPLIANCE SUBCONTRACTING

    QUESTION: I currently work in the automotive industry. I am the only person responsible for all international trade and compliance for our plant in Ohio. Recently we were obtained and I have been thinking about going out on my own. I already have a Bachelor’s in Business and am a Certified Classification Specialist. Besides getting […]

  • SANCTION VS EMBARGO COUNTRIES

    QUESTION: 1) What is the difference between sanction and embargo countries? 2) What is the difference on sanction/embargo countries on the BIS and OFAC list? **************** Answers: Trade sanctions target specific types of transactions, as in a prohibition to sell arms to a specific business, country, government or regime. An embargo represents a complete prohibition […]

  • Goods Sold In Transit Requirements

    QUESTION: We are looking for input regarding a Goods Sold in Transit scenario. We are a US based company and purchase or transfer not controlled items from suppliers and subsidiaries within the EU to other subsidiaries outside the EU. As well as shipments between different countries or customs regions outside of the EU. The transfer […]

  • Rosneft in Vietnam

    QUESTION: Provided it complies with the Directives (no Arctic, shale, etc), can a US company do business with Rosneft Vietnam? Could a UK company? I think the answer is yes, so long as we’re careful about end use and location. *************** Answers: Rosneft is listed under three major restrictions: 1. BIS Entity List 2. OFAC […]

  • Vetting Form or Template for Foreign Supplier

    QUESTION: We are importing goods and would like to know if there is a specific vetting form or template when selecting foreign suppliers? If not, does anyone have one they don’t mind sharing? *************** Answers: This is more of a sourcing or procurement role and QA supplier qualification role. Trade Compliance does have a “part […]

  • STARTING A FORWARDING COMPANY

    QUESTION: So we are a manufacturing company that imports into the US and as such we use NVOCC’s, freight brokers, etc.. We would like to branch out and start our own freight brokerage company but are confused about this law I see on most literature….”As a broker by law you may not charge or receive […]

  • Technology transfer to Singapore

    QUESTION: We, a US company, purchased a German-owned company and all of their intellectual property including technical data that is controlled under the EAR. Currently manufacturing is only done in the US. We want to sell all IP and controlled technology to our Singapore branch, and begin manufacturing in India. Since currently owned by a […]

  • 9802/FTZ AND NAFTA

    QUESTION: Scenario: We are importing product made from in Mexico. The part we are importing has both 9802, NAFTA, and non-NAFTA components. Question: On our Entry are we able to break out all 3 components so that we can take advantage of both the 9802 and NAFTA duty free status for those components? ========== Answers: […]

  • LICENSED BROKER SUPERVISION REQUIREMENT

    QUESTION: An importer learns that their Freight Forwarder / Customs Broker no longer has a Licensed broker on staff in the local office. Can that local office still file Customs entries on the importers behalf, using the corporate office’s National Permit? ========== Answers: 5. Waiver Request for Qualifying Licensed Individual A waiver is a broker’s […]

  • HTS UNIT OF MEASURE ISSUE

    QUESTION: We have items that we have shipped for many years using schedule B: 6909.11.0000. This item is a very small ceramic ball that we sell by the lb. or Kg. Therefore, counting them as units is not an option. Until recently, we used X (No quantity required). Unfortunately, now that CBP has eliminated that […]

  • LICENSE FOR IRANIAN EMPLOYEE

    QUESTION: I have an non-US citizen/non green card Iranian citizen working at my USA company in the USA. He will now need access to AT controlled data. I have no BIS/OFAC authorization for him because it was not needed (EAR99 only up until now). Is it solely BIS that I have to obtain a license […]

  • Brokerage permit requirements

    QUESTION: I do business with a Customs broker in our local city. The broker is headquartered in another city within the state and has a national permit. I just found out this week that the only Licensed Customs Broker in the local city office resigned. Can I still have this office file our Customs entries […]