QUESTION: We are a US based manufacture who will begin exporting to our client in Myanmar Our client, the end user, would like us to use a “third party cosmetic company” to act as the importer of record So the end user client does not have a delay in importing, clearing Myanmar Customs Our client, […]
QUESTION: I reviewed the recent penalty announcement from OFAC and realized I don’t know the answers to some basic questions https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20190131_elf.pdf 1. Is there any de minimus amount of North Korean content that can be in your finished good/component import from a 3rd country? a. Clearly we can not import NK origin goods, nor goods […]
QUESTION: My company recently had a broker file 2 entries under our importer number without our Power of Attorney. The only way I found out about it was through an ACE report. We also had this happen a few years ago. Is there a way to prevent brokers from erroneously filing entries with our IOR […]
QUESTION: Is anyone having delays from DBEI in Ireland regarding individual licenses for dual use items to end users (military / state entities) in Saudi and UAE ? If so, has the Irish government provided anything in writing? We have seen articles where other EU members have frozen arms exports to Saudi, but nothing about […]
QUESTION: We have a customer that is having us drop ship items to foreign entities via a small parcel courier. They are insisting that we put a paper copy of the EEI filing in the box when we ship. I have pointed out that this is illegal per the Census Regulations, but they still insist. […]
QUESTION: Has anyone taken the CUSECO or CUSICO. How is the difficulty compared to the Customs broker License Exam. Would you have sample questions to share for CUSECO or CUSICO. If not would you know where I can find these questions. ========== Answers: I took the CUSECO exam and passed on the first try. It […]
QUESTION: Does anyone know, or have insight as to, what will happen to 19 CFR Part 102 “Rules of Origin” (commonly known as the NAFTA Marking Rules) upon implementation of the USMCA ? =================== ANSWERS: Before there can be “implementation” of USMCA, it first needs to pass as a law, hardly a certainty to start […]
QUESTION: We produce, classify and sell a finished part to an International distributor. This distributor in turn resells our part (without any additional processing, changes, alternations, etc), to their customer. When the distributor resells our part, they are changing the classification to significantly lower the duty rate without discussing the change with us. We have […]
QUESTION: We received a Double Red Flag alert from our Restricted Party screening provider for a customer on the World Bank of Ineligible Firms I understand firms and individuals listed are sanctioned under the Bank’s fraud and corruption policy. While the World Bank of Ineligible Firms listing is not part of BIS Listing of Parties […]
QUESTION: I know that form 3347 is only valid if it’s presented within 90 days of the date of entry. If the entry has been more than 90 days, is there a different form or other option to change the declaration of an owner? ========== Answers: Can your customs broker cancel the entry and resubmit […]
QUESTION: I was looking for the government’s Consolidated Screening List, but I’m not finding it where it once was. Was it moved? Is it unavailable during the shutdown? *************** Answers: Is it unavailable during the shutdown George Tuttle III Law Offices of George R. Tuttle, A.P.C. 1100 Larkspur Landing Circle, Suite 385 Larkspur, CA 94939 […]
QUESTION: Wondering who in the industry also uses stock transport orders (STO) and how do you deal with payment? We issue a PO to transport goods from one foreign plant(which we own) to our US plant and there is no record of a financial payment on this movement. How do I conduct a 3 or […]
