QUESTION: We sell consumable items in the auto industry. We sell to distributors in the Middle East and Turkey. Our technical sales team received an email from someone in an embargoed country requesting support related to one of our PNs. We do not sell to anyone in this embargoed country, obviously. However, these consumables are […]
QUESTION: We sell consumable items in the auto industry. We sell to distributors in the Middle East and Turkey. Our technical sales team received an email from someone in an embargoed country requesting support related to one of our PNs. We do not sell to anyone in this embargoed country, obviously. However, these consumables are […]
QUESTION: How are companies actually blocking IP addresses for the Crimea Region of Ukraine? Are companies doing this? What are the mechanics? Is it required under the law? If you are tracking, are you able to track internet traffic from particular countries, regions, or locations? ========== Answer: Block from all of Ukraine, then have process […]
QUESTION: Can an Embargo Country national be hired without having a deemed export license in place? My understanding is that if an offer has been made and they started working at the company. We can have them work on non-technology (non-CCL) or non-EAR99 goods until license in place. ==================== ANSWER: Your hobby in your spare […]
Question: Our German subsidiary wants to sell medical products to another German company who could possibly sell the products to their customers in Iran. Would we be required to obtain an OFAC license to cover the potential sale of our products into Iran ? ========== Addl Answers: For an overview of the Iranian sanctions and […]
Question: Where can I find a list of all the countries the USA cannot do business with please? ========== Answers: Go to the US Treasury site at: http://www.treasury.gov/resource-center/sanctions/programs/pages/programs.aspx You will see that there are all kinds of different sanctions. ========= Use the country chart as a general rule. You can find at: https://www.bis.doc.gov/index.php/forms-documents/doc_view/14-commerce-country-chart […]
Question: What do the members recommend to be the best avenue for obtaining guidance from OFAC, related to embargoes/sanctions as they pertain to a potential business deal? Is contacting and obtaining a response from OFAC_Feedback@treasury.gov good enough? Or must we do some form of an official inquiry? ========== Answer: I have called them with questions […]
Question: As an American company with international subsidiaries I would like to know how and if you notify US Customs of trading companies that solicit quotes on a worldwide basis for projects in Iran. I think that part of our due diligence is that we should inform someone who collects this type of information and […]
Question: What are folks doing to vet NEW customers from an export compliance perspective, aside from checking them on the various Restricted Parties Lists? Is that really enough in this day and age? BIS is preaching more and more about “front companies” set up in the USA that aren’t real, legitimate companies. What […]
Question: Our foreign subsidiary ,located in the UK, is asking if they can sell medical products that have no U.S. content to US embargoed countries and countries where there are limited restrictions. The parent company does have a controlling interest with the UK subsidiary . Based on my understanding of the EAR, […]
Question: Our foreign subsidiary ,located in the UK, is asking if they can sell medical products that have no U.S. content to US embargoed countries and countries where there are limited restrictions. The parent company does have a controlling interest with the UK subsidiary . Based on my understanding of the EAR, […]
Question: Here is the scenario – A US company builds and ships product to a company dealer in Singapore. It is labeled “ Made in The USA”. We sell thru a Trading Company so the sale is made at a transfer price and is invoiced to the dealer. Our sale is screened for DPL via […]