Question: Our company is a training facility for helicopter pilots. We have full-flight simulators that are used during training and our students come from various countries for training. In an upcoming training session, a prospective student will be bringing his personal night vision goggles (NVG) to use during the training. The goggles are ITAR controlled. […]
Question: Hello, I am trying to export a Dell server with and Nvidia H200 chip. Per the OEM, the server has HTS Code: 8473.30.9100 and ECCN: 4A090.A. I need to export to the following countries: Germany, UK, Canada, and Switzerland. I am trying to determine whether License Exception NAC or ACA would apply or whether […]
Question: My company exports EAR99 items to Serbia. In our screening software, Serbia comes up as “gray embargo”. The receiving party, or intermediaries, do not appear on the consolidated list. In checking the Balkans-related sanctions under the OFAC website, I am not seeing anything that concerns me from an export compliance related perspective. The […]
Question: Here is the situation: Company in country “X” nominates a US forwarder to facilitate export of items from my client’s office. Their appointed drivers pick up the goods and deliver to their US based freight forwarder who arranges logistics/freight for the export. For a long time, the forwarder has filed AES/EEI for this client […]
Question: We sell our medical products to the cruise ship companies who dock at Cuba but our products will NOT go on-shore, always remain on the cruise ship. Being medical products, there are likely to be a license exemption, but do we need to explicitly mention on our Ts&Cs to the cruise ship companies? Answer […]
Question: With the TikTok ban looming, I am looking for some guidance on if it is at all possible to continue to do business with them if the ban goes through. I say no, but management says that it would not affect us. TikTok has locations all over the world, just about every country and […]
Question: Hi everyone! Does anyone have a Trade and Sanctions Compliance Risk Assessment they could share? I’d really appreciate it. (And please, no suggestions to check BIS or Google) Thanks so much. Answer 1: Hi. Attached is a Trade Compliance and Sanctions Risk Assessment I created for a recent project. It might be a good […]
Question: Hello Membership – We are exporting unassembled kits where, if exported assembled, would be EAR99 [per § 770.2(b)(1)], however, some components have an ECCN. I know that per § 770.2(b)(1) if we export a unit of equipment that contains parts with licensable content that we can export under without a license if that unit […]
Question: We are putting together a Technology Control Plan as the items under our services are considered controlled (ECCNs 5Axxx, 9Axxx, 7Axxx for example). Due to the layout of our facilities, our repair operations is an open floorplan and we are working to figure out the best way a foreign national could be identified so […]
Question: Hello all, I have two questions. As we know, only the United States uses the EAR99 classification. Suppose a foreign-made item falls below the de minimis threshold and is thus not subject to U.S. jurisdiction; what classification should be used in a foreign jurisdiction where the concept of “EAR99” does not exist? Should we […]
Question: If my company imports goods into the US and resells to an overseas company who will immediately export the goods from the US as FPPI and my company as USPPI. Does there need to be a markup on the sale from my company to the foreign company to meet the definition of “financial interest […]
Question: Can someone please share an example of a voluntary disclosure template for export purposes? Answer 1: You didn’t say what agencey – BIS, DDTC, OFAC, Census…they each differ, but at the same time clearly provide the “template”. For example see 764.5(c) of the EAR. Answer 2: I used the following template to provide a […]
