Export Compliance

Questions and answers about Export Compliance

  • US DOC BIS Requester List

    Question: Is anyone familiar with the new BIS sanction “Requester List”?  A service Provider’s Restricted Party Screening module has flagged multiple partners as 100% match, but there are no notes/explanations as to what the matches are for, there is only a spreadsheet listing company names, country, and date column with “March 2024”.   I checked a […]

  • Routed Export Transactions

    Question: If we are contracted to sell to a customer located overseas (the contract is between our US branch and a non-US Company), can we name the US branch of the foreign customer as the exporter of record to avoid doing a routed export transaction?   Or would the contract have to be between my Company’s […]

  • Syrian National

    Question: I work for a US company that has a branch in Saudi Arabia.  Currently our recruiter in Saudi is looking for some candidates to be hired in Saudi Arabia and one of them has Syrian nationality.  Since Syria is an embargo country we will need to apply for an export license, but what about […]

  • ECCN Load Ports

    Question: Does anyone here happen to know if Load Ports require a License and ECCN number? Answer 1: It will depend on the commodity in question; however, you should treat any delivery or shipment of goods to a port or terminal on behalf of a customer as an export, or a pending export.   Assuming that […]

  • Russia / Iran Sanctions – Common High Priority Items List – HS Codes

    Question: In recognizing increased focus by BIS on HS Codes identified in Common High Priority Items Lists since the Export Five memorandum in September 2023 and now Iran in the BIS Federal Register entry, Vol. 89, No. 78, Monday, April 22, 2024, more and more EAR99 items are eliciting further due diligence., a membership Q & […]

  • Restrictions

    Question: Where would you go to find out information on exporting from the US to Bangladesh? I’m trying to find out if there is any regulation/restrictions to ship leather skins from the US to Bangladesh. Answer 1: My first go-to is to reach out to your customer and ask what is required for importing into […]

  • Export Compliance

    Question: Hello, I have been tasked with writing the best practices for export compliance for my company.   Would any member have such a document they can share as an example? Thank you and best regards, Maeve Shivnan Asked by: Maeve Shivnan – maeve.shivnan@eosits.com Answer 1: You can download export compliance guidelines from BIS here which […]

  • US Entity List

    Question: A question for the membership: We supply a part to our affiliate in Europe for their stock.   They send that part to their customer who is on the US Entity List, which shows License Requirement – for all items subject to the EAR, and the license is presumption of denial.   The part needs to […]

  • License Exception TMP

    Question: Does our company need to complete the TMP license exception form for each employee that is traveling internationally, taking into account that they are visiting countries that are not restricted, and nothing on their work computers and cell phones will be restricted by the US government? Answer 1: First, there is no “TMP exception […]

  • UAE Sanctions

    Question: After running a Restricted Party Screening on a potential Customer in UAE, the results came back with country notes for risk regarding Financial Action Task Force.  Is the associated risk with UAE reason to pause with doing business. Answer 1: The Financial Action Task Force (FATF) is an international policy-making and standard-setting body dedicated […]

  • on-hand documentation for Made in USA Claims

    Question: I need to provide guidance on the markings and the manufacturing partners claim it should be Made in USA. These items will ultimately be exported to other markets, and we want to only have 1 SKU for the supplier to make. Where are the regulations for minimum Export Marking requirements for the item, and […]

  • Export Trade compliance Risks with non-US based workers

    Question: Personal or political opinions aside, what are the compliance risks associated with having a non-US based employee handle export compliance? Additionally, while it may not be a recommended practice, is there any rule/law prohibiting it? Thank you! Answer 1: The only regulatory thing to factor in is that AES filing cannot be done by […]