QUESTION: Our company doubled its size for the last 7 years while we did not increase number of Export Compliance personnel (EAR99 worldwide sales). I was wondering if you can share similar trend and if possible, how many people in export compliance you have per overall number of employees in your company. Ours is 1/4500. […]
QUESTION: Can anyone share how they set up their export recordkeeping program? What docs do you save? How do you save the info – electronic or hard copy? How do you set up the recordkeeping folder – by year/month/day? How do you set up the specific export file – ITN/AWB#/Customer/Date/Inv#? %%%%%%%%%% ANSWERS: What docs = […]
QUESTION: Can anyone provide guidance on filing a deemed export violation? %%%%%%%%%% ANSWERS: Suggest making an investigation to start with, and then determining if the violation is ITAR, EAR or other. You will will want to do an initial disclosure to State, Commerce or whoever else governs your items. Then once investigation has been completed, […]
QUESTION: I have nearly completed an Export Compliance Manual for the small manufacturing company that I work for. Our attorney wants $7500 to review the document. I know BIS will review it for free. The attorney says that if you ask them to review it, you are more targeted for audits. Does anyone know if […]
QUESTION: Is it ever relevant for export control purposes whether a person’s US citizenship is based on birth or on naturalization? Answers: No ( in the context of US jurisdiction/regulations) **************** No. Not all U.S. persons are U.S. citizens. A U.S. person is a U.S. person. The definitions of the different types of persons can […]
QUESTION: There are times when we ship full containers that the goods are shipped on a house bill and master bill of lading. When we receive originals, the master bill is not always included. Is it sufficient for record keeping purposes to have only the house bill of lading on file, or do we need […]
QUESTION: I would like to hear comments from the membership about the policies/procedures in their companies with regard to the use of, and access to, CCL-controlled products by employees who are not U.S. persons. Specifically I am referring to an R&D lab that uses many different types of equipment (analytic, measurement, etc.) that may be […]
QUESTION: My organization is preparing to ship, from the current US location : an assembly line with various specially designed machines, and a machining line with several varieties of specially designed CNC controlled spindle lathes, robodrills, broaching and milling machines, to our parent in Japan. This is considered a transfer and I believe we are […]
QUESTION: I’m looking for a more efficient way to go through “D” and “E” product groups in Category 5 on the CCL for classification without going back and forth between groups. Does anyone have a checklist? ************ Answers: We are software company too, but I found myself spending most of the time actually not into […]
QUESTION: One of the companies we are considering to conduct business with had a BIS administrative proceeding opened up against it back in 2007. There was an official investigation and “Charging letter”. Company agreed with findings and paid fines etc. Any issues with working with this company now? That happened in 2007. It’s 2019. Do […]
QUESTION: Part 758 of the EAR states: …”all parties that participate in transactions subject to the EAR must comply with the EAR.” My question is, to what extent does the party that ships the product on behalf of the USPPI have responsibility to comply with the EAR. I do know that at minimum the shipper/forwarder […]
QUESTION: We are a freight forwarding company, and have several small aircraft parts manufacturers as customers. When doing an internal review, I noticed that some of them declare that their goods are EAR99. I even found some correspondence (when our employees questioned classification) where they were adamant that their products are not controlled and are […]
