Export Compliance

Questions and answers about Export Compliance

  • Sales in export operations/compliance

    Question: I work for a small corporation. We handle a variety of non-licensed goods. So, a recent situation appeared: export operations handling orders. – is this a conflict of interest? Where export department is handling foreign orders, taking on a sales role, and ensure export compliance. I see it as an issue since it just […]

  • Routed Shipments and truck bills of lading

    Question: Have any of you see where you have a routed transactions and either the forwarder nor the forwarder’s chosen trucking company provide a completed truck bill of lading.   In some cases, my company will create a truck BOL for the trucker but I don’t think that is a good idea and I feel we […]

  • US Subsidiary Filing EEI for another US Subsidiary

    Question: Under our parent company, a subsidiary (Company A) is the manufacturer and USPPI exporting products a couple times a month.  I work for another subsidiary (Company B) which owns our Logistics division (Company C). Can an employee of Company C, file an EEI on shipments for Company A? If so, is a POA or […]

  • USCMA COUNTRY OF ORIGIN

    Question: I have products coming from the USMCA facility in Mexico my customer in Egypt is issuing a letter of credit  requesting a certificate of origin countersigned by the local chamber of commerce and legalized by the local embassy My question here is do I issue a new COO stamped by the local Chamber of […]

  • Export Control process

    Question: Dear members, I have been asked to by my company recently to write an export control process as part our compliance procedures, can any members help if there any written process to follow or slide appreciate your assistance.  Asked by: Abdallah Elhaj – abdallah.elhaj@cerespower.com Answer 1: This is a big job.  It is not […]

  • Licensable scanning item – are the results controlled as well?

    Question: So, we have a gyroscope that’s controlled by BIS for US export. Our question is this:  what about the data generated by this gyroscope?  The spreadsheets, the graphs…are THEY also controlled? Answer 1: Look at the “E” clauses within the ECCN category that would cover that gyroscope.   Determine if the technical data is controlled […]

  • EU, Cuba and US

    Question: My company recently acquired a manufacturer in the EU – Spain.  Until this acquisition, we had a presence in the US only.  My understanding is that the manufacturer in Spain is a wholly owned subsidiary, and will be managed by the US corporate office, so am I correct that the EU entity is subject […]

  • Shipper’s Letter of Instruction

    Question: Question: My client wants to issue a power of attorney (POA) authorizing us to prepare and sign a Shipper’s Letter of Instruction (SLI) on their behalf. Does anyone see regulatory or compliance issues with this? Background: I work for an international distribution company based in the US that ships to our US client’s international […]

  • ECCN Classification checklist

    Question: Does anyone in the membership have an ECCN classification checklist they would be willing to share? Answer 1: https://www.bis.doc.gov/index.php/export-control-classification-interactive-tool

  • Dual Use training

    Question: I’m planning to do some Export 101 level training for my company.  For dual use, I want to give examples of commonly used items that are considered dual use that an average person might not think of having a dual use.  For example, cell phones, steel pipes, PS3 consoles, cameras, etc. Please give some […]

  • Reexport license requirements for foreign-made goods

    Question: Scenario: A foreign-made machine was imported into the United States, used here for a few years, and then reexported to another country with a BIS license as dual-use product based on destination. Machine contains no US software, no US controlled parts, was not built from US technology. End user/end use are not red flags. […]