Export Compliance

Questions and answers about Export Compliance

  • OFAC EXCEPTION E CHECKLIST

    QUESTION: We have a US owned China entity that sells to a China customer.  The China customer takes this US uncontrolled article and assembles it into their product and then sells to a US sanctioned, comprehensive embargoed country. No US content is in the item we sell, but we do have an expatriate living in […]

  • CUSTOMER PROVIDED DOCUMENTATION

    QUESTION: We are preparing an export shipment to Saudi Arabia.  Our customer has provided a shipping label and commercial invoice and is asking us to use this paperwork. Upon review of the documentation we noticed some discrepancies and have asked the customer to correct. I am not comfortable using this paperwork and would prefer to […]

  • EXPORT RECORD-KEEPING

    QUESTION: Are the EEI filings in ACE sufficient for export record keeping purposes or is the company required to save them separately with their other export records internally? *************** Answers: Because the EAR allows records to be stored electronically, the answer is YES.  Essentially if you were requested to product the export records for a […]

  • ANSWER TO QUESTION ON END USER STATEMENT LANGUAGE

    Question: We are revising our statement of assurance for export control. Would members be willing to provide language used for their end user statement/statements of assurance that their customers sign? Does the document contain indemnification language? **************** ANSWER: Basic one attached –End use statement I have tweaked versions for China/Russia/Venezuela to accommodate military end use/end […]

  • Answers to QUESTION ON DENIED PARTIES LISTS

    Question: For some reason, I had it in my head that there were somewhere between 9 and 13 different denied parties lists but when I went to the BIS consolidated list, it shows only 6 (from all the depts..) lists.  Am I missing something ?  or are there 9-13 lists internationally?  And if so, is […]

  • DC AS EXPORTER OF RECORD

    Question: Our affiliate in Mexico is planning on making direct purchase of fashion accessories from a U.S. vendor. Terms will be FCA U.S. port and they want the terms to be FCA Miami, FL,  the location of our Distribution Center. The intention is then to consolidate these goods with the goods coming out of the […]

  • EXPORT AUDIT PLANNING

    Question: In the event that the BIS or Dept. of Commerce / Census, OFAC or any of the agencies would want to conduct an export audit on your company, in your experience what do they approach you with for export reference?  Is the ITN reference number from your AES filings the main reference point for […]

  • EXPORT SCREENING FREQUENCY

    Question: Can any of the members advise the frequency of their export screening, how they determined/benchmarked the frequency, and whether they are using automation- no need to name the system/company. =========   Answers: DPL / Export screening at a transactional level on every shipment, whether domestic or export. Screens at time of shipment in our […]

  • EXPORT CHECKLIST

      Question:   I want to create an export checklist that employees will fill out and sign every time they prepare a shipment for export. It would include checking boxes for all of the “Red Flags” we should be aware of as an exporter.   Can anyone in the membership provide a template?   ===========

  • EXPORT DOCUMENTS

      Question:       Hello,       Need the help from the members.       Our company sells to a domestic customer, the domestic customer is asking us       to export the shipment to their related company in Puerto Rico, our company       would pay all freight charges […]

  • EXPORT DOCUMENTATION REQUIREMENTS

      Question:   I am new at this so need some guidance, please.   My company is a contract manufacturer and has received their drawings for items controlled under 9A991 and 9B991 for which they would like us to manufacture.  The sale would be between my company in the U.S. and their company in the […]

  • EXPORT CHECKLIST

    Question: I want to create an export checklist that employees will fill out and sign every time they prepare a shipment for export. It would include checking boxes for all of the “Red Flags” we should be aware of as an exporter. Can anyone in the membership provide a template? ===========