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. […]
Question: We have a routed export customer. We do not allow EXW, so the terms are FCA warehouse. The customer is coming into our warehouse, we will load the LCL goods on the container. The customer will take ownership once they leave and they will unload that container and consolidate with other goods before they […]
Question: Do you report export shipments to subsidiaries of your company and do you only report shipments exported from the US? Answer 1: The License Exception ENC semiannual reporting requirement can apply to both exports from the US and to reexports from Canada. See 740.17(e)(1). Shipments to subsidiaries of US companies authorized under 740.17(a)(2) are […]
Question: I am new in an Export Compliance role. Is there a checklist and audit plan I can leverage? Answer 1: How are you going to audit if you are new to export? Your focus should be on getting some core basic education at a BIS/SIA seminar. Nonetheless, to get started, reference the BIS site […]
Question: Hello community, Need some input regarding export authorization. We had rented an equipment from a supplier in Kazakhstan for use locally in the country. Unfortunately, the equipment got damaged during the job and per contract we are responsible for repairing the unit before it is returned back to the owner. Repair can only be […]
Question: Does your company issue a Travel Certificate to employees traveling internationally with technical data on their laptop? If so, how much detail is included on the form. Would you mind sharing your templates? Answer 1: When controlled technical data/technology is being transported on a laptop or other company electronics to another country, we include […]
Question: An unrelated company shipped a Huawei product to us for R&D purposes. The 5A992.c item was not sold to us and now needs to return to Japan from the US. Understanding the Huawei sanctions, is it Ok to ship a product made by Huawei in a non-sale scenario? Answer 1: The designation by BIS […]
Question: We have a long standing distributor in Russia who uses their own agent to make all transportation arrangements from the U.S.A. to Russia. The product is EAR99, not included on the Luxury Goods list, and does not require a license based on §746. They have expressed their difficulty, to be expected, in finding transportation […]
Question: A customer wishes to install software that we wrote/license on ships. The ships are registered in Germany but can travel almost anywhere. Are there special export rules related to exports destined for ships, aircraft or other methods of transport? Some software is EAR99 but some are 5A002 but qualify for license exception ENC. The […]
Question: Hello! – If a US manufacturer (USPPI) sells to a foreign buyer (FPPI) for finished goods which contains consigned materials sent to them earlier from that foreign buyer, is it presumed that the sales price from the US manufacturer to the foreign buyer should be excluding the value of the consigned materials that were […]
Question: Hi, does anyone have an export control audit form you are willing to share? I am going to audit my logistics team and would like to use the forum as a template. Asked by: Alex Greene – agreene@rti.org Answer 1: This is what we use: https://www.icpainc.org/wp-content/uploads/2023/01/Export-Review-Checklist.xlsx
Question: I took over trade compliance for my company in the second quarter of 2022 because of a corrective action in our prior disclosure. Because of the prior disclosure the majority of my focus has been on the import side of trade compliance. As the new year approaches, I am beginning to work on export […]
