QUESTION: According to 15 CFR 772 and the SNAP-R User Manual, “The end user is not a forwarding agent.” I inherited oversight of a BIS technology export license to a foreign manufacturing site where a freight forwarder is listed as an end user. Upon questioning this, I’ve learned that the freight forwarder is providing onsite, […]
QUESTION: We are a US non-profit organization that provide mainly EAR99 over-the-counter and prescription medicines and various medical supplies throughout the world. We have a 3PL in the NL that receive and warehouse a lot of our donated non-US medicines and medical supplies that we receive from our donors within Europe. The 3PL also provides […]
QUESTION: What is the process for replacing defective merchandise that requires an export license (BIS and DDTC) when you have shipped the full quantity or value allowed by the export license ? Is there a way to report the return and/or the destruction of defective goods and ship the replacement on the original license or […]
QUESTION: I have a question pertaining to these two headings in the CCL. Both indicate “RS applies to the entire entry” and “A license is required for items controlled by this entry for export or reexport to Iraq or transfer within Iraq for regional stability reasons. The Commerce Country Chart is not designed to determine […]
QUESTION: Is it a common practice to share the actual copy of an export license with a consignee listed on the license? What reason could be used not to share the license and use a company letter stating the conditions and requesting an acknowledgement? ****************** Answers: Normally YES. If there are specific provisos that pertain […]
Question:  Could the membership please comment on what value they assign for Technical Data on a DSP-5? We have a disagreement in our office over how to determine the value for technical data and whether a Tech Data license needs to be decremented when data is provided to a foreign party. It would be helpful […]
Question: Say I export my product (EAR99) to Germany. At this point I file AES with NLR. A couple of months go by and learn that that product is going to a sanctioned country where an export license is required. If I knew that the product was going to be on-forwarded to a sanction country […]
Question: We (US Company) recently acquired a Swiss company who has active export licenses under their name, we want to dissolve that legal entity name but want to see if those licenses can be assigned to the new parent (US) company name. Does anyone know where to find information about it? ************** ANSWERS: I assume […]
Question: I’m new to the Export license issue as I have been primarily involved with Imports in the past. I’m being advised that if a Department of State export license was granted for one of our business units, it is acceptable for another business unit to export the good, file the export declaration via AES […]
Question: For the 117 or so companies who BIS says are making use of License Exception STA: how long do you keep or plan to keep your consignee statements signed by the end user before requesting new ones? I didn’t see anything in 740.20 about how long they are valid.
Question: We sold a product (an electronic measurement instrument) to a customer in France a few years ago. It was, and still is, classified under an ECCN that is controlled under NS2 and CB2, therefore we exported without a license. We don’t have ownership or control of the product. Our original export contained the […]
Question: We obtained a license from OFAC to affect a payment to an Iranian. The license application listed the banks that potentially would be involved, including the recipient’s bank in the United Arab Emirates. The license took a year to get approved; […]
