Question: We develop software products (EAR99, 5D992) that can be used to help build pretty much anything. Since there is potential for end-uses under Part 744, we obtain end user statements for int’l orders to help us “know our customer”. We receive 200-400 EUSes each month.I’m trying to find out where companies with similar level […]
I realize the exporter is responsible to ensure they only export to people / companies that are not prohibited. The government does not dictate exactly how you should set up your export screening program; only that you must be compliant. We currently have an export screening program in place to screen new customers at time […]
Question:I’ve seen many pieces of correspondence about routed exports – defining what they are and what the responsibilities of each party will be and I remain confused…and that includes review of 15 CFR 30.4. I would appreciate the membership’s help: Scenario: My company is in the US Our subsidiary office in Chile accepts an order […]
Question: Although a country may be exported to, with EAR99, or even BIS controls,with no license required, do any companies have “restrictions” theyplace on countries not D or E countries? Is there a “corporateresponsibility” that states compliance should always check orders tothese countries?
Question: Although a country may be exported to, with EAR99, or even BIS controls,with no license required, do any companies have “restrictions” theyplace on countries not D or E countries? Is there a “corporateresponsibility” that states compliance should always check orders tothese countries?
Question:When you are the USPPI in a routed export transaction, are you required under 15CFR 772 to obtain and keep a copy of the export bill of lading from the customer’s freight forwarder? If no, where is the exemption stated in the regulations?
Question:The situation is that the Indian subsidiary of my US based company wants to sell products to another Indian company that states they will then forward the products to Libya. Most of the products are EAR99 but there are a few that are classified under other ECCN classifications, which some have sample shipment exemptions. Also, […]
I would like to ask the collective wisdom of the group, how do youhandle requests for original documents? As a shipper, we are often asked by the routing FPPI to send their goods to forwarders in say Miami for shipment … I send original sets of documents to the forwarders via courier to document & […]
In a routed export transaction, if the forwarder obtains a POA and Authorization to file EEI from the FPPI, is that sufficient to make it a “routed” transaction? Is it a requirement for the USPPI to also obtain in writing from the FPPI that they agree to take on theresponsibility of the EEI filing? If […]
Here’s the situation: My hard drive crashed. The data recovery company is in Canada. I have EAR and/or ITAR controlled data on my hard drive, but it is not accessible to anyone because my hard drive cannot be read. I export the hard drive to Canada so the data can be recovered. Am I exporting […]
License exception GOV (15 CFR 740.11), permits exports of certain commodities, software and technology to personnel and agencies of the US Government, agencies of cooperating governments, and diplomatic/consular missions of acooperating government without a license. Use of license exception GOV is subject to special Wassenaar Arrangement reporting requirements in Part 743.1. For exports of items […]
Here’s the situation: A US manufacturer orders a finished good from a foreign supplier. The US manufacturer sells sub-components to the foreign finished goods supplier. The sub-components are shipped from a second foreign supplier, and the sub-components are then used to manufacture the finished good. The finished good is then imported by the US manufacturer. […]
