QUESTION: Pending export transaction involving medical equipment to Cuba. Fully understand that an EAR/BIS license is required and that in most cases BIS approves licenses for medical devices/equipment: Question: Is an OFAC license also required? Based on some prior Cuba licensing I did several years ago, I think the answer is NO only an EAR/BIS […]
QUESTION: We are trying to put forth a questionnaire to our internal business unit to determine whether the machine learning software, programs, libraries, and technology we are working on are export controlled. Can the membership share your best practices on what to ask of the internal business unit(s) in regards to machine learning? What questions […]
QUESTION: We are an integrator and IT set-up provider for companies across the globe. In several instances the companies who we do this for have sourced and supplied their own equipment. We have always operated under the understanding they have to be the EOR if it is being exported as we don’t own the goods. […]
QUESTION: Under a routed export scenario foreign buyer instructs U.S. supplier to ship a part to their freight forwarder using Free Carriage (FCA) Incoterm. Supplier/Seller arranges domestic shipment to Miami. Under FCA seller has responsibility for customs clearance and documentation. Does the USPPI (or their authorized agent) have to request written authorization/POA from Foreign Principal […]
QUESTION: My organization is currently screening our export orders / shipments against our Restricted Party Screening application. Many of our foreign customers are actual distributors, so we know they are not the End user. Some of our distributors are a related party and others are not. The concern for the non-related distributors is to release […]
QUESTION: Scenario: Company A in USA handles the sourcing and purchasing of ECCN 1C234 zirconium metals on behalf of Company B in China. Company B is a marketing office based in Hong Kong that is also sole owner of Company C a smelting plant that melts the Zirconium material and produces a commercial product out […]
QUESTION: Our company sells to a company in Puerto Rico. They tell us they handle with their forwarder as a routed transaction but that they are the USPPI. It is a routed transaction. They tell us that they can be listed as the USPPI with a Puerto Rico address and that their freight forwarder can […]
QUESTION: Would be interested in hearing from the group on what their best practices are on obtaining a proof of export on their EXW shipments. We have always asked for proof of export on all of our EXW shipments and have not had much push back. But in the last couple of years, we seem […]
QUESTION: We have some training laptops for our company that we want to send to our office in Canada. They are loaded with our company training programs, ERP system etc. We have a Canada person returning to Canada, who will take these in his car across the border. What does he need in order to […]
QUESTION: Some of our US domestic customers export products to US Military Bases abroad. Does anyone know where to find export and import guidance so we can understand what requirements we need to meet? ========== Answer: If the contract qualifies for the usage of Defense Transportation Regulations, it would be https://www.ustranscom.mil/dtr/. That would be one […]
QUESTION: We ship what we call a “domestic export”. We are a USA company, selling to another USA company, where we know at the time of selling the product it is going to be exported. The company we sell to is always the USPPI. If our product needed a license, the USPPI would be responsible […]
QUESTION: Looking at the Commerce Control List (CCL), many items are controlled solely for “AT”, or Anti-Terrorism reasons. Consulting Supplement Number 1 to Part 738 of the EAR, we find precisely ZERO countries with AT Column 1 or AT Column 2 licensing requirements. What’s the point of this type of control (probably one of the […]
