QUESTION: Can someone share what a global export/sanctions “risk assessment” looks like (for a large US Headquartered Fortune 300 company, locations in 50 countries, exports from many global locations)? I understand that the answers/info filled in are company specific. I am just asking for a sample of what it physically looks like and what the […]
QUESTION: We are an EU based company registered in the US as foreign Importer of Recorder to import pharmaceuticals products. Now we would also like to export pharmaceuticals from the United States to Europe. Can a non-US based company act as an official Exporter of Record in the US? =========== Answers: NO We are your […]
QUESTION: We are a U.S. importer with almost all of our imports coming from related parties. I recently learned that our R&D teams request failed or damaged machinery or just parts of them to be returned to the plants “all the time”. Our quality team in the U.S. will ask the end users to send the equipment back […]
QUESTION: I know that EEI filings for exports to China, Russia or Venezuela of items controlled by ECCNs not listed in Supplement No. 2 to Part 744 will not be required until September 27, 2020. My question is: will items that are EAR99/NLR be subject to any EEI requirements to these three countries if their […]
QUESTION: What is considered a best practice in screening methodology? We are looking at an option that includes two concurrent screenings, the first is a batch screening on a nightly basis of all entities and the second is real-time screening per transaction at time of export I know this will be primarily be a business […]
QUESTION: My foreign military customer has nominated a freight forwarder to collect an item that requires a commerce license. The goods will be consolidated and sent under the name of the foreign military customer c/o the freight forwarder using strategic trade authorization – STA My company name will not appear on any of the shipment […]
QUESTION: On a routed export to China or Russia, what are the pros and cons for the USPPI filing the EEI vs the freight forwarder? %%%%%%%%%% ANSWERS: When the USPPI files the EEI as a routed export, they are technically doing so, not on their own behalf, but on behalf of the FPPI. Anyone who […]
QUESTION: If a Foreign Customer contracts their freight forwarder in their foreign country and the foreign freight forwarder contracts a U.S. freight forwarder, what is the responsibility of each party involved regarding a POA? How can we release shipment to the U.S. freight forwarder? ========== Answers: You probably need to see the sub-POA from the […]
QUESTION: With the move by the President to Hong Kong Export Restrictions and Sanctions to be deemed as CHINA, how does this effect normal shipments to Hong Kong companies that are not defense/military shipments. Are these now to be considered under the rule that went into effect June 29,2020 that requires all shipments to China […]
QUESTION: We have an item that we assemble in the US out of dozens of foreign parts from 5+ countries. It seems like this is still simple assembly and would not change the origin based on US definition of Substantial Transformation in case rulings. The component that seems to provide the essence is from China. […]
QUESTION: I’m having a hard time figuring out the related parties criteria for an Export transaction. It mentions the 10% ownership, whether direct or indirect. Could a common parent company fit the 10% indirect ownership criteria making Companies A, B, and C considered related parties regardless of whether they are separate legal entities without direct […]
QUESTION: Has anyone heard when the new proposed regulations for routed exports will be released? ************ Answers: I just talked to Keisha at Census – it is with BIS still for review and synchronization. The BIS and Census rules have to come out on the same day. Census’ draft rule has been done for a […]
