QUESTION: What is the best way to see which US companies are requesting anti-dumping or countervailing duties on international manufacturer’s or countries? I cannot see the information in ACE. ************* Answers: The Federal Register lists the AC/CVD petitions filed. https://www.federalregister.gov/documents/search?conditions%5Bterm%5D=AD%2FCVD+PETITIONS I find the best information can be found on the ITA site. There is a […]
QUESTION: A rather large holding company (not a public traded company) based in Japan owns a group of other companies. A group company based in Switzerland (medical devices) recently contacted me (USA company) to perform a manual screening of a bank in France. The name and the address of the French bank did not show […]
QUESTION: A US registered company with manufacturing facilities overseas wishes to ship medical devices from the foreign manufacturing facility to Iran – The devices are not on the “List of Medical Devices Requiring Specific Authorization” – Devices are not US originating, but they may contain some US parts – Corporate HQ is in the US, […]
QUESTION: If we have a US owned business in China that sells to a China company who then sells to Iran, now that General License H is in the wind down period, soon to be gone, can the US company be held liable for this secondary transaction between a China company and Iran? ========== Answers: […]
QUESTION: Looking for recommendations and suggestions on how to respond to this hypothetical scenario: 1) We are a US company that manufactures US product. 2) We sell to a Turkish Distributor 3) We are advised by an anonymous source that this Turkish distributor is selling goods to a Turkish company that is owned by […]
QUESTION: According to EAR 742.8, it appears EAR99 items are allowed to export to Iran if the end use or end user is not mentioned in the regulation or found as a restricted party. In addition to, if the commodity is not noted in Part 746.7. However, I am not too sure about OFAC 560.201.205? […]
QUESTION: My company is inquiring whether they can ship a U.S. medical device to a medical trade show in Saudi Arabia where it will be picked up by an Iranian customer. The Iranian customer will then take the medical device back to Iran. I am aware that medical devices can be shipped to Iran under […]
QUESTION: Our sales team has asked if we can export a US made product to a non-embargoed country. The issue is the company in in this non-embargoed country is owned by an Iranian company. I’ve plan to make the following request, or ask the following questions of the sale team: 1) Please provide […]
QUESTION: My US company has a 50% ownership of a French company. This French company has a manufacturing plant in the UAE, which exports to Iran. Are there any legal concerns for us for having part ownership in this foreign company? The product is EAR 99 and has no US components. What about if the […]
QUESTION: We have been asked to supply to an entity in Iran products out of one of our Southeast Asia countries. I have reviewed General License H and it appears that the transaction as outlined does not violate OFAC sanctions against Iran. General License H only applies to foreign entities owned or controlled by a […]
QUESTION: I am looking at the regulations for the SEC Reporting requirements related to transactions with Iran’s energy sector. It is my understanding that although General License H allows foreign subsidiaries to do business in Iran (subject to the license requirements), the SEC requirements (Section 13(r) of the Securities Exchange Act) require a disclosure if […]
Question: US Company exporter knows 2 FACTS: 1) The part /component you export from the USA will be incorporated into a foreign origin item NOT subject to the EAR (i.e. beneath de minimus) 2) The foreign end item (that is not subject to the EAR) will be exported to Iran. Is this OK, since the […]
