LIABILITY/ RISK

LIABILITY/ RISK

  • RPS MANAGEMENT OF POSITIVE HITS

    QUESTION: I am curious to hear about the level of due diligence that companies take to resolve potentially “positive” screening results.   For example, how do you verify that the John Doe who just placed an order with your company is not the same John Doe who is on OFAC’s SDN List?   What steps […]

  • CUSTOMS LIABILITY WITH GO (GENERAL ORDER)

    Question:I’m with a CM and we routinely receive drop-shipped defective product from third parties. In these cases, we are normally the USPPI. We received a shipment via “Direct” service(Airline only, no Forwarder) with documents reflecting another country all together. Airline refused to cooperate by obtaining documents in compliance with CBP rules. Our customer was unable […]

  • Broker Errors on MID

    Question:   The Importer has identified a handful of informal entries made during Q1 of 2010 related to food items where the broker inadvertently transmitted the incorrect MIDs (textile manufacturers) to Customs.  From a compliance standpoint, would the members agree the impact is de minimus, let it go and move on?

  • Identifying Risks and Pending Federal and Legislative Bills

    Question:   Good morning, are there members in the group that are responsible for identifying and keeping up with pending federal and legislative bills that can impact both international and domestic shipping such as the upcoming CSA 2010 rule? If so, can you share any insight or suggestions on how you stay on top of […]

  • Consignment Stock and INCO Terms

    Question:   Consignment stock is when you deliver a product to a customers warehouse (example 10,000kgs) and you invoice the customer at intervals (example monthly) based upon their usage report. The benefit is that the customer has the material local ready for use, and the supplier saves money in delivery costs doing it all in […]

  • LIABILITY/ RISK Q&A 1

    Question: We purchase products from US based Food Brokers on a DDP basis. We often visit the foreign vendors facility for quality checks as well as plant inspections. And, we sometimes place PO’s with the foreign factory. My understanding is that though we are not the Importer of Record for these transactions that we could […]

  • LIABILITY/ RISK Q&A 2

    Question: If a port agent sends cargo in bond (7512) to a non-bonded warehouse and the warehouse receives the cargo not knowing it is in bond who is liable? The carrier who signed the 7512? What is the correct procedure to correct this?

  • LIABILITY/ RISK Q&A 3

    Parent Company is US who holds many different companies from a variety of markets. Some of those companies are not US entities. Do the non-US companies have to follow US law relating to denied persons, sanctions and embargoes because their parent is US even if the product is made outside the US? US company held […]

  • LIABILITY/ RISK Q&A 4

    Our US company (which has several foreign locations) was recently merged with a company in France. Last week I met the company Global Logistics Director who is from the French company and resides in France. He believes that everything is a machine spare part. They do not apply tariff numbers under General Rules of Interpretation. […]

  • LIABILITY/ RISK Q&A 5

    Our company manufactures software. If we were to find out that a customer of ours is using our software to write a program to be used in an application in an embargoed country, what is our liability? The software package itself would stay in the permitted country but the software program (executable) would be exported. […]