• OFAC Sanctions Compliance Questionnaire

    QUESTION: We are spending a lot of time researching our customers located in sanctioned countries so we would like to prepare a general questionnaire for our customers to answer to help us with the clearing process. I am looking to see if anyone has a questionnaire they could share on this subject or give advice […]

  • OFAC Sanction on my customer

    QUESTION: My U.S. customer has a foreign sister company who violated the Iran Sanctions; neither company has been placed on the Denied Parties Listing. An agreed to penalty was paid. My items were not directly sold into Iran, but my items were assembled onto the item that was sold to Iran. What are my liabilities […]


    QUESTION: Has anyone in the ICPA community explored the use of a 3rd party importer of record (IOR) service provider in countries (outside of the US) where your company does not have a presence and your in-country customer does not want to be – or cannot be – the IOR? This IOR service provider would […]

  • Global Assist Allocation

    QUESTION: Wondering if anyone had a strategy for allocating Customs assist costs to multiple regions which require assist declaration? Let’s assume transaction value and 100% costs are allocable to the assist- Do you consider an assist used in sales to multiple countries is declarable at full value outside the US, or is there an approach […]

  • Foreign based TC staff

    QUESTION: As a follow-up question, what if the foreign-based Trade Compliance staff has dual citizenship? i.e., both a U.S. passport and a passport issued by an EU member country? Original question: Our Trade Compliance group supports DCs in the US, SG, and NL. I am the only staff in the US and was wondering if […]


    QUESTION: I’m going cross eyed reading Executive Orders. Is the current status of the Government of Venezuela that it is only subject to the financing restrictions of EO 13808, but is not BLOCKED entirely? ========== Answer: Read 31 CFR 500 for any Treasury questions https://www.ecfr.gov/cgi-bin/text-idx?SID=4544ae6adea84a6f1cda56716c045a46&mc=true&tpl=/ecfrbrowse/Title31/31cfrv3_02.tpl#0

  • MZ & PK

    QUESTION: Does anyone know if Pakistan or Mozambique has anything that resembles export regulations (meaning like the EAR/regime countries)? I export from there and am wanting to know if they have any true export regs/control lists I should be following (google doesn’t seem to think so, but it’s no match for ICPA expertise). ========== Answer: […]

  • End User Statement language

    QUESTION: I am receiving end user statements from suppliers that prohibit or specify their product will NOT be used in: NUCLEAR END-USES; CERTAIN ROCKET SYSTEMS; CERTAIN CHEMICAL AND BIOLOGICAL WEAPONS; MARITIME NUCLEAR PROPULSION; etc, from section 744. It seems if you have the license or authorization from BIS then you are ok. The end user […]


    QUESTION: An offshore software development company needs remote access to hardware in the USA to test software. Encryption is not used on any of the hardware they will be using to test. Are there any export restrictions? Would you please provide guidance? ========== Answers: It sounds like you’re offering a Cloud service? If so check […]

  • Consolidated Shipments

    QUESTION: Recently, we had a standard export transaction where the foreign customer purchase some items and had us send the cargo to their US Agent/consolidator. We instructed the consolidator that we would file the EEI (as the USPPI) and asked them to contact us with shipping details when they were ready to export. This all […]

  • Wine Gift to Europe

    QUESTION: One of our executives would like to send a bottle of wine to Europe as a gift. Is there a way for us to import this into the EU without involving the person that this would be gifted to? We have operating locations in the EU but I am not sure if this matters […]


    QUESTION: Does the new ECRA REPLACE the EAA? In other words, is the EAA defunct now? ECRA is now the legal authority for the EAR. ============ Answers: Yes, that is my understanding ============ Both – Various parts of the EAR are currently authorized by various provisions of three statutes: -IEEPA/International Emergency Economic Powers Act -EAA/Export […]