QUESTION: Where does the responsibility for FCPA (Foreign Corrupt Practices Act) reside in your organization? Does your Global Trade Compliance/Customs Compliance department or team manage the compliance for this area? If not, how is it managed and by ‘whom’? ==================== ANSWERS: In my experience, FCPA is usually managed by Legal and not Trade Compliance when […]
QUESTION: We understand that PSCs with a revenue adjustment of less than $ 20.00 are not required. We import under a preferential trade program and have discovered potential issues with our valuation. There will be zero duty impact with making value corrections so we are clearly under $ 20.00/entry. I would think to cover ourselves […]
QUESTION: We are importing an used equipment and will extract one part from it, This part will be then exported back to the same foreign supplier in France. Is this considered a substantial transformation? We are no charging the supplier for the work perform to break the equipment apart and obtain the part. I am […]
QUESTION: I am hoping some guidance can be given for Routed Transactions, and what others consider to be due diligence for attempting to have corrections made to EEI filings (all EAR99 products). The error could be the USPPI address, or adding Inc or LLC to an entity name, or not placing the correct gross […]
QUESTION: If another company requests and is granted reduced duty on a tariff code / item, can any importer also claim the reduced duty for the same goods? If so, what is the procedure? ************** Answers: Yes, any importer can take advantage of a MTB if it is granted. The MTB will be effective for […]
QUESTION: Regarding Manifest Confidentiality, I am requesting clarification regarding the variations of company information that should be included. I have looked at past answers on this topic which include how the request is worded. I realize that including variations of the actual names of the parties (importer/consignee) in the request are key to effectively keep […]
QUESTION: I will be starting a new job as a trade compliance manager. HR and hiring mgr warned me that I will be inheriting a team that is not functioning well and has some issues, some of it is blamed on previous manager and some on the current staff (old dogs not wanting to learn […]
QUESTION: Has anyone started receiving refunds yet for their protests on phones covers since the Otterbox Court decision was finalized on 11/23/2016 ? ================== ANSWER: Not for my clients. We are told by the CEE that they are awaiting instructions from HQ on how to proceed. I realize you may be saying, “The Court of […]
QUESTION: Would anyone in the membership be able to provide a link to the export regulations for South Korea in English? ================= ANSWER: You might try this link: http://www.yestrade.go.kr/portl/html/eng/sub02/s02_3.jsp
QUESTION: Do any members have experience in dealing with “4PLs”? A company is considering “outsourcing” the export/imports process to a third party that is not a forwarder or broker – this third party would be the 4PL. The 4PL would handle logistics and clearance processes, and work with forwarders and brokers. The main question we […]
QUESTION: Have any other members had an experience with the Dept. of Agriculture locating a wood borer larvae in a container, though all pallets are stamped heat treated? If so what options were you given? How did you address? Our forwarder advises the inspector assigned issued an EAN (Emergency Action Notice); when we inquired about […]
QUESTION: We are transferring a pallet of liquid samples (classified as hazardous) to a foreign customer as an ancillary part of a divestment agreement. The foreign customer has assigned a U.S. NVOCC to pick up the pallet under a routed export transaction. We have agreed to provide MSDS, pack the pallet, and load for pick […]
