QUESTION: Compliance Personnel – In the training you’ve attended, where in the Regulations does it correlate with If you have knowledge the product shipped is to an end user on a sanctioned or embargoed parties end item and with that knowledge you have committed a violation? **************** General Prohibition 10 ***************This is all covered in […]
QUESTION: Company A (US), as exporter and manufacturer of the 600 series items, exports to Company B (DE) under a BIS export license. Company B, re-exports to a Company C (NZ) under the authority of a BIA re-export license. Scenario 1: Does Company C (NZ) require a re-export license to return the items to […]
QUESTION: We have been contacted by BIS export enforcement inquiring about our shipments to RU and wanting to make sure we understand the rules currently in place. We have stopped all shipments as of end Jan. The contact and email from BIS seems to be an outreach more than a fishing expedition , but wondering […]
QUESTION: Routed Transactions. It has been our process that for each and every routed transaction that we have, we obtain from the client a statement that states they approve the transaction as “routed” via their freight forwarder. We also obtain a statement from the forwarder that they “accept the transaction as routed in accordance with […]
QUESTION: How are companies dealing with increased demurrage and detention charges from forwarders? We book port to door, and do not believe we should pay these added fees. It is the forwarders’ responsibility to manage the process, correct? Shouldn’t they bear the cost and not pass on to us? %%%%%%%%%% ANSWERS: Not all forwarders are […]
QUESTION: Going through a merger and got pulled in too late to a detention turned exclusion of merchandise for “insufficient proof” no forced labor in supply chain. The broker/import staff who responded to the detention order did not understand the extent of the request (or what a WRO is) and admittedly didn’t do a great […]
QUESTION: I know that what GL account/s royalty payments are booked in does not determine dutiability – that is determined by the purpose and obligations of the payments – but does the membership have any views on what are best practices on how a company should book dutiable versus non-dutiable royalty payments? **************** Answers: The […]
QUESTION: My office in Switzerland purchases glucose meters/glucose sticks (used by diabetics) from a Japanese manufacturer and imports them into Poland and warehoused. Because of the Ukrainian/Russian war. Screening of Russian sellers/distributors were performed and no red flags. However I was told that my office in Switzerland is required to obtain a BIS 711 from […]
QUESTION: We have a Russian customer that pays in advance for their order placed with our division in the EU (our HQ is in the US). According to Finance, we should be fine because if the bank blocks the payment, we won’t sell and not on the hook since we screen the customer and our […]
QUESTION: Do the Russia sanctions in place by OFAC restrict the future purchase of, or current ownership of stock in Russia sanctioned companies? %%%%%%%%%% Answer: This is a complex question as there are several different layers, or tranches – if you will, of sanctions with each having different impacts on the named sanctioned entities. Some […]
QUESTION: Due to the imposition of sanctions on Russia and Belarus we have a number of containers that are either in process of being shipped to Russia or are in transit that need to be turned around a come back to the US. I know we can return them without making entry because they are […]
QUESTION: We only manufacture EAR99 items. We have more than 15 plants in the US, do we need to screen visitors? We have a visitor check in process with temporary badges but currently not screening them. =========== Answers: Yes, even though you only manufacture EAR99 products some of these products can be considered dual use. […]
