Question: I have been hired to create a trade compliance program for a midsize import / export company. To my surprise, there isn’t a centralized department nor does senior management understand the fundamentals. I am looking for a big statement of what trade compliance is……something along the lines of Trade compliance is the bridge between […]
Question: I currently have the fourth edition (2007) of the Explanatory Notes. Can the membership advise if the changes to the new edition are substantial enough to warrant an investment to the fifth edition (2014)? ========== Answer: While the question of how to invest your budget is ultimately one for you and your company to […]
Question: What do the members recommend to be the best avenue for obtaining guidance from OFAC, related to embargoes/sanctions as they pertain to a potential business deal? Is contacting and obtaining a response from OFAC_Feedback@treasury.gov good enough? Or must we do some form of an official inquiry? ========== Answer: I have called them with questions […]
Question: I am holding an individual Customs license, but I am not actively engaged in Customs business. Do I still need to pay $100.00? Please kindly let me know. I thought I could just fill out the form and send to the port, and I don’t need to pay $100.00. ========== Answers: You have to […]
Question: I filed 2 protests with Customs in late 2012 and early 2013. They were both approved on April 30, 2013. This is for a total refund of $38,000. We have not gotten a check yet. How long does this take? I also filed several PEAs in early 2013 on the same issue which is […]
Question: We are about to start exporting to China on a regular basis. I need to know the requirements for certificates of origin. Are they required? Can we create a blanket certificate? Does it have to be stamped by our local Chamber of Commerce? Is there a better way? *************** ANSWERS: The China customer should […]
Question: I am curious to hear what compliance training other companies do for their third-party partners, like distributors, sales reps, vendors, customs brokers or freight forwarders. If you do get involved with training them, what are the details? And is it live, recorded, web-based, etc? Do you use an outside training company? What issues or […]
Question: We have been asked to approach OFAC to obtain a General License for our Europe operations to ship to Crimea. This license would be for USA origin goods that are consider EAR99. The goods are initially exported from US and sold to our Europe intercompany location. The goods come to rest in EU territory, […]
Question: I am wondering whether Writ of Mandamus” or “Administrative Procedure Act “(APA) can be used to compel a Federal Government Agency such as CBP to make a decision on pending matters within a reasonable amount of time. I am referring to binding ruling request at CBP HQ in DC that sometimes takes years to […]
Question: We manufacture electronic equipment that we have designated as EAR99. However, recently I was informed that some of our products with this designation contain MMIC power amplifiers. Do we need to make a classification determination based on the MMIC amplifier within the final product, or the final product performance and technical characteristics itself? ========== […]
Question: We are a US company who usually sells product through an agent in Canada, but occasionally we will send no charge samples, or urgent warranty replacements directly to customers. There is not currently in-house agreement to provide a POA for our courier to clear the goods on our behalf in Canada, so DDP shipments […]
Question: Licenseable means the NEED to get a LICENSE Exemptions and Exceptions ELIMINATE the need for a LICENSE ******** ITAR 126.5 is the Canadian exemptions section. Most of those are easily “licenseable” (according to at least one version of that definition anyways).  So most likely you meant the 126.1 countries (arms embargoed). But […]
