Question: I am interviewing for a position that wants candidates with knowledge about IMO shipping regulations. I think these regulations were adopted by the US and made part of 49 CFR. I know quite a bit about that. I can’t find a solid x-ref to confirm this. Does anyone know where / how the US […]
Question: We are a freight forwarder considering hiring a foreign national on an L2 visa with Class A18 employment status. I have reviewed the ITAR, but am interested in other members€™ concerns and suggestions regarding our obligations under the ITAR with respect to our customers€™ business. The employee would have access to the usual forwarding […]
Question: The sanctions related to the Russian aggression towards the Ukraine placed restrictions on our business dealings with a published list of individuals plus any entity over 50% owned by these individuals. Such ownership is not always easy to determine. Does anyone know why the US government has not published a list of those entities […]
Question: I was informed that a blood collection kits (to be used in conjunction with a clinical study I guess) was being held by courier company, where they needed the Affirmation of Compliance code. When I looked at the invoice I read that the kit consisted of needles, test tubes, pipettes, blood collection needles cryovials. […]
Question: Does anyone in the membership know if information on penalty assessment in Census VSD cases is published, and if so, where? We are trying to assess the likely financial outcome of a Census VSD involving several years of errors in AES filings ************ ANSWERS: CBP penalties issued for AES violations, whether or not related […]
Question: As a trade compliance professional who reported up through tax and tax planning departments I became familiar with the concept of “tax provisioning”. This is when a company sets aside an amount of money to pay possible tax liabilities in the future. Sometimes these payments never materialize, sometimes they materialize but are less than […]
Question: Do you block sales to parties on the World Bank Debarred list? ********** This is a very general question. If your business or project is financed by the World Bank, or if you are operating under World Bank conditions, you should. ************ Yes, to anyone on any of the lists ************ If you mean […]
Question: Does anyone in the membership have any suggestions we can use when our international sales people are getting orders from new customers? Ideally, we’d like to set up a standard form that our sales team can fill out which would show Customer name, company name, ultimate country of destination, freight forwarder, Incoterms expected, bank […]
Question: I have an interpretation question regarding license exception TMP. It says in 740.9(a)(5) that the “exporter maintains ownership of the commodities and software while they are abroad.” Would ownership by a wholly-owned foreign sub or foreign branch satisfy this requirement? ========== Answers: Ownership is related to who owns the item is temporary exported so […]
Question: We are a US company and have 2 people registered for a conference in Russia. The list of speakers includes at least one person on the OFAC SDN list and there is a registration fee for the conference. My train of thought is that if the speakers are volunteers/not paid, I have no issue […]
Question: We have a situation which I’m sure is not unique to the industry but unsure how to handle it or what the solution would be. Our contract with our customer states “we retain title and loss until destination (our customer)”. The customer also requests (demands) we use their preferred carrier. A shipment arrived to […]
Question: I’d like to know how the membership handles preparing IMO or IATA DG declarations for routed or distributed shipments. For routed, we are acting as the exporter but often will not pack the goods in the container for export. The will be delivered to a forwarder first so we cannot attest that the packaging […]
