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 […]
Question: Our company has a “Know Your Customer” screening process in place. We ask our sales reps or customer service reps to complete a “Know Your Customer” questionnaire for every account they handle and we ask them to refresh the questionnaire ANNUALLY. The usual questions appear on this questionnaire, i.e., what type of business is […]
Question: A routed transaction, 15 CFR 30.1 is defined as a transaction in which the FPPI authorizes a U.S. agent to facilitate export of items from the United States on its behalf and prepare and file the EEI. The definition clearly states “AND” as both are a requirement to fit the definition of routed. If the […]
Question: My question is regarding counterfeit products found in the US market. Our marketing team bought some products from on line retailers. After our product team’s review and test, it’s confirmed they are counterfeit products. Can someone in the membership share their experiences in handling this counterfeit product issue? Is there anyway to find out […]
Question: Would any member be willing to share their trade show process or template for importing, exporting trade show booths and associated equipment, giveaways etc.*************** ANSWERS: We typically work with the forwarder that is selected by the event organizer for the event. They provide us with all of the information we need, including all forms […]
