Miscellaneous

MISCELLANEOUS

  • OFAC LICENSES TO IRAN

    Question:       OFAC issues general licenses to authorize activities that would otherwise be prohibited with regard to Iran. Such licenses are issued for items such as:  medicine and basic medical supplies, food, transportation of human remains, certain services of NGO’s activities or amateur sports, etc. The situation between US / Iran may change […]

  • TSU FOR PUBLICLY AVAILABLE SOFTWARE

    Question:       The below three questions came up when I was reviewing our export paperwork   for laptop hand carries by company employees.  I’m trying to understand how    and the limitations of the TSU license exception to the export of publicly   available technology and software.       The crux of […]

  • GLOBAL RISK ASSESSMENT

    Question:   Export trade data reports and facts about exports is at the   top of my list to assess export risk , I’d like to hear from the membership   what type of reports do you mostly use to manage and assess risk on your   export  activities and strategies?    Some of the […]

  • EEI PRE-DEPARTURE FILINGS Additional Answers

    Question:   My question concerns the list of countries where an EEI must be filed predeparture (as per 15 CFR 30.4 (a) 6).    15 CFR 30.4 provides for situations where you must file your EEI predeparture.   One of these situations is for “Shipments to countries where complete outbound manifests are required prior to […]

  • 5A002 BOARD IN 3A992 SYSTEM Additional Answers

    Question:   Our supplier has recently advised that the board which they supply to us is   5A002. We include it into the test system that we build in the US, which was   previously classified in a CCAT as 3A992. Does that affect the test system   ECCN? It is likely my predecessor did […]

  • EEI PRE-DEPARTURE FILINGS Additional Answers

    Question:   My question concerns the list of countries where an EEI must be filed   predeparture (as per 15 CFR 30.4 (a) 6).    15 CFR 30.4 provides for situations where you must file your EEI predeparture.   One of these situations is for “Shipments to countries where complete   outbound manifests are required […]

  • BIS LICENSE EXCEPTIONS Additional Answers

    Question:   Does anyone have the complete breakdown of BIS license exceptions that are “list based” vs. available for general use?  List based are the ones that must be noted with the ECCN entry on the CCL in order for one to use (ex. LVS, GBS).  The other ones can be used in any case […]

  • US IMPORT DUTY RELIEF

    Question:   Our contract manufacturer in China sources a raw material/component for our   product from the U.S. The component falls under 4908.90. This US raw   material/component comprises greater than 50% of the value of the finished   good. However, the substantial transformation of the product occurs in China.   We will import the […]

  • BIS CCL 5A002 Additional Answers

    Question:   If one has a 5A002.a.1 item, AND a CCATS stating it’s eligible for license exception ENC, does license exception ENC only overcome the EI reason for control (i.e. I still have to deal with NS1 control), or does a CCATS stating ENC eligibility overcome both reasons for control (EI / NS1)?   ============

  • DETROIT – TOLEDO LOCAL ICPA GROUP

    Local ICPA group:   NOTE: interested members MUST contact Lisa directly at: Lisa_Withrow-Tringali@mascohq.com   A few ICPA members are starting a local ICPA group in the Detroit – Toledo area.   It will start in January, meet one day a month (yet to be determined) from 3:00-5:00.  We will meet at different locations, but the […]

  • BIS LICENSE EXCEPTIONS

    Question:   Does anyone have the complete breakdown of BIS license exceptions that are “list based” vs. available for general use?  List based are the ones that must be noted with the ECCN entry on the CCL in order for one to use (ex. LVS, GBS).  The other ones can be used in any case […]

  • MANIFEST CONFIDENTIALITY

    Question: I submitted a renewal request for manifest confidentiality back in June.  I haven’t yet received  a response yet.  I’ve left 3 voicemail messages with the Privacy Act, Policy and Procedures Branch but no one returns my call.  Any suggestions? ==========