Question: Where do most of the ICPA members place responsibility for TSArequirements? Who is responsible for monitoring and audting the screeningcapabilities and process as well as signing PoAs and consent forms withservice providers ? Is this considered a transportation or trade complianceresponsibility? If trade compliance, what is the rationale? What regs arethere that would require […]
Question:We have a project that calls for handouts of technical data at working meetings where foreign persons are present. Our relationships with foreign government labs, contractors, and subcontractors are complex. We have several Technical Assistance Agreements covering many more countries than we have Agreements, plus many DSP-5 licenses for individuals. Does anyone have a footer […]
Question: In 27 CRF 447.53 (a) (3) – (Exemptions) It states that ” The provisionsof part 447 are not applicable if” …..importation of articles (other thanthose which would be “firearms” as defined in 18 USC 921 (a)(3))manufactured in foreign countries for persons in the US pursuant todepartment of state approval. Q (1) – A defense […]
Question:Does anyone in the membership have a TAA amendment template for a foreign party to the agreement name change (only)? This is treated as a minor amendemtn per 22 CFR 124.1(d). I am not sure which TAA amendment language and certifications need to be included.
Question:Any members created a quick and easy guide for their companies on doing business in France, Japan, Thailand or India. Would you be willing to share? Found the FexEX website with profiles but wondered if anyone had put something in a presentation format. If not, know of any other sources?
Question: US CBP recently reliquidated several informal entries (1 with an EV of$240) that were entered under 8708.99. Customs rate advanced theentries to 3926.90 making these formal entries. It is my belief thatthe correct HTS classification is under 8505.90. These entries were allreliquidated well beyond the voluntary reliquidation period of 90 days. Does CBP have […]
Question: We are assessing the impact of a resolution (Resolution 251) announced inAugust by the Secretary of Industry in Argentina that would require alicense to import printed matter (manuals, publications, software licenses,etc) into the country. There is currently a 60 day hold on theimplementation of the resolution that is now scheduled to take affect inearly […]
Question:Our company has a large number of EEI’s filed per year against our EIN number by forwarders that have been given authority by the FPPI to do so. This process as we all know makes it difficult to check their work. The transactions are routed so the authority given by the FPPI is valid. We […]
Question: We are reviewing our standard mutual non-disclosure agreement (MNDA) for use with potential overseas business partners. The existing agreement was written for use between two or more US companies and contains reference to export-controlled information as follows: Proprietary data exchanged under this agreement may be subject to the export laws of the United States […]
Question:I have seen correspondence from ICPA members in the recent past indicating that if you are the ultimate consignee and not the importer of record, Customs will go after the ultimate consignee since you are the party that caused the import. I have also seen the Focused Assessment ultimate consignee record keeping guidelines and it […]
Question: Does anyone know if there is any screening of export containersfor radioactive content at the ports? We are running into a problem wherewe need to ensure non-radioactivity in the non-ferrous scrap we areshipping and some of our suppliers don’t have the means to screen attheir facilities. Management has asked the question about whether ornot […]
Question: I am in the process of increasing resources for our Import/Export department which currently exists of 1 Trade Compliance Manager. We currently import over 4500 imports annually and a yet to be determined # of exports. I was looking to benchmark other companies to see what the size of your Import/Export Department is relative […]
