QUESTION: If we export from the U.S. to Belarus (D:1 country per EAR) items that are EAR99, do we need a license from BIS and/or OFAC? ************* Answers: With respect to Commerce and the EAR, review your General Prohibitions with respect to the facts and circumstances of the transaction. Uncontrolled items subject to the EAR […]
QUESTION: Curious if anyone in industry would be willing to share how long it is taking to receive their TAA approvals these days? ========== Answers: I handle these approvals for my company. If they are TAA under Construction materials it takes a long time for you have to go through every item to see if […]
QUESTION: My company is importing a large machine that was broken out into 2 containers. One of the containers was bumped to the next vessel. The original plan was to import both containers at the same time and clear as a single machine, albeit unassembled. I am not sure how to clear this now that […]
QUESTION: Looking for feedback on doing business via the GSA vs. Tier 2 resellers. We currently participate in the GSA but we may not want to in the future. What are the advantages and disadvantages of each? Thought asking the people who actually do the work might be the place to get some “real” answers. […]
QUESTION: Looking for feedback on doing business via the GSA vs. Tier 2 resellers. We currently participate in the GSA but we may not want to in the future. What are the advantages and disadvantages of each? Thought asking the people who actually do the work might be the place to get some “real” answers. […]
QUESTION: Cargo arrives in the US and is admitted to the FTZ. Two years later the cargo is withdrawn from the FTZ and entry is made into a bonded warehouse using a type 21 entry. What is the date of importation which starts the 5 year bonded warehouse time limit? %%%%%%%%%% ANSWERS: I would surmise […]
QUESTION: We don’t import anything on the high risk list of goods produced by forced or child labor. Should we still implement a process for verifying our suppliers’ manufacturing locations outside the US? If so, what are members doing to check all the vendors locations when they don’t import goods produced by forced or child […]
QUESTION: Does the consignee country need to match the destination country on a certificate of origin? The factory cannot issue one C/O for consolidated shipment from CN because the destination is in the UE and the buyer is located in the UK. %%%%%%%%% ANSWERS: Is this a drop shipment? Are you confusing a Certificate of […]
QUESTION: We imported lumber over 10 days ago, but since it was not heat treated at a high enough temperature at origin, CBP issued an Emergency Action Notice saying that we have to send it back. Duties of $40 are scheduled to be paid ~Sep 22 under Periodic Monthly Statement. Where in the regulations does […]
QUESTION: Is a BIS-711 End-User Statement required if my shipment is NLR? When might I want this with an NLR shipment, and when might I not? %%%%%%%%%% ANSWERS: Technically a BIS 711 is not a requirement however the totality of the circumstances needs to be considered. It is dependent on a number of factors – […]
QUESTION: I’m looking for best practices to perform a deeper drive in sanction party screening. In most cases, the party exercising the task at hand only has limited information (name of entity, address, tax ID) so, learning about company officers or subsidiaries require further research. How do you learn about these when all you have […]
QUESTION: Would the membership kindly share supplier due diligence questionnaires with respect to trade sanctions, FCPA, and forced labor? =========== Answer: Is this for large volume vendors only? If so, what value? You may want to approach this similar to an M&A due diligence perspective and then cut back on the line of questioning. You […]
