Miscellaneous

MISCELLANEOUS

  • Foreign National Employment

    OT Fact Sheet: Origin Certification Requirements QUESTION: We have situations where our foreign owned company employs citizens from embargoed countries (think Iran) to work in the United States. We have controls around what projects and tech data they are exposed to but interested to hear if the membership has any best practices, they would be […]

  • Uk restricted party lists

    OT Fact Sheet: Origin Certification Requirements QUESTION: I was checking with my Restricted Party List screening provider to ensure they have added any “new” lists this year put out by the UK post-Brexit.  They’re telling me that there’s really been no change – they already offered (pre-Brexit) a unique UK list “consolidated financial sanctions targets) […]

  • Documentation to the Middle East

    OT Fact Sheet: Origin Certification Requirements QUESTION: Does anyone have any tips or tricks to shorten the process of presenting documents to countries in the Middle East (namely Qatar, UAE, Saudi Arabia and Bahrain)? As I understand it: All commercial invoices and packing lists must be stamped and signed with wet ink A certificate of […]

  • Humidity, Location, Light and Temperature Logger and Communicator

    OT Fact Sheet: Origin Certification Requirements QUESTION: I am exporting a humidity and temperature logger to our subsidiaries for them to use during shipments of product that is susceptible to heat, cold, humidity and light. The vendor has told us that they use HS Code 8517.62 – Machines for the reception, conversion and transmission or […]

  • ETHICAL SOURCING

    OT Fact Sheet: Origin Certification Requirements QUESTION: I am curious on how USA importers handle ethical sourcing.  For example let’s say I import a shirt (100% cotton) made in Korea and apply the Korean USA FTA.  CBP issues a CF28 requesting information regarding the origin of the cotton.  Well as the importer I would have […]

  • HS codes on invoices for Saudi Arabia

    OT Fact Sheet: Origin Certification Requirements QUESTION: Is anyone in the membership aware of new SASO rules (certification process) that would discourage HS codes on export documents?  We use a software program that prints the HS code on the invoice, certificate of origin, and the packing list.  If the importer in Saudi is using their own […]

  • Controlled technical data

    OT Fact Sheet: Origin Certification Requirements QUESTION: Could anyone share how your company ensures associates do not access controlled technical data while traveling to arms embargoed countries (particularly China) with a company owned mobile device? Do you prohibit the associates taking the mobile device? Do you create a contractor account with no controlled technical data […]

  • SHIPPING TO SUDAN

    OT Fact Sheet: Origin Certification Requirements QUESTION: Now the BIS has removed Sudan from the State Sponsor of Terrorism list if we sell items that are EAR99 and/or only controlled for AT as long as we do not sell to denied parties are we Ok to sell to Sudan? Do we need a license or […]

  • HTS CHANGES ON SHIPPING DOCMENTS

    OT Fact Sheet: Origin Certification Requirements QUESTION: We export food products from both Canada and the US to over 100 countries globally. In the last few months, we have received requests from International Customers asking us to change the HS code on their documentation.  In some cases, we do not agree with the suggested HS […]

  • BIS LICENSED SHIPMENT OVERVALUED

    OT Fact Sheet: Origin Certification Requirements QUESTION: It’s been discovered that 2 export shipments we made in January had incorrect prices. Our AR department discovered 2 digits on the price were transposed causing the shipment to be overvalued. What are the requirements/best practices in regards to updating the value on our EEI filings to reflect […]

  • SELLING USML AND CCL ITEMS

    OT Fact Sheet: Origin Certification Requirements QUESTION: We stock aircraft parts, some of which are on the USML, some are on the CCL, most are EAR99. We sell these to only U.S. companies; what is our due diligence when determining their plans to potentially sell these to foreign end users? ************* Answers: If you are […]

  • Shipping Items with encryption to Russia

    OT Fact Sheet: Origin Certification Requirements QUESTION: My company has a part that has encryption. We already filed with BIS for a CCAT#. We didn’t receive a CCAT# yet. 30 days have already passed. Can we send the part to customers in Russia? =========== Answers: I would not send it.  I would follow-up with BIS […]