QUESTION: One of the requirements for using Strategic Trade Authorization (STA) is tied to previous USG authorizations. Can this be any applicant’s authorization or only the exporter’s authorization? · 740.20(c)(1) o Note to paragraph (c)(1). License Exception STA under § 740.20(c)(1) may be used to authorize the export, reexport, or transfer (incountry) of “600 series” […]
QUESTION: I’m curious to learn what policies and procedures other companies have implemented with regard to the use of, and access to, CCL-controlled capital equipment and its technology. For example, if a company buys a machine tool to support its manufacturing activities, and the machine tool happens to be classified as 2B001, do you have […]
QUESTION: Our marketing team wants to ship company SWAG, tee shirts, mugs, paper notebooks, hats, pens etc. Value is about $30.00. No food or beverages will be shipped. Can we just send this by a larger courier to a home address as personal items without itemizing and classifying? %%%%%%%%%% ANSWER: There is no generic customs […]
QUESTION: I could use some advice from the membership. We recently had an exact name match between a person at a customer and an entry on the Entity List. The Entity List entry was added in 2012 and only has the name and an address in a suburb of Moscow. Our customer is in Moscow. […]
QUESTION: With the Hong Kong Autonomy Act being signed into law, will the Section 301 tariffs be applied to imports made in HK now? %%%%%%%%%% ANSWERS: https://www.whitehouse.gov/presidential-actions/presidents-executive-order-hong-kong-normalization/ %%%%%%%%%% Yes. ================================================================
QUESTION: With the onset of Hong Kong now being treated as China, has there been anything stated about a change to the two digit country code to be utilized for imports and exports. Are we still to use HK or should it now be CN? %%%%%%%%%% ANSWER: My understanding is that you will report CN. […]
QUESTION: We are looking for ways to mitigate tariffs besides the use of exclusions on products for building infrastructure. Does anyone know if there is a provision or program for products used in building infrastructure that allows for a reduction in tariffs? ******************* Answers: Tariff reducing provisions and programs? There are numerous. Free Trade Agreements (FTAs); […]
QUESTION: What are the tools/mechanisms that OFAC has at its disposal to discover a potential violation of a US foreign owned company conducting Business with a 50% sanctioned ownership company? Even when the US company does daily screening against the 50% sanction lists that are out there, those lists may not be complete, and […]
QUESTION: The 32 FAQ’s regarding Venezuela do not directly answer these questions. Seeking help from the members: Regarding the recent changes in export law to Venezuela, what is the likely correct answer to the following: Product “A” is not military at all, no dual use, completely civilian, EAR99, but Product “A” [a fully automated pallet […]
QUESTION: 3 scenarios. Facts as follows: US Company “A” sells to Europe company “B”. No OFAC sanctions in place on company “B” AND Company “B” is not owned in aggregate of 50% or more by OFAC sanctioned entities. Company “B” places a PO to company “A” and in the PO instructs company “A” to ship […]
QUESTION: Our US company will be leasing manufacturing equipment to a manufacturer in Thailand. The equipment will be used to manufacture a product for sale within Thailand and to other countries. The manufactured product will NOT be exported to the US. Our US company will receive a royalty off the sales of this Thai manufacturer. […]
QUESTION: Can someone confirm that if the export consist of only EAR99 and NLR, the export is exempt from the EEI filing change on 6/29/20? %%%%%%%%%% ANSWERS: Below is a reply we received directly from BIS’ Regulatory Policy Division: QUOTE Please review the guidance that BIS has provided on its website at https://bis.doc.gov/index.php/all-articles/2-uncategorized/1686-revisions-to-eei-filing-requirements-pursuant-to-revisions-to-section-744-21-china-russia-venezuela-military-end-use-end-user-rule. Per the […]
