QUESTION: Does anyone running SAP know why they have the country code for Greece as “EL” instead of “GR”? They are telling me they can’t/won’t fix it. It causes a snafu when I extract customers from SAP to upload to my Restricted Party List screening provider, as they reject them all for invalid country code. […]
QUESTION: One of my suppliers was recently added to the Entity List for human rights/ forced labor issues. Unsurprisingly, the supplier denies the allegations. The fact that the US govt has come to this conclusion should lead us to a pretty strong presumption that there are slavery/trafficking concerns at this supplier. But we have no […]
QUESTION: Is a shipment by a small parcel carrier considered to be a routed export if the foreign customer asks for the freight charges to be charged to their account with the same small parcel carrier? The shipping company would be in full control over all other aspects of the shipment. ============ Answers: No. Same […]
QUESTION: Can you please advise how you are assigning a country of origin (COO) to a software as a service (SaaS) intangible item for Trade Agreement Act (TAA) purposes ? %%%%%%%%%% ANSWER: We use the IP owner. This is a challenging one since coding is often done in multiple countries. Party that owns the intellectual […]
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 […]
