Miscellaneous

MISCELLANEOUS

  • GL Coding for freight, customs, brokerage and miscellaneous expenses

    QUESTION: I was hoping someone could help me figure out the best way to code invoices/bills from our couriers and FFs/Customs brokers. We are looking at our freight and duty costs and realize that when the accounting system was set up the accounting team simply set up two GL Codes; Inbound Freight and Outbound freight. […]

  • Routed Transactions

    QUESTION: What needs occur when there is a routed export transaction, (the FPPI appointed its US forwarder to export the goods and file EEI)- However, the EEI is being filed under the USPPI’s EIN number? ============ Answers: 15 C.F.R. §30.3(e) covers this nicely and includes your responsibilities as the USPPI in a routed transaction as […]

  • Customer restricted party screening

    QUESTION: Does anyone screen less than their entire universe of foreign customers, for either cost or manageability or other reasons? For example, by applying certain risk criteria such as transaction size or customer location or EAR99 status of the merchandise? Thank you =========== Answers: Not sure this is a good question to ask – the […]

  • Russian supplier info to conduct their own denied party screening

    QUESTION: I received an email from our courier broker asking for information regarding our Russian supplier so they could conduct the Denied Party Screening #1,we conduct DPSs of all vendors, customers banks etc. We told them it was not necessary because it was done and we showed proof of screening. #2 the name and address […]

  • EGYPT DEC. OF CONFORMITY

    QUESTION: • My sales person received an email from one of our customers in Egypt asking for a Declaration of Conformity for the product we sold and exported to them. The product is sitting in Egyptian Customs right now. We are not the importer of record and do not have a presence in Egypt. What […]

  • MID CODE SCENARIO

    QUESTION: I have an item that is formed in to the actual item in CN and then shipped to TH to have a finish coating applied. The coating does not change the character of the good. In this case, since it does not involve textiles, can I use the seller/shipper MID code (TH) on the […]

  • Data release info from CBP

    QUESTION: Is there a way to request with CBP not to release our data to Market Intelligence platforms? ========== Answers: https://www.cbp.gov/sites/default/files/assets/documents/2019-Aug/Electronic%20Vessel%20Manifest%20Confidentiality%20Trade%20ACE%20Information%20Notice_2.pdf ========== Yes, and I think it is a good idea to do so. See 19 CFR 103.31(d). You can request import and export manifest confidentiality. There is supposed to be an electronic process rolling […]

  • OFAC enforcement

    QUESTION: Question regarding the Apollo Aviation OFAC case. What is the opinion of the group that if Apollo had received end user certificates they would not had compliance violations? Is Apollo’s liability continual since these were leases vs sales? I want to understand OFAC’s intent so I can ensure our company’s policies and practices are […]

  • WCO/WTO COOPERATION WITH NON-MEMBERS

    QUESTION: Can anyone point me to WCO and/or WTO rules, regulations or clauses that have to do with the jurisdiction WTO/WCO member customs agencies over importers or exporters outside of their jurisdiction? For example if a customs agency in Brazil or India or Japan wanted detailed information about a US company’s product’s manufacturing process or […]

  • Authority of Customs Agencies to require staffing

    QUESTION: In addition to the power and authority of Customs Agencies (globally) to assess fines and penalties on importers when there have been clear indications of negligence, gross negligence or fraud uncovered during an audit, do Customs Agencies also have the legal authority to require an importer to hire qualified staff to address the issues […]

  • How to investigate duty application by origin and product?

    QUESTION: Hello, we have been importing from China, are in the process of investigating feasibility of switching to other countries of origin. There are special duties like Section 301, 232, etc. that apply per origin and product. Is there an easy way to figure out which applies to our potential new source? Is there a […]

  • Possible move of DC from Germany to Netherlands – due diligence

    QUESTION: We are revisiting the site location of our DC in Germany. Our business is growing and before we expand into new warehouse space we would be interested in the pros and cons of moving our DC to NL. Has anyone done this before? Would you be able to show your pros and cons and […]