Miscellaneous

QUESTION: I would say that no BIS RPL lists apply to suppliers/parties the company imports from. Does anyone restrict their screening of suppliers to only OFAC lists? Thanks- ========== Answers: I would disagree. ========== A company should be verifying all parties with whom they do business. My company uses an online database which screens from […]

QUESTION: I would like some membership feedback on the below… Company A and B are related and both US based. Company A cuts a PO (FOB terms) to a China supplier for 90 widgets. Company A is the IOR upon arrival/entry of the goods for US Customs purposes. Company A files customs entry and clears […]

QUESTION: Are there any repercussions for reporting a suspected trade violation if after CBP’s investigation it turns out it’s not a violation? We were told by our manufacturer in China that a seller in Canada purchases from a competitor in China shipping to Canada and then selling in the US market with a NAFTA Certificate. […]

QUESTION: We are looking at expanding e-commerce business into Asia. Local customers will enter orders using local characters such as Japanese, Mandarin and Hindi. I am looking to see if anyone in the ICPA membership has dealt with RPL screening of non-Western characters and can provide advice. Do you hire a service to translate to […]

QUESTION: I have an opposite situation, but similar concept. In my case, the Tier 1 supplier is using components from multiple other countries (more than five), and installing them into the final assembled product that we are buying from them. We are paying for tooling costs to each of those locations, including our Tier 1. […]

QUESTION: I work for a multi-layered company with one of our units being a 3PL who arranges export transportation for our customers. We have never owned the product and we simply warehouse and arrange transportation for our customers. Another business unit is a distributor where we own and sell the product locally and then act […]

QUESTION: We are spending a lot of time researching our customers located in sanctioned countries so we would like to prepare a general questionnaire for our customers to answer to help us with the clearing process. I am looking to see if anyone has a questionnaire they could share on this subject or give advice […]

QUESTION: My U.S. customer has a foreign sister company who violated the Iran Sanctions; neither company has been placed on the Denied Parties Listing. An agreed to penalty was paid. My items were not directly sold into Iran, but my items were assembled onto the item that was sold to Iran. What are my liabilities […]

QUESTION: Has anyone in the ICPA community explored the use of a 3rd party importer of record (IOR) service provider in countries (outside of the US) where your company does not have a presence and your in-country customer does not want to be – or cannot be – the IOR? This IOR service provider would […]

QUESTION: Wondering if anyone had a strategy for allocating Customs assist costs to multiple regions which require assist declaration? Let’s assume transaction value and 100% costs are allocable to the assist- Do you consider an assist used in sales to multiple countries is declarable at full value outside the US, or is there an approach […]

QUESTION: As a follow-up question, what if the foreign-based Trade Compliance staff has dual citizenship? i.e., both a U.S. passport and a passport issued by an EU member country? Original question: Our Trade Compliance group supports DCs in the US, SG, and NL. I am the only staff in the US and was wondering if […]