QUESTION: I’m looking for thoughts on End User Statements and whether your company uses them? It is a “Best Practice” on all the government trade sites and we have incorporated them into our compliance program. Most of our products are classified as Dual Use, and are EAR99 and we only request them for exports. […]
QUESTION: I know we have sanctions and embargoes on NK, IRan, Cuba which limit our ability to trade with these countries without certain licenses, exceptions and approvals. I was surprised to learn recently though that a US citizen can travel to Iran, Cuba or NK without an issue. Is this correct? I always thought […]
QUESTION: FACTS Company A resides in the United States Customer resides in Mexico Customer designates a freight forwarder in Texas Company A ships to freight forwarder in Texas and receives payment from Customer in Mexico QUESTIONS Is this a routed transaction? Who files the EEI? Should the Freight Forwarder be requesting Company A’s EIN? Should […]
QUESTION: My company is developing a global valuation standard. We’d like to add an appendix list of FOB vs CIF value countries. Does anyone know of a published list where we can get that information? ========== Answer: The vast majority of WTO countries are CIF. I’m not aware of a formal list, but the FOB […]
QUESTION: I’m new to the area of software downloads and need some best practices. Obviously, it’s easy to ban IPs in Iran, North Korea, etc. But is that enough? How do I guarantee that a prohibited national isn’t downloading the EAR99 software another way, in another country or by masking his IP address? I guess […]
QUESTION: We are a manufacturer of paper/plastic products all EAR99. We don’t sell medicine, agriculture commodities, or medical devices. If we conduct denied parties screening, would it be safe to exclude Sudan from the restricted countries list or there are other restrictions I should be aware of? BIS mentions CCL based controls §742.10 (not applicable to […]
QUESTION: Scenario: Drapery sold to cruise line for guest rooms ion the vessel Goods to be shipped to Miami, FL to the customer’s (cruise line) agent Goods to be placed on non-US cruise ship in Miami prior to sailing Question: Is this considered a US domestic move because the goods were loaded in Miami, or […]
QUESTION: Below is a response that was given to a question posed last August. Does anyone know if Census has provided any new guidance regarding the use of 98 for exports when 98 was not used at time of import? RESPONSE: “This question has been presented to Census as part of the Aerospace Industry Association’s […]
QUESTION: Looking for clarification as to whether our broker was correct in claiming Special K (duty free) provision on Chapter 29 HTS without the CAS# or compound name being listed on the Chemical or Pharmaceutical Appendix. Also, looking for confirmation that according to General Statistical Notes Section 3(c)(iv) goods eligible for Special K provision are […]
QUESTION: The Importer I work for was under CBP audit at the time I was hired. The audit had been ongoing for a couple of years and they had a prior audit a couple of years before that. We have two prior disclosures out for valuation, classification and ADD/CVD. Our counsel (CBP Attorney and the […]
QUESTION: I just got done reading attachment A to customs directive 3550-055 regarding constructing MID codes for US imports. It references constructing the code a for a manufacturer or SHIPPER. My question is: is one to use the SELLER name/address or the SHIPPER name/address? Example: Seller is ALWAYS ABC Co 123 Main St Berlin Germany. […]
QUESTION: I am preparing a compliance audit/ risk assessment for my facility in Mexico. In addition to topics such as classification, valuation, etc., what questions should I ask specifically for IMMEX compliance? ========== Answers: Valuation method declared upon import and upon export usually the raw material imported is under consigment so no direct sale, but […]
