QUESTION: Is anyone else in the steel industry or trade community having a problem when filling out the exclusion request with the excel cell rounding their entered data? Example- in the cell for minimum thickness, I type 3.68mm but the exclusion request application rounds it to 4mm automatically. This is not what I typed but […]
QUESTION: Cast of Characters • Company DE • Company KR • Company U.S. • Forwarder DE • Forwarder U.S. • Broker U.S. • Pallet A-U.S. • Pallet B-U.S. • Pallet C-KR Scene (Problem) • Company DE exported Pallets A-U.S. and Pallet C-KR, to U.S. (EXW) • Company DE exported Pallet B-U.S. to KR (EXW) Notes […]
QUESTION: Is it compliant under the OFAC sanctions for a U.S. company, to sell a U.S. product to CITGO for delivery to CITGO in the U.S.? %%%%%%%%%%% ANSWER At the moment, the US has exempted Citgo from its sanctions until July 27. Still, I would recommend flagging as a high-risk customer already now, as these […]
QUESTION: Who does the BAA compliance analysis at your company? I feel like it should be procurement or supply chain. I’m a trade compliance manager and I’m being asked to do it. I feel like it shouldn’t be me. Am I wrong? ********************* Answers: From a procurement standpoint there really is not much for either […]
QUESTION: Does an importer need to apply for a ruling to see if their products qualify under the Nairobi provision, or would it be reasonable to reference an existing ruling for a “like” commodity for justification to use this provision? %%%%%%%%%% ANSWER: To get a better idea of the nuances of the qualification requirements, take […]
QUESTION: We have software that we want to make available for public download from our website in the USA. This would be a trial version of the software that expires after a period of time. If the user wants to continue using the software, they would have to purchase a downloadable software key. To download […]
QUESTION: We are working with a Russian supplier of plastic beads. They will send us free samples. The supplier is requesting that we send them our bank information. There is no sale, no $$ being exchanged. I am told its a “Customs requirement” but not sure how since this is an export from Russia, not […]
QUESTION: We are exporting a product to Korea and supplying the importer with a KORUS Certificate. Korean Customs insists that the classification falls in Chapter 29, but we classified it Chapter 38, clearly based on a Customs Ruling. I had heard in an FTA webinar that you could list two classifications for 1 part, if […]
QUESTION: We are a US based manufacture who will begin exporting to our client in Myanmar Our client, the end user, would like us to use a “third party cosmetic company” to act as the importer of record So the end user client does not have a delay in importing, clearing Myanmar Customs Our client, […]
QUESTION: I reviewed the recent penalty announcement from OFAC and realized I don’t know the answers to some basic questions https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20190131_elf.pdf 1. Is there any de minimus amount of North Korean content that can be in your finished good/component import from a 3rd country? a. Clearly we can not import NK origin goods, nor goods […]
QUESTION: My company recently had a broker file 2 entries under our importer number without our Power of Attorney. The only way I found out about it was through an ACE report. We also had this happen a few years ago. Is there a way to prevent brokers from erroneously filing entries with our IOR […]
QUESTION: Is anyone having delays from DBEI in Ireland regarding individual licenses for dual use items to end users (military / state entities) in Saudi and UAE ? If so, has the Irish government provided anything in writing? We have seen articles where other EU members have frozen arms exports to Saudi, but nothing about […]
