QUESTION: Our compliance department is not located at corporate and we would like to know if it’s possible to change the mailing address for customs correspondence to the offsite address without changing the IOR location at corporate. I talked to our broker and they said this was not possible unless the IOR address was changed […]
QUESTION: Our company sent hardware to our foreign subsidiary in for use in a trade show. Now our foreign subsidiary would like to do an in country transfer to another company. Based on the ECCN and the BIS Part 740.9 the article sent to our foreign subsidiary qualified for the BIS TMP exception. Since the first […]
QUESTION: We are wondering if anyone in the membership can provide a clear answer to a question we have about when a licensing agreement should be counted as an assist. Here is the scenario: Company A is an importer in the US and pays for a license to use Company B’s (which is also located […]
QUESTION: When filing the EEI, indicating domestic or foreign origin of goods is a required as a mandatory field per below reg: FTR 15 CFR30.6(a)(11) Domestic or foreign indicator. Indicates if the goods exported are of domestic or foreign origin. Report foreign goods as a separate line item from domestic goods even if the commodity […]
QUESTION: We have to provide proof of use certificates for goods that we are legally importing duty-free under 9817.00.50 agricultural use. The imports happen multiple times during the year. We are considering how often to provide these proof of use certificates. For anyone who has done or is doing these certificates, how often do you […]
QUESTION: I am putting together a chart for employees explaining what the 10 General Prohibition mean to help them clear country alerts and actions that need to be taken I am having a hard time putting together the correct wording when I come to Gen Prohibition 8 Under the prohibition you cannot export or reexport […]
QUESTION: We have a product that is classified as UN3481- Lithium Ion Batteries Contained in Equipment and falls under Special Provision 188 (IMDG). We have not been able to get any forwarders or ocean carriers to accept this freight for LCL cargo out of China or Taiwan. Does anyone have an explanation as to why […]
QUESTION: Can anyone provide me a definitive answer as to what criteria the DOC uses to determine whether an encrypted part is Restricted or Unrestricted? A review of the regulations does not provide a straight forward answer to the question. What I am looking for is that “elevator” answer you can give your boss when […]
QUESTION: Is it a common practice among U.S. based companies to employ a non-U.S. employee say in MX or IN to handle U.S. imports/exports/FTA qualifications? ****************** Answers: Based on past experience, a two part equation works well, the first on is having locals (non-us) resources sorting through the compliance details for each country and the […]
QUESTION: When utilizing a 3rd Party Software Management system to screen business partners; Agents, Distributors, Toll Manufacturers as such could we have your feedback and suggestions on the criteria you may have used to determine who should be screened? ************* Answers: All customers, vendors, suppliers should be screened against restricted/prohibited party lists Outside 3rd party […]
QUESTION: We have learned that we may have two entities (gold smelters) deep in our supply chain that were blocked by OFAC as of this past April. Although not specifically named by OFAC, these two entities appear to be captured by the sanctions because they are >50% owned by a blocked entity. This information came […]
QUESTION: Our broker has been entering zero amounts for invoice lines with an extended amount under $1 in value. Although ACE is allowing these zero dollar entry summary lines, I’m not sure this is acceptable to CBP. Need some advice or guidance on this. Thanks. ========== Answers: First you need to understand that CBP rounds […]
