QUESTION: Is there a list of countries affected by the OFAC 50% Rule? Right now I am only aware of Russia, Venezuela, & China *************** Answers: “This guidance responds to inquiries received by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) relating to the status of entities owned by individuals or entities […]
QUESTION: Is there a formatted letter that I can have the membership point me to? We are impacted by the OFAC sanctions surrounding the Russia personnel now appearing on the SDN, and the companies they own are equally sanctioned. I need to report our wind down efforts to OFAC and do not know how to […]
QUESTION: Our broker picked “not related” on the 7501 when it should have been “related.” We have been using them for several years, and I believe this was a clerical error. Is this a field we should file a PSC for? ========= Answers: Yes ========== Personally I would enter this file in my audit folder, […]
QUESTION: Does anyone know or is familiar with how an importer would request CBP to formally liquidated entries that are well 20yrs old and still open? ========== Answers: Are these entries subject to ADD/CVD? This is the only area where I believe entries could remain unliquidated for such an extended period of time. I would […]
QUESTION: Can anyone tell me what it means when BIS advises that that they will not issue a license with one of the end users indicated due the fact that they will go through what is called a “Pre-License Check” which could take months. This same end-user is listed on our current license and we […]
QUESTION: I have several customers asking for a copy of my 7501 and other import documents so they can verify the additional duty paid related to Section 301 imports from China. My documents show my inter-company pricing and we are not passing on the full amount of the duty increase. Obviously, I don’t want to […]
QUESTION: My company is looking to set up a potential customer located in Iraq. The item that we ship is EAR99. Besides the obvious (screening owner against denied party list) what else should we take into consideration? ========== Answers: Anti-boycott requests =========== That is the only trade concern, ensuring you are not dealing with a […]
QUESTION: I WOULD LIKE TO ASK IF THE MEMBERSHIP WILLING TO SHARE YOURS DO’s AND DON’Ts LIST TO PRESENT TO THE SALES AND MARKETING FOLKS. ========== Answers: 1) Don’t tell them they will go to jail. They will get the gist of it when you share #2. 2) Do share the publication “Don’t let this […]
QUESTION: I am wondering is there a list of keywords or training information that will help me to recognize boycott language in Sales Contracts? ================== ANSWERS: Linked is a list of boycott language from the published penalty cases that I compiled in 2015. http://www.icpainc.org/wp-content/uploads/2014/10/Anti-Boycott-Penalty-Language.docx ================= Here are a few of the words/phrases that we use […]
QUESTION: We are being asked by our business to allow an Iranian intern to work in one of U.S. Locations. We have been conflicting information from various outside counsel and wanted to see what is being done in practice or if there is anyone that can shed their experience. Facts: Iranian Student on a U.S. […]
QUESTION: We received an RWA from BIS for a license application based on a questionable (possibly military – although end user claims civilian) end use for products that are only AT1 – to be shipped to a weapons/ordnance mfr in Country Group D. Included in the BIS response was the standard phrase: “items otherwise eligible […]
QUESTION: Here is the proposed scenario: Company A is a large importer/exporter domiciled in the USA. Company A buys US-domiciled Company B, which is a smaller US company that also imports and exports. Company A purchases Company B as an asset purchase only. Is company A responsible for any Company B prior US Customs issues, […]
