QUESTION: Scenario Company A (US) sells to Company B (US) Company A files EEI under its tax ID and exports products to Company C (MX), which happens to be an affiliate of Company B (US) Company A exports products to Company B’s affiliate in MX Question Is this non-compliant in accordance with U.S. Census Bureau […]
QUESTION: If you are shipping commodities through freight forwarder shipment systems and you process shipments throughout the day, how can you tell if you are following the “Rule of One” 15CFR 30.37A? ****************** Answers: The only way to be sure is to put in some checks and balances for any orders going out to the […]
QUESTION: My company has just made the move to expanding our Trade Compliance department Global. Previously we were only U.S., so I’m looking for resources and regulations surrounding import/export compliance in the rest-of-world markets, specifically EU and China. We are doing a total review of importer/exporter eligibility requirements, classification reviews, valuation rules in different Customs […]
QUESTION: My question is about Russian sectorial sanctions, SDN and SSL. Do 50% rule and Secondary Sanction apply to SSL entities? =================== ANSWER: Yes and see below that pertains to Directive 4 The provision, exportation, or reexportation, directly or indirectly, of goods, services (except for financial services), or technology in support of exploration or production […]
QUESTION: A Belgium chemical company importing in the EU is registered in REACH (as the only representative-OR of U.S. manufacturer) and currently takes title, imports, sells goods throughout Europe. Due to restructuring, a new UK company is being formed and will take title, import, store, sell and transport goods throughout Europe. The Belgium company will […]
QUESTION: Our European entity just received notification from the German Customs Agency about an audit. It will cover three years. The notification did not mention any particular area – classification, value, origin as a focus. The auditor requested read only access to our ERP system and wants access to the following documents and info: Last […]
QUESTION: We are hoping the membership can provide answers to the following questions regarding the current Korean Steel Quota: Have Korean suppliers each been given a portion of the total quota or does each supplier request the amount of quota they require for each export transaction? How does the Korean government decide the quantity of […]
QUESTION: What should we advise our broker to declare for the country of origin of a mixture of food items (example below). All I can find in the regulations is country of origin marking requirements and the proper way to declare sets on the 7501- nothing about mixed products. We have a trail mix product […]
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 […]
