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, […]
QUESTION: We recently moved our in-house distribution to an outside 3rd Party warehouse. For our large export shipments we would create the SLI/SED and give to the freight forwarder to submit the EEI on our behalf. For routed shipments we would give the data fields required but not sign the SLI because our customers forwarder […]
QUESTION: I work for a U.S. manufacturer , and my question regards restricted party screening. When screening a company (whether a customer, vendor, service provider, etc.), do you screen just the company information or do you also screen contact names for individuals who work for the company? For instance, would you screen only ABC Company […]
QUESTION: Regarding the use of 9801.00.2500 for products not of US origin, does the exporter of the product need to be the importer upon its return as defective? The phrase in item (4) “by or for the account of the person who imported them into, and exported them from, the US” is what I am […]
QUESTION: My company sells under the Incoterm CIF (Cost, Insurance, & Freight). We provide insurance coverage as required. We understand that as the seller in the transaction, we are responsible for the insurance premium. Our question has two parts: 1) Is it the usual and customary practice for there to be a deductible on a […]
QUESTION: Our parent company is requiring us to complete a High Risk Profile questionnaire on all new Business Partners (who sell our product) and customers, as well as an updated questionnaire after 2 years. This is in addition to a RPLs screening at the time of being setup in our ERP system, as well as […]
QUESTION: Does anyone know if it is acceptable to show 2 currencies (USD and BRL) for different line items on the same commercial invoice? The Brazilian importer is asking for that and with all of the horror stories of delayed shipments I wasn’t sure if this would cause any delays or confusion upon import. We don’t […]
