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, […]
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 […]
