QUESTION: Can someone within the membership please confirm that as long as a US Person (i.e. foreign subsidiary of a US company) that produces and ships to other foreign locations is NOT subject to US Anti-boycott regulations as long as they ship items without any US content (i.e. engineering, know-how or parts)? I understand this […]
QUESTION: My office in the UK has asked me for an updated Russian sanctions/screening checklist, explicitly incorporating all the directives under all relevant executive orders, including EXECUTIVE ORDER 13662. Does anyone have a good , current one? Don’t want to re-invent the wheel and all that…… ================= ANSWERS: You can get the list from this […]
QUESTION: Does anyone in the membership know when registration will open up for the trade symposium in August 2018? All I have found on CBP’s website was save the date info. Thanks! ========== Answer: Registration opens Tuesday May 29 at 12pm
QUESTION: If U. S. Company sells goods in CCL list, that is not EAR99, to another U.S. company, the buyer exports goods to Taiwan,where the goods does not meet any license exception, which party is responsible for getting the license? ========== Answers: Under the EAR, the party that is responsible for engaging in the export […]
QUESTION: I am evaluating my new employer’s sanctions and end user check policies. I was told “so we check immediate parent company (but not ultimate parent company), subsidiaries (but only one level down), sister companies (under the same immediate parent company) and noted directors on the credit checks for the entity. “ Is this sufficient […]
QUESTION: Do lawyers have to undergo annual or some other time-bound re-certification? I know there are certain CLE requirements, What if a lawyer does not reach the annual CLE requirement? Do they get suspended/disbarred? Can they get their license back? If so, how and how long does it take to get :”reinstated”? Is there any […]
QUESTION: Several of our suppliers are located in Mexico. Over the past few weeks, there seems to have been an increase in custom inspections at the Laredo border crossing. This is leading to delays in our supply chain. Are others experiencing the same thing and does anyone have any idea what is driving the increase […]
QUESTION: Would like to know as the recipient to a Used Product returned for repair at my facility, do I need to challenge the declared value of the used product? Does the customs check on these values? I would think the easiest justification is using Nett Book Value (NBV) If the value seems too lowly […]
QUESTION: I am seeking guidance on how to prepare my company for any increased scrutiny under Customs’ Forced Labor regulations. We import a great deal from China, and while we have a robust product safety group who focuses on this area, we want to focus on and tackle this issue from a Trade Compliance angle. […]
QUESTION: Is there a de minimis of U.S. content for sanctions / embargoes on Cuba, Iran, North Korea, and Syria? I.E., a product can have up to 10% U.S. content and still be considered a foreign product not subject to the sanctions, as long as no U.S. persons are involved. If so, where can I […]
QUESTION: Can someone within the membership please confirm that as long as a US Person (i.e. foreign subsidiary of a US company) that produces and ships to other foreign locations is NOT subject to US Anti-boycott regulations as long as they ship items without any US content (i.e. engineering, know-how or parts)? I understand this […]
QUESTION: Our agent overseas has advised they cannot enter a foreign based party as the consignee when submitting their AMS Filing? The foreign based company in question has a U.S. Customs bond and a Customs assigned number. Does anyone know if this is acceptable or how to submit AMS when your consignee is foreign based? […]
