QUESTION: I have a Purchase Order for engineering services with a UK company and have recently learned they have a dual national (UK and Iranian) working on this project. The US technology involved is EAR99. Do I have an EAR or OFAC violation? Or both? ===================== ANSWERS: If the UK citizenship was received subsequent to […]
QUESTION: Ok, if things can’t get more confusing, here we go with Sec 301. Does anyone in the membership know if this will also affect LEDs that are sent to a contract manufacturer in Mexico that uses a Maquiladora? HTS code is 8541.40.2000 We send LEDs from out facility in China to Mexico where they […]
QUESTION: One of the customers of one of our foreign subsidiaries was a match on a IMF list of ineligible vendors. Does this preclude our foreign entity from doing business with this customer or does it just mean that the IMF will not do business with them and others can choose to do business with […]
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: They generally announce that registration is open via CSMS about 4-6 weeks prior to the date of the Symposium.
QUESTION: We import lighting fixtures from out contract manufacturers in China. They are shipped to our US distribution warehouse, we pay duties on all shipments. We then sell to a customer in Costa Rica. These products would fall under the China-Costa Rica Free trade agreement. Our customer in Costa Rica is asking for the certificate […]
QUESTION: Does the membership have any insight as to how the recently proposed 25% tariff hike on some Chinese-made goods may affect Maquila operations? At first glance, it does not appear this would have an impact on goods that are Immediately Exported to MX. Nor does it appear that it would have an impact on […]
QUESTION: We make in the U.S. an item that requires an export license to China but not to Japan. We sell the item to a Japanese end-user, who installs the item in their equipment. They receive an order from a customer in China, so they export their equipment to China, satisfying applicable Japanese export license […]
QUESTION: When conducting an on-site visit at an US facility by Foreign Nationals under the STA Exemption, is an AES filing required? If yes, what value should be used? ========== Answers: Please see 15 CFR Part 30.2(d)(3) and 758.1 (b) which indicate intangible transfers are excluded from filing. ========== I assume you’re talking about deemed […]
QUESTION: “Can any embargoed country National work for a US Company subsidiary overseas?The subsidiary is a US wholly owned/and or joint venture 51/49%”***********Answers:The answer would be no. Due to financial remuneration to the worker overseas from US subsidiary, this is covered under OFAC sanctions for the US subsidiary.**********They can, but if your technology or software […]
QUESTION: Can products be in compliance with the Pennsylvania Steel Products Procurement Act if the steel is sourced from the USA but the final product is manufactured in another country? I don’t believe so because substantial transformation to the finished product will occur in another country so the country of origin will change but would […]
QUESTION: I work for a medical device company and someone is trying to send a dead mouse across to Canada for research and testing. Does anyone know what types of certificates you need or licensing to send something like this? ********** Answers: I just have to say – I LOVE THIS QUESTION! You made […]
QUESTION: We are thinking of moving our Free Trade Agreement process & CTPAT supplier survey solicitation to our internal team in Mexico. They would handle customer requests from both customers in Mexico (currently already handling this) as well as customer requests from US customers. I know this has been done by other companies, but are […]
