QUESTION: The company is a technology company dealing with controlled finished goods. ECCN is 5A002. They would like to be able to hand carry their product into various countries in ASIA to carry out demonstration and training and thereafter bring it back to their ASIA HQ which is in Singapore. How can one prepare and declare […]
QUESTION: I am looking for suggestions or best practice for obtaining written authorization from the FPPI for compliance to 15 CFR 758.3(b) where the foreign principal party in interest assumes responsibility for compliance to US law for a routed shipment. Do any members have a form letter or a form that you can share? […]
QUESTION: If you are approached by your company’s salesman and he tells you that his customer whom he has known for a long time would not furnish or submit an end use certificate, what would your appropriate response be? ========== Answers: How do we know that the customer will not use the product for illegal […]
QUESTION: An Export Enforcement Officer from Dept. of Commerce unexpectedly showed up at our facility asking questions about an order that shipped the previous week. Apparently they are investigating one of our Customers and their customers for possible diversion risk, and wanted more details. All documentation was in order, and we were able to prove […]
QUESTION: If a company currently does not perform any type of customs compliance operations or oversight, but is looking to hire someone for that position and the person starts to uncover various issues (HTS, Value, Assists, etc.) at what point do you start reporting the issues to CBP? Do you look back 5 years and […]
QUESTION: I was wondering if the membership could share where Trade Compliance falls within their corporate organizational structure. My global pharmaceutical company has recently proposed a restructure where the Trade Compliance Manager, who used to report to directly to the Director of Supply Chain (North & South America), will now be reporting to the […]
QUESTION: Does anyone know if other countries accept prior disclosures like the United States? Can anyone recommend where to find out how to make corrections and disclosures in each country? ========== Answers: Disclosures are possible in the UK. ========== Yes, most countries follow similar disclosure rules like the US, but not with their own unique […]
QUESTION: I work for a company (Company A) which exports high-end customized software as well as services. Currently, a good amount of Company A’s exports are done through Electronic Download or provision of said services. I go by 15 C.F.R. 30.55(o) which states intangible exports of software and technology, such as downloaded software and technical […]
QUESTION: Would appreciate the opinions from the membership about Personal Liability Insurance for the Empowered Officials in our Trade Compliance department. Should each EO be covered with an insurance policy? Our trade compliance program is still in the beginning stages. As we dig deeper we suspect some product ‘ is being supplied for […]
QUESTION: Looking for suggestions on best practices for housing and updating contact information for businesses and the people within those businesses who are responsible for trade activities. Looking to include information such as experience, designations, training attended, years in the role, etc. Looking for something that would be relatively easy to maintain, allow trade […]
QUESTION: In the situation below (3 line items), we would need to file the Foreign and Domestic parts separately even though they have the same HTS, correct? When filing separately, do we even need to file the Foreign parts since the amount is less than $2,500? *************** Answers: You would only need to file […]
QUESTION: We are looking for guidance from the membership regarding invoice requirements for import clearance. We have a customer request to purchase a box of 500 items (reflectors). They wish to buy this item in bulk; referring to it as a kit. It clearly doesn’t meet the Customs definition of a kit. We buy these […]
