Miscellaneous

MISCELLANEOUS

  • RPS LISTS

    QUESTION: Is there a top 5-10 list of MUST audit restricted party lists that I should screening against instead of coming through hundreds of questionable lists that provide an overwhelming amount of questionable feedback? We utilize third party RPS software but the issue we are finding is that when the software pulls from hundreds of […]

  • BROKER EMPLOYEE POA FORMAT

    QUESTION: When a customs brokerage grants POA to it’s employee (whether or not the employee is individually licensed as a customs broker) to conduct customs business under it’s corporate customs broker license, what format which should be used ? Would anyone have any templates to share ? ========== Answer: In our firm, we always empowered […]

  • 600 SERIES PROCEDURES

    QUESTION: Does anyone in the membership have a reference to explain the if there are difference for the IT system controls and procedures that an exporter has to have in place to handle 600 series ECCN’s versus non-600 series ECCN’s and EAR99 items that you would be willing to share?   We have items pending […]

  • RESOLVING RPL SCREENING HITS

    QUESTION: We are in the process of improving our ability to screen all transactions against OFAC and other restricted party lists.   We expect this improvement to result in an increase in potential “hits” from our screening.  We are working with our business groups to identify individuals to be assigned to investigate & clear these […]

  • TAA ORIGIN COMPLIANCE

    QUESTION: I have a confusing scenario (confusing for me).  A US company who does repair work for a big telephone seller, wants to send telephones (manufactured in China and are no longer available) to a company in Mississauga Canada, to be torn apart.    The parts will then be placed in kits (mechanical kits and […]

  • DECLARING CORRECT ORIGIN

    QUESTION: I have one question regarding the Certificate of origin document for stock coming from Thailand. The footwear company I work for has a bonded warehouse in Amsterdam. We have the so called “direct” shipments to one of our customers in Switzerland. I am saying “direct” because the shipments come to our warehouse, they are […]

  • LOGISTICS VS COMPLIANCE STAFFING

    QUESTION: I am looking to benchmark the distinction of Logistics vs. Compliance activities/tasks/responsibilities.   Current structure in the department is a total of 4 employees (1 Manager and 3 Team Members) in the corporate headquarters (i.e. centralized) which functions and is responsible for international freight and logistics (think daily export order processing, freight quotes, hazardous […]

  • AU TRANSFER PRICING

    QUESTION: I need help regarding transfer pricing and customs valuation.   We export the product from the U.S. to Australia. It is between the related party. In our intercompany commercial invoice, we declare the cost plus transfer pricing mark up, which is provided by the tax dept. At the end of each quarter, our finance […]

  • WCO CLASSIFICATION DOCUMENT

    QUESTION: Does anyone know what U.S. Customs office or other government agency would be able to provide a WCO classification document (a document explaining how a particular product is to be classified to the 6-digit level under the HTS)?  Any information about the WCO classification decision making process would also be helpful.  I note that […]

  • CBP BULLETIN MAY 30 2002

    QUESTION: Does anyone have a copy of the Customs Bulletin, Vol. 35, No. 22, dated May 30, 2001?  Customs Bulletins on CBP.gov. start Jan., 2002.  Specifically looking for “Notice of Revocation & Modification of Ruling Letters and Treatment Relating to the Classification of Laminated Flooring”, dated May 30, 2001, in the Customs Bulletin, Vol. 35, […]

  • EXTRATERRITORIALITY

    QUESTION: As we are all too familiar, the US rules, e.g., Export Administration Regulations among others, exert extraterritoriality for US technology.   The rules follow the technology everywhere it goes, forever.   As far as I can determine, EU countries, and Germany in particular, don’t seem to do that (e.g., for German technologies).   Their rules […]

  • DECLARING LEASED EQUIPMENT

    QUESTION: One of our business units leases ISO tanks to a foreign customer and the tanks are returned to the US within a few months.   Are we required to declare the leased ISO tanks on AES filings even though we are not selling the tanks, but leasing them? If we need to declare the […]