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 […]
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 […]
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 […]
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 […]
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 […]
