Strategies for Surviving Government Enforcement Actions. Export Controls By Paulette Kolba March 2, 2015
|
|
- Eric Campbell
- 5 years ago
- Views:
Transcription
1 Strategies for Surviving Government Enforcement Actions ì Export Controls By Paulette Kolba
2 Export Controls ì Census (Commerce Department) ì Customs and Border Protection (CBP) (DHS) ì Bureau of Industry and Security (BIS) (Commerce) ì Directorate of Defense Trade Controls (DDTC) (State) ì Office of Foreign Assets Control (OFAC) (Treasury)
3 Prevention ì Don t get into trouble in the first place! ì Documented Compliance Program Written Policies and Procedures Training Systems and Process Controls Monitoring and Auditing ì Red Flag Awareness ì Restricted Party Screening
4 Export Enforcement ì CBP at the border ì Individual export control agencies after export ì BIS: Office of Export Enforcement (OEE) ì State Department: Homeland Security Investigations (HSI) (ICE) ì Investigations are coordinated across several agencies through the Export Enforcement Coordination Center (E2C2)
5 High Probability / Low Impact ì CBP Enforcement of the Foreign Trade Regulations AES Errors ì CBP Focus: Transportation Data Elements: Port of Export Date of Export Mode of Transportation (exiting the U.S.) Carrier (transporting cargo out of the U.S.) ì $10,000 Penalties How much file profit does that eat up?
6 Low Probability / High Impact ì Diversion to Embargoed Countries ì Shipments to Restricted Parties ì Anti- Boycott Violations ì Knowing that a violation has or is about to occur ì IEEPA* Civil Penalties - up to $250,000 ì Challenge Maintaining awareness in our operations * International Emergency Economic Powers Act
7 CBP Enforcement of the Census Regulations ì CBP Imposition and Mitigation Guidelines ì CBP issues penalty notice (can go back 3 years) ì Research and petition for mitigation ì Determine if you have a systemic issue ì Take meaningful corrective measures ì Higher penalties for repeat offenders
8 Exams, Detentions and Seizures ì 19 USC 1595a(d) merchandise exported or sent from the U.S., or a6empted to be exported contrary to law, and any property used to facilitate expor=ng, purchase, receipt, transporta=on etc. prior to exporta=on, shall be seized and forfeited to the United States. ì 22 USC 401 (AECA) whenever an a6empt it made to export any arms or muni=ons of war or other ar=cles in viola=on of law, or whenever there is probable cause to believe [such ar=cles] are intended to be exported in viola=on of law, the Secretary of Treasury [CBP and ICE] may seize and detain such ar=cles.
9 Exams, Detentions and Seizures ì Not for AES errors BUT remember - AES data feeds the CBP targeting system ì Suspected license issues (BIS, DDTC, OFAC, etc.) ì Prohibited merchandise (drug paraphernalia / unapproved drugs) ì Goods intended for an embargoed destination or restricted party ì Need probable cause
10 Exams, Detentions and Seizures ì Coordinated through the Exodus Command Center ì CBP, ICE, BIS (licensing) ì Can take awhile to make the determination ì Cost, loss sales ì No statutory timeline on how long CBP can detain cargo
11 Exams, Detentions and Seizures ì Is the forwarder responsible? Were you properly authorized to handle the transaction? Did you obtain all of the information in writing? Did you transmit the information accurately? Did you have reason to question it? ì Refer CBP to the U.S. Principal Party in Interest (USPPI) for further information / substantiation of their license determination
12 Enforcement Actions ì Charging Letters, Subpoenas, Warrants ì Do you have an internal process? ì Do you have an escalation policy? ì Should you contact Legal Counsel? ì Internal Reviews
13 Subpoenas ì Requests typically ask for: All documents All communications For a specific timeline or for specific transactions Might include an search ì Be prepared to invest time and money Internal review and analysis of all documents and communications Can you identify / locate the communications? External (legal) review and analysis
14 Do you need legal advice? ì Determine if you need legal counsel advice ì Example 1: Repeat Requests Same item ICE may share reasons with you May not be a need for outside legal counsel ì Example 2: Requests involving diversion to an embargoed country (such as Iran) Better to get guidance and outside review
15 Subpoenas ì Ask if you are the target ì Seek legal advice (internally first) and determine if outside counsel will be needed ì Keep communications and review within a limited circle of individuals ì Limit the scope of the request, if possible ì Ask for more time
16 Subpoenas ì Gather documents / communications ì Conduct an internal review and investigation ì Determine your culpability and scope of the issue ì Respond to the request ì Be prepared for further requests on the same subject and decide if you ll want subpoenas for subsequent requests
17 Enforcement Actions Destination freight forwarder diversion Ties to a U.S. company Ties to previous violations of a related company Penalty: $125,000 Negative publicity BIS Press Release
18 Anti- Boycott Charging Letter Charging letter Review of files Internal investigation to determine scope Negotiate settlement Corrective measures: controls, monitoring, training FOIA - Anti- Boycott Alleged Violations
19 Shipping to Party on Entity List U.S. freight forwarder shipped to a party on listed on the Entity List without a license 4 violations Charged in 2014 for violations that occurred in 2009 Settlement: $90,000
20 Excerpt from Charging Letter
21 Negative Publicity Freedom of Information Act FOIA foia/index- of- documents Public informa=on Nega=ve publicity Newsle6ers / Blogs Being the example in government and trade presenta=ons
22 Voluntary Self Disclosures ì What if you discover a violation? Do you disclose or not? ì Pros and Cons Mitigating Factor most of the time Could still result in fines ì Can t do it after you ve been contacted
23 Best Practices ì Policies for handling any USG request ì Policies for handling visits from enforcement (OEE, ICE) especially if they have a warrant ì Internal escalation policy ì Work with attorneys who specialize in the government agency / trade issue you are dealing with
24 BIS Best Practices ì BIS Best Practices for Prevention of Transshipment Diversion ì ì Best Practice No. 1 Companies should pay heightened attention to the Red Flag Indicators on the BIS Website and communicate any red flags to all divisions, branches, etc., particularly when an exporter denies a buyer s order or a freight forwarder declines to provide export services for dual- use items. Best Practice No. 2 - Exporters/Re- exporters should seek to utilize only those Trade Facilitators/Freight Forwarders that administer sound export management and compliance programs which include best practices for transshipment.
25 BIS Best Practices ì ì Best Practice No. 3 - Companies should Know their foreign customers by obtaining detailed information on the bona fides (credentials) of their customer to measure the risk of diversion. Specifically, companies should obtain information about their customers that enables them to protect dual- use items from diversion, especially when the foreign customer is a broker, trading company or distribution center. Best Practice No. 4 - Companies should avoid routed export transactions when exporting and facilitating the movement of dual- use items unless a long standing and trustworthy relationship has been built among the exporter, the foreign principal party in interest (FPPI), and the FPPI s U.S. agent.
26 BIS Best Practices ì Best Practice No. 5 When the Destination Control Statement (DCS) is required, the Exporter should provide the appropriate Export Control Classification Number (ECCN) and the final destination where the item(s) are intended to be used, for each export to the end- user and, where relevant, to the ultimate consignee. For exports that do not require the DCS, other classification information (EAR99) and the final destination should be communicated on bills of lading, air waybills, buyer/seller contracts and other commercial documentation. For re- exports of controlled and uncontrolled items, the same classification and destination specific information should be communicated on export documentation as well.
27 BIS Best Practices ì ì Best Practice No. 6 - An Exporter/Re- exporter should provide the ECCN or the EAR99 classification to freight forwarders, and should report in AES the ECCN or the EAR99 classifications for all export transactions, including No License Required designation certifying that no license is required. Best Practice No. 7 - Companies should use information technology to the maximum extent feasible to augment "know your customer" and other due- diligence measures in combating the threats of diversion and increase confidence that shipments will reach authorized end- users for authorized end- uses.
28 Resources BIS Best Practices for Preventing Transshipment Diversion BIS "Know Your Customer" Guidance BIS Red Flag Indicators CBP Imposition and Mitigation Penalty Guidelines for Failure to Comply with the Foreign Trade Regulations Consolidated Screening List
29 Contact Information Questions??
Effective Communications. Discussion Effective communications between exporters and freight forwarders
Effective Communications Discussion Effective communications between exporters and freight forwarders Today s Session Pre-planning the export transaction Regulatory controls Communications between shippers
More informationU.S. Customs and Border Protection (CBP) Outbound Issues Webinar
Department of Homeland Security U.S. Customs and Border Protection (CBP) Outbound Issues Webinar Office of Trade Relations Point of Contact: Steven Graham, International Trade Liaison Office of Field Operations
More informationEXPORT ESSENTIALS. DHL Express The International Specialists. Phillip Poland Boston, 2015
EXPORT ESSENTIALS DHL Express The International Specialists Phillip Poland Boston, 2015 Agenda 1 Customs Trinity Classification, Valuation, Rules of Origin 2 Documents Needed Information, Document 3 Commercial
More informationThe Riddle of the Exporter
The Riddle of the Exporter Exporting Regulatory Compliance Topics We Will Cover: Legal Right to Export USPPI Government Agencies That Control Exports The EAR-Export Administration Regulations Types of
More informationBIS Best Practices for Industry to Guard Against Unlawful Diversion Through Transshipment Trade
BIS Best Practices for Industry to Guard Against Unlawful Diversion Through Transshipment Trade U.S. Department of Commerce Bureau of Industry and Security Office of Technology Evaluation Where Industry
More informationCompleting the Shipper s Letter of Instructions (SLI)
Completing the Shipper s Letter of Instructions (SLI) Rev: 08/17 1. U.S. PRINCIPAL PARTY IN INTEREST (USPPI) Provide the name and address of the U.S. exporter (U.S. principal party in interest). The USPPI
More informationYou ve Got your License now what? Or Where Export Meets Customs. Marc Binder International Trade Compliance Strategies, LLC (ITC Strategies)
You ve Got your License now what? Or Where Export Meets Customs Marc Binder International Trade Compliance Strategies, LLC (ITC Strategies) Society for International Affairs YOU VE GOT YOUR LICENSE NOW
More informationForeign Trade Regulations Mandatory Automated Export System. Omari Wooden Trade Ombudsman Foreign Trade Division U.S. Census Bureau.
Foreign Trade Regulations Mandatory Automated Export System Omari Wooden Trade Ombudsman Foreign Trade Division U.S. Census Bureau 1 Today s Topics Legal/Filing Requirements U.S. Principal Party In Interest
More informationExport Management and Compliance Policy
I. PURPOSE Export Management and Compliance Policy The purpose of this document is to define the Export Management and Compliance Policy for AZZ Inc. ( AZZ ) and its directors, officers, applicable employees,
More informationCBP Identifies Most Common Reasons for Outbound Detentions and Seizures
International Alert CBP Identifies Most Common Reasons for Outbound Detentions and Seizures 08.10.10 On June 10, 2010, U.S. Customs and Border Protection ("CBP") held a webinar focusing on CBP's frontline
More informationU.S. Shipper s Letter of Instruction (SLI) Completion Guide U.S. PRINCIPAL PARTY IN INTEREST (USPPI) ULTIMATE CONSIGNEE
U.S. Shipper s Letter of Instruction (SLI) Completion Guide This document is intended only as a general reference for completion of Expeditors Shipper s Letter of Instruction (SLI) form, which can be used
More informationSanctions Compliance & Evaluation. April 19, 2013
Best Practices to Ensure Compliance Leslie Devereaux Sanctions Compliance & Evaluation April 19, 2013 Overview OFAC Compliance Programs When do Violations Occur? Penalties Resources on Treasury s Website
More informationACE Reports for Export
ACE Reports for Export Value and Process Paulette Kolba DSV Air and Sea, Inc. Acronyms ACE Automated Commercial Environment AES Automated Export System CBP Customs and Border Protection ECCN Export Control
More informationInstructions for Completing a Shipper s Letter of Instruction
These instructions refer to the corresponding field numbers on an OCEANAIR. This information is required in order for OCEANAIR to properly process your shipment for export. This form is used to spell out
More informationPresentation to the Long Island Import Export Association Export Compliance Due Diligence, Regulations & Responsibilities
Presentation to the Long Island Import Export Association DB Schenker Risk, Insurance & Trade Advisory Solutions Ivelisse James New York 2017-11-08 Agenda 1 2 3 4 5 6 7 8 9 10 Introductions - Regulations
More informationCORRECT WAY TO FILL OUT THE SHIPPER'S EXPORT DECLARATIONS FOR IN-TRANSIT GOODS, FORM (Follow carefully to avoid delay at shipping point.
CORRECT WAY TO FILL OUT THE SHIPPER'S EXPORT DECLARATIONS FOR IN-TRANSIT GOODS, FORM 7513 (Follow carefully to avoid delay at shipping point.) Note: On September 28, 1998 the Office of Management and Budget
More informationExport Management and Compliance Program Guide
Export Management and Compliance Program Guide The UAMS Export Management and Compliance Program Guide attempts to provide relevant information about export controls and how they affect the academic and
More informationTable of AES Data Elements *
Table of AES Data Elements * *source: CFR Title 15, Part 30.6 Foreign Trade Regulations Data Element: (NOTE: Some data elements have been abbreviated, eliminating redundant or rarely used information.
More informationEXPORTER ACTIVITY DATA ANALYSIS
EXPORTER ACTIVITY DATA ANALYSIS Accessing and analyzing the U.S. government records of all company export transactions is a very useful way of identifying compliance issues. While companies may generally
More informationDEPARTMENT OF HOMELAND SECURITY U.S. CUSTOMS AND BORDER PROTECTION. CBP Dec
DEPARTMENT OF HOMELAND SECURITY U.S. CUSTOMS AND BORDER PROTECTION CBP Dec. 09 26 Guidelines for the Assessment and Cancellation of Claims for Liquidated Damages for Failure to Comply with the Vessel Stow
More informationFREQUENTLY ASKED QUESTIONS FILING OF ELECTRONIC EXPORT INFORMATION VIA THE AUTOMATED EXPORT SYSTEM
FREQUENTLY ASKED QUESTIONS FILING OF ELECTRONIC EXPORT INFORMATION VIA THE AUTOMATED EXPORT SYSTEM 1. Enforcement of the FTR..3 2. Time Frame For Providing Internal Transaction Number To The Exporting
More informationCLASSIFICATION COURSES
CLA 101: Classification I (2 CCS) CLASSIFICATION COURSES Learn basic HTSUS terminology, classification concepts and methods. A perfect introduction to this important import concept. Classification Tools
More informationCrossing the Border. Mexico Trade & Logistics. Empower Your Supply Chain Seminar
Crossing the Border U.S. Export Documentation Requirements Commercial Invoice Inland Bill of Lading/Airway Bill Packing List Certificate(s) of Origin Electronic Export Information (EEI) Commercial Invoice
More informationTRADE COMPLIANCE PROGRAM MARCH 7, 2018 CHANDLER S. LEONARD DIRECTORATE OF DEFENSE TRADE CONTROLS JEREMY K. HUFFMAN HUFFMAN RILEY PLLC
IMPLEMENTING AN EFFECTIVE TRADE COMPLIANCE PROGRAM MARCH 7, 2018 CHANDLER S. LEONARD DIRECTORATE OF DEFENSE TRADE CONTROLS BRYCE BEWLEY BUREAU OF INDUSTRY AND SECURITY JEREMY K. HUFFMAN HUFFMAN RILEY PLLC
More informationPresenting a live 90 minute webinar with interactive Q&A. Td Today s faculty features:
Presenting a live 90 minute webinar with interactive Q&A ITAR and EAR Compliance Review and Investigations i Conducting Internal Audits and Evaluating Whether to Disclose Potential Violations to Mitigate
More informationDFA & SCTC 2013 Annual Conference. Joe. A. Cortez U.S. Census Bureau Foreign Trade Division
DFA & SCTC 2013 Annual Conference Joe. A. Cortez U.S. Census Bureau Foreign Trade Division Today s Topics Background/Primary Responsibilities of the Foreign Trade Division (FTD) Electronic Export Information
More informationExport Compliance and Controls
Export Compliance and Controls Massachusetts Export Center Evening Export School May 15, 2002 Barry Hurewitz Hale and Dorr LLP Washington, DC Overview What is an export? Export Control Authorities Treasury
More informationEXPORT CONTROLS EXPORT CONTROL COMPLIANCE AND RISK: FOR BUSINESS OFFICES
EXPORT CONTROLS EXPORT CONTROL COMPLIANCE AND RISK: FOR BUSINESS OFFICES U. S. laws that regulate the distribution of items, technology, services, and information, including items and technology used in
More informationChapter 2 The Basic Entry Process - Entry and Entry Summary CFR , 149 Flash Drive: Ch 2 Entry and Entry Summary. I. Entry 142.
Chapter 2 The Basic Entry Process - Entry and Entry Summary CFR 142.0-142.19, 149 Flash Drive: Ch 2 Entry and Entry Summary When goods and merchandise arrive in the Customs Territory of the United States,
More informationChapter 7 19 CFR Part 18 Transportation in Bond. Table of Contents
Chapter 7 19 CFR Part 18 Transportation in Bond Table of Contents Overview...7-2 General Provisions...7-4 Immediate Transportation Without Appraisement...7-8 Merchandise in Transit to Foreign Countries...7-10
More informationTrans-Border Global Freight Systems, Inc.
Trans-Border Global Freight Systems, Inc. EXPERIENCE THE DIFFERENCE * IMPORT * EXPORT * DOMESTIC * VALUE ADDED SERVICES Commitment, Creativity, Reliability, Imagination, Excellence 2 MISSION STATEMENT
More informationG LO S S A RY O F T E R M S
c r o s s - b o r d e r G LO S S A RY O F T E R M S ACRONYMS CSXT Intermodal provides shippers valuable tools to better understand and navigate cross-border shipping. For more information on key terms,
More informationExport Management Compliance Program. Copyright 2014 Mike Allocca. All rights reserved.
Export Management Compliance Program Exporter Responsibilities It is the exporter s responsibility to be aware of and comply to, all existing and future regulations of any and all U.S. government agencies
More informationTOP 10 EXPORT COMPLIANCE MUST KNOWS
TOP 10 EXPORT COMPLIANCE MUST KNOWS Wisconsin International Trade Conference May 10, 2016 Ulice Payne President, Addison-Clifton Nathan Eilers Director, Global Trade Compliance, Rockwell Automation US
More informationCase 1:11-cr JEB Document 1-1 Filed 04/01/11 Page 1 of 9
Case 1:11-cr-00119-JEB Document 1-1 Filed 04/01/11 Page 1 of 9 AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT JENG SHIH also known as JAY SHIH DOB: x/xx/xxxx I, Ashley E. Schrank, being first duly sworn, depose
More informationSelf defense. How exporters should manage relationships with third parties to minimize liability risks
Self defense How exporters should manage relationships with third parties to minimize liability risks Exporters can run afoul of export control rules even if they are not directly responsible for violations
More informationOFFICE OF EXPORT CONTROL
THE UNIVERSITY OF NEW MEXICO MAIN CAMPUS OFFICE OF EXPORT CONTROL GUIDELINES FOR PURCHASING, INVENTORY CONTROL, AND UNIVERSITY SERVICES (SURPLUS PROPERTY) ADELICIA GUNN PROGRAM SPECIALIST INTRODUCTION
More informationA Smarter Way to Work Drones and Export Controls
Drones and Export Controls Brent Connor Thompson Hine LLP Washington, D.C. Brent.Connor@ThompsonHine.com 202.263.4188 April 20, 2017 Introduction Enforcement Agencies Export Controls Pertaining to Drones
More informationCUSTOMS PROFESSIONAL S TOOLKIT. Export. Improve your compliance and grow your export business.
CUSTOMS PROFESSIONAL S TOOLKIT Export Compliance Improve your compliance and grow your export business. Customs professional s toolkit Export Compliance Having export capabilities gives you the advantage
More informationImporter Security Filing Fax paperwork to or as a TIFF or PDF attachment to
10 + 2 Importer Security Filing Fax paperwork to 781-286-3095 or e-mail as a TIFF or PDF attachment to 10+2@OCEANAIR.NET INSTRUCTIONS: Fax or e-mail this FULLY COMPLETED coversheet and / or supporting
More informationShipper s Letter of Instruction (SLI) Reference Guide
(SLI) Rev: 11/08/10 Summary: International shipments valued at $2,500 or more, require US customs documentation via the AES online system. InterLogic, Inc can complete the required documentation on the
More informationT Compliance. rade Handbook
T Compliance rade Handbook About the Firm Thompson Coburn LLP s International Commerce attorneys counsel clients in the legal aspects of shipping goods, services and technologies across international borders.
More informationCHAPTER 13 DISTRIBUTION STRATEGIES: PHYSICAL DISTRIBUTION AND DOCUMENTATION
CHAPTER 13 DISTRIBUTION STRATEGIES: PHYSICAL DISTRIBUTION AND DOCUMENTATION MULTIPLE CHOICE 1. Air transportation may not lower this cost. a) transportation (X) b) packing c) inventory 2. This transportation
More informationAudit Module: Self-Assessment Tool
U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY & SECURITY OFFICE OF EXPORTER SERVICES EXPORT MANAGEMENT & COMPLIANCE DIVISION www.bis.doc.gov EXPORT MANAGEMENT & COMPLIANCE PROGRAM Audit Module: Self-Assessment
More informationExport Documentation
Export Documentation Presented by BDG International, Inc. Presenter: Bengt Reed Anderson, ces President 840 Tollgate Road Elgin, IL 60123 Tel: 847-760-0000 Cell: 630-776-1872 email: banderson@bdginternational.com
More informationAbout the New York State Science & Technology Law Center:
EXPORT GUIDEBOOK About the Export Control Guidebook: This guidebook was compiled by the New York State Science & Technology Law Center to assist individuals considering the export of their technology.
More informationBlue Lantern. Dr. Judd Stitziel Chief, Regional Affairs and Analysis Office of Defense Trade Controls Policy
Blue Lantern End-Use Monitoring Program Dr. Judd Stitziel Chief, Regional Affairs and Analysis Office of Defense Trade Controls Policy Bureau of Political-Military Affairs Mission To help ensure the security
More informationINTERNATIONAL TRADE COMPLIANCE PROGRAM at GE
INTERNATIONAL TRADE COMPLIANCE PROGRAM at GE Yi Jiang, Trade Compliance Manager, APAC General Electric Company. 26 th ASIAN EXPORT CONTROL SEMINAR, Feb 26-28, 2019, Tokyo, Japan The organization structure
More informationExports and other party audits
Registration Management Committee Exports and other party audits A presentation at the 2012 AAQG RMC Auditor Workshop July 19-20, 2012 By Don Buehler, President DISCLAIMER The information contained herein
More informationExporting 101* The Legal Implications of Going Global.
Exporting 101* The Legal Implications of Going Global. by Florian Hauswiesner, Esq. FCEDA Exporting Workshop February 26, 2008 HAUSWIESNER KING LLP Introduction: The Economic Landscape for Exports (2006)
More informationDEPARTMENT OF HOMELAND SECURITY. U.S. Customs and Border Protection. 19 CFR Parts 4, 10, 18, 113, 122, 123, 141, 191, and 192. [CBP Dec.
This document is scheduled to be published in the Federal Register on 07/13/2017 and available online at https://federalregister.gov/d/2017-14549, and on FDsys.gov 9111-14 DEPARTMENT OF HOMELAND SECURITY
More informationOT:RR:RD:BS H CMS DEPARTMENT OF HOMELAND SECURITY. U.S. Customs and Border Protection
This document is scheduled to be published in the Federal Register on 08/14/2017 and available online at https://federalregister.gov/d/2017-17080, and on FDsys.gov 9111-14 OT:RR:RD:BS H275910 CMS DEPARTMENT
More informationDEPARTMENT OF HOMELAND SECURITY. U.S. Customs and Border Protection [ ] Entry/Immediate Delivery Application and ACE Cargo Release
This document is scheduled to be published in the Federal Register on 01/26/2015 and available online at http://federalregister.gov/a/2015-01343, and on FDsys.gov [9111-14] DEPARTMENT OF HOMELAND SECURITY
More informationIMPORTING: COMMERCIAL INVOICES. Importing into the United States. The Import Commercial Invoice COMMERCIAL INVOICE
IMPORTING: COMMERCIAL INVOICES This guidance is provided by the U.S. Customs and Border Patrol from A Guide for Commercial Importers. The CBP publishes a wealth of information to assist the import community
More informationNAVIGATING THE EXPORT PELLET MARKET GENERAL SESSION III JULY 29, 2014 ADAM MOOK LOGISTICS PLUS, INC.
NAVIGATING THE EXPORT PELLET MARKET PRESENTED BY: GENERAL SESSION III JULY 29, 2014 ADAM MOOK LOGISTICS PLUS, INC. AGENDA Considerations Before You Export Incoterms 2010 Common Export Documents U.S. Government
More informationImporting to the U.S.: Key requirements you need to be aware of
Importing to the U.S.: Key requirements you need to be aware of Eight areas of the importing process you should familiarize yourself with before you ship your goods to the U.S. If you re new to international
More informationMaterial Transfer Agreements Export Controls
Material Transfer Agreements Export Controls Sean Hayes, J.D., Ph.D. Research Advisor June 13, 2017 Material Transfer Agreements Establishes rights and obligations of parties when research material is
More informationBills of Lading 101. March 27, 2017
Bills of Lading 101 March 27, 2017 Bills of Lading - Overview What is a Bill of Lading? The function of a Bill of Lading Lifecycle of a bill of lading Types of bills of lading Bills of lading and the Bank
More informationWorld Trade Consultant, Inc.
Attn: Valued Clients This letter is to inform you, effective January 26, 2009, U.S. Customs and Border protection (CBP) will implement a new import security requirement referred to as the Import Security
More informationDear Importer, BONDING: December Client Alert: New US Customs Compliance regulations for 2009
December 2008 Client Alert: New US Customs compliance regulations for 2009 Client Alert: New US Customs Compliance regulations for 2009 ISF (Importer Security Filing) or 10+2 Department of Homeland Security
More informationProtecting the Food Supply October 2003
http://www.cfsan.fda.gov/~dms/fsbtact.html Protecting the Food Supply October 2003 FDA Actions on New Bioterrorism Legislation Fact Sheet on FDA'S New Food Bioterrorism Regulation: Interim Final Rule -
More informationCORRECT WAY TO COMPLETE THE SHIPPER S EXPORT DECLARATION FORM 7525-V
CORRECT WAY TO COMPLETE THE SHIPPER S EXPORT DECLARATION FORM 7525-V Title 15 Code of Federal Regulations, Part 30 (www.census.gov/foreign-trade) U.S. Department of Commerce Donald L. Evans, Secretary
More informationFREQUENTLY ASKED QUESTIONS Instruments of International Traffic Imported into the United States with Residue February 3, 2012
1. When will CBP begin enforcing HQ Ruling H026715?...2 2. What is the definition of an Instrument of International Traffic?...3 3. How is an IIT, arriving from a foreign country with residue, manifested
More informationX-Rite and Pantone Anti-Corruption and Compliance Training for Third Parties
X-Rite and Pantone Anti-Corruption and Compliance Training for Third Parties English Version 2 1 X-RITE AND PANTONE Anti-Corruption and Compliance Training for Third Parties Distributors, Resellers, &
More informationTOSHIBA AMERICA BUSINESS SOLUTIONS, INC. EXPORT CONTROL PROGRAM
TOSHIBA AMERICA BUSINESS SOLUTIONS, INC. EXPORT CONTROL PROGRAM Version 4.2 October 23, 2014 Process Policy 1605.001.000.000, Page 1 I. TABLE OF CONTENTS Page I. Table of Contents & Revision History 1
More informationWorld Shipping Council. Bureau of the Census
Comments of the World Shipping Council Before the Bureau of the Census In the matter of Mandatory Automated Export System (AES) Filing for all Shipments Requiring Shipper s Export Declaration Information
More informationChapter 4 Documents Used in International Trade
Chapter 4 Documents Used in International Trade Documents Used in International Trade Operations Financial documents Used to obtain payment Commercial documents Not intended to obtain payment Both documents
More informationMAP-21 Moving Ahead for Progress in the 21st Century
MAP-21 Moving Ahead for Progress in the 21st Century presented by Ken Hoffman of Dysart Taylor Cotter McMonigle & Montemore, P.C. Transportation & Logistics Council Nashville, Tennessee March 18, 2014
More informationACE Program Status and PGA Integration Status. Professional Association of Exporters and Importers Webinar
Carlos R. Rodriguez U.S. Customs and Border Protection ACE Business Office ACE Program Status and PGA Integration Status Professional Association of Exporters and Importers Webinar September 24, 2015 Agenda
More informationNavistar Defense Code of Conduct
Navistar Defense Code of Conduct INTRODUCTION Navistar Defense, LLC (hereinafter Navistar Defense or the Company ) is committed to conducting its business according to the highest standards of ethics and
More informationImporter Security Filing AKA 10+2
Importer Security Filing AKA 10+2 Background The ISF and Additional Carrier Requirements were borne out of the Security and Accountability For Every (SAFE) Port Act of 2006 which required the filing of
More informationTITLE 19 CUSTOMS DUTIES PART 149 IMPORTER SECURITY FILING
Sec. 149.1 Definitions. Importer Security Filing Importer. For purposes of this part, Importer Security Filing (ISF) Importer means the party causing goods to arrive within the limits of a port in the
More informationImporting Food to Canada
Importing Food to Canada Stay in-the-know with trade news and updates from Livingston. Subscribe today at www.livingstonintl.com/subscribe Follow us today! @Livingston_Intl April 10, 2017 Joumana Bteich
More informationORIGINATING OFFICE: FO:TCF DISTRIBUTION: S-01 CBP DIRECTIVE NO A DATE: AUGUST 7, 2003 SUPERSEDES: ,1/7/88 REVIEW DATE: AUGUST 2006
CUSTOMS AND BORDER PROTECTION DIRECTIVE ORIGINATING OFFICE: FO:TCF DISTRIBUTION: S-01 CBP DIRECTIVE NO. 3240-036A DATE: AUGUST 7, 2003 SUPERSEDES: 3240-036,1/7/88 REVIEW DATE: AUGUST 2006 SUBJECT: IN-BOND
More informationCBP Proposal for Advance Trade Data Elements
CBP Proposal for Advance Trade Data Elements Security Filing 10 + 2 Presented By: John Jurgutis CBP 5/2/2007 1 Justifications for Security Filing Enhance Targeting and Risk Analysis Capabilities Improve
More informationIn order to improve carrier service and reduce freight costs, BOSTONtec implemented a new freight program January 1, 2016.
The following is included as a guide for BOSTONtec s freight program: BOSTONtec Preferred Carriers Helpful Freight Claim Information US Department of Transportation Regulations In order to improve carrier
More informationOffice of International Trade Importer Self-Assessment Handbook
Office of International Trade September 2005 What is Importer Self-Assessment? IMPORTER SELF-ASSESSMENT QUICK REFERENCE GUIDE Importer Self-Assessment (ISA) is a partnership between CBP and importers to
More informationImporter Compliance for 10+2 Importers Security Filing Requirements
Importer Compliance for 10+2 Importers Security Filing Requirements What is the Importer s Security Filing? New security filing requirement imposed on all importers for goods arriving via ocean transportation
More informationPAYMENT TERMS, SHIPPING, AND DOCUMENT
PAYMENT TERMS, SHIPPING, AND DOCUMENT REQUIREMENTS UPDATED: 07/17/15 PAYMENT TERMS Sportsman s Guide standard direct import terms are FOB port of origin. No payment transactions will occur until the import
More informationEXPORTS - GENERAL. Updated: February, 2013
EXPORTS - GENERAL Updated: February, 2013 In our air freight division each of our offices is licensed as an IATA (International Air Transport Association) Agent with the exception of our Hong Kong office.
More informationTradeSmart Web CCI (Canada Customs Invoice) Training Manual. https://webcci.farrow.com/webdataentry/login.smvc
TradeSmart Web CCI (Canada Customs Invoice) Training Manual https://webcci.farrow.com/webdataentry/login.smvc ~ 1 ~ V5.0 Aug 2014 Table of Contents General Information 3 Creating a Web CCI 4 Consignee
More informationTuff Torq Corporation Security Export Control Operations Standards
Tuff Torq Corporation Security Export Control Operations Standards Tuff Torq Corporation Corporate Policy of Export Control: In alignment with Yanmar Co., Ltd., the Tuff Torq Corporation will insure that
More informationApplication of Cargo Preference Requirements to the Federal Ship Financing Program
This document is scheduled to be published in the Federal Register on 12/01/2016 and available online at https://federalregister.gov/d/2016-28863, and on FDsys.gov BILLING CODE: 4910-81-P DEPARTMENT OF
More informationU.S. Bonded Carrier Issues Are On The Rise? Why?
U.S. Bonded Carrier Issues Are On The Rise? Why? What is a bonded load? In bond shipments refers to imports or export shipments which have not been cleared by customs. In bond shipments to and within the
More informationMaritime Security Council. AfrICANDO Security for Africa s Road & Rail Transportation Infrastructure
Maritime Security Council L AfrICANDO 2010 Security for Africa s Road & Rail Transportation Infrastructure DoubleTree Grand Hotel Biscayne Bay Miami, Florida September 28, 1010 Presentation Objective This
More informationMay Nelson, Regulatory Counsel, ORPSS, CFSAN Laura Draski, PhD., Director, Prior Notice Center Anthony Taube, Deputy Director, Prior Notice Center
Changes in the Prior Notice Final Rule and Revised Compliance Policy Guide An FDA Perspective (73 FR 66294 (final rule); November 7, 2008 74 FR 20955 (CPG); May 6, 2009 ) May Nelson, Regulatory Counsel,
More informationCompliance Guidelines: How to Develop an Effective Export Management and Compliance Program and Manual
U. S. D E P A R T M E N T O F C O M M E R C E B U R E A U O F I N D U S T R Y A N D S E C U R I T Y O F F I C E O F E X P O R T E R S E R V I C E S E X P O R T M A N A G E M E N T A N D C O M P L I A N
More informationCopyright JnF Specialties, LLC. All rights reserved worldwide.
Certificate of Origin The undersigned of: (Owner or Agent) (Name and Address of Shipper) declares that the goods shipped via on the date consigned to: Copyright JnF Specialties, LLC. All rights reserved
More informationFocused Assessment Program Overview and Updates. Office of International Trade Regulatory Audit October 2, 2014
Focused Assessment Program Overview and Updates Office of International Trade Regulatory Audit October 2, 2014 Who is Regulatory Audit? Regulatory Audit s (RA s) mission is to conduct postentry audits
More informationMR GLOBAL LOGISTICS TERMS & CONDITIONS OF SERVICE
MR GLOBAL LOGISTICS TERMS & CONDITIONS OF SERVICE These terms and conditions of service constitute a legally binding contract between the "Company" and the "Customer". In the event MR Global Logistics
More informationMastering Purchasing Management for Inbound Supply Chains
Mastering Purchasing Management for Inbound Supply Chains Thomas A. Cook CRC Press Taylor & Francis Croup Boca Raton London New York CRC Press is an imprint of the Taylor St Francis Croup, an informa business
More informationWhat are the documents commonly used in letter of credit transactions?
What are the documents commonly used in letter of credit transactions? Understanding the main characteristics and usage of the letter of credit documents Proforma Invoice In international trade transactions,
More informationFSC.DEC/11/08 Organization for Security and Co-operation in Europe 5 November 2008 Forum for Security Co-operation Original: ENGLISH
Organization for Security and Co-operation in Europe Forum for Security Co-operation Original: ENGLISH 562nd Plenary Meeting FSC Journal No. 568, Agenda item 3 DECISION No. 11/08 INTRODUCING BEST PRACTICES
More informationAgency agreement. For the compensation hereinafter stated, Principal and Agent shall both use their best efforts to perform the following duties:
Agency agreement This agreement is made [date], between [principal], a corporation organized and existing under the laws of the State of Washington, with its principal office located at [address, city,
More informationFrequently Asked Questions Regarding Minimum Security Criteria for Importers 03/25/2005
Frequently Asked Questions Regarding Minimum Security Criteria for Importers 03/25/2005 Q: 1.Why is CBP updating the security guidelines for C-TPAT importers? Will other enrollment sectors also be subject
More informationNational Transportation Specialists, LLC 1801 S Pennsylvania Avenue, PO Box 299 Morrisville, PA
1801 S Pennsylvania Avenue, PO Box 299 Morrisville, PA 19067-0299 Dear Carrier: Thank you for your interest in, a nationwide Logistics provider. To become a qualified carrier for, we require the following
More informationP12 Export Documents
P12 Export Documents Types of Export Documentation for Air Freight and Sea Freight Commercial Invoice Packing List Certificate of Origin Bill of Lading Air Waybill Export License/Declaration Commonly Used
More informationA Message for Brokers Letter And Security Guidelines for Brokers
A Message for Brokers Letter And Security Guidelines for Brokers Kingchem LLC is a participant in the Customs-Trade Partnership Against Terrorism (C-TPAT). C-TPAT is a voluntary joint government-business
More informationP R E S E N T E D T O : A I M U / M I C A S
(Not so) Straight Forward and Freight Forward: Claims Handling Under Freight Forwarder Shipper's Interest and Legal Liability Policies A Litigation Perspective P R E S E N T E D T O : A I M U / M I C A
More informationNew Castle County Ethics Commission GOVERNMENT ETHICS NEW CASTLE COUNTY
New Castle County Ethics Commission GOVERNMENT ETHICS IN NEW CASTLE COUNTY A GUIDE FOR NEW CASTLE COUNTY OFFICIALS AND EMPLOYEES New Castle County Ethics Commission TABLE OF CONTENTS INTRODUCTION...1 Who
More information