Category: Customs Compliance

Appropriate to the Season and to something that should stay with us all throughout the year... On the first day of Christmas my company gave to me- A Management Compliance Policy which establishes my management’s and my company’s commitment to export compliance; On the second day of Christmas my company gave to me- An Export...

We are all familiar with the requirements of filing the Electronic Export Information (EEI) in the Automated Export System (AES); but let’s be honest- it may be a regulation, but it is more like an administrative process: you file the information and if you make a mistake, you amend it. No big thing. Maybe not…...

It’s almost Thanksgiving and when I think Thanksgiving, I think about traditions. Truthfully, no one in my family even likes turkey and we’ve discussed deviating from eating it every year, but we just can’t do it! Why? Tradition! We have all kinds of traditions at this time of year: fighting over (ahem, I mean breaking)...

In a September blog “INCOTERMS, They are a-changing” , we discussed what potential changes could occur during the review process of INCOTERMS 2010 by the International Chamber of Commerce (“ICC”). The ICC has now released the latest revisions, which they believe will help simplify the responsibilities of the buyer and the seller in a trade...

The World Trade Organization (“WTO”) ruled on September 30th that the U.S. was free to impose $7.5 B in tariffs on European goods being imported into the U.S. The increased tariffs could begin as early as October 18th. The ruling is the result of fifteen years of litigation related to original allegations by the U.S....

During all the activities (sanctions, tariffs, designated entities, etc.) of the past two months there was an updating of guidelines by Customs and Border Protection (CBP) that may have been overlooked. In July, CBP updated its Forfeiture Remission Guidelines for Export Control Violations.   Considering the fact that the last update was published in 2004, changes...

In a previous blog, we discussed the concept of “reasonable care” as it applies to your trade compliance program.  The focus was how export and import programs dovetail with many other areas of compliance, such as policies and procedures, valuation, Free Trade Agreements, and more.  Today, I’d like to switch gears and talk about how...

Within a few short weeks, the International Chamber of Commerce (“ICC”) will release the much-anticipated INCOTERMS 2020 and, as it did in 2010, the publication of the ICC decisions will change the landscape of international trade.  As you may remember, the INCOTERMS were reduced from thirteen (13) to eleven (11) with the 2010 revisions. While...

Capital One is famous for its slogan, “What’s in your wallet?”  But in the world of trade compliance officers, the pertinent question might be, “What’s in your compliance plan?” Earlier this year, OFAC published “A Framework for Compliance Commitments.”  This framework provides direction and insight into what the agency believes are essential elements of a...

In response to the U.S. imposition of additional tariff increases on May 10, 2019, China’s Ministry of Finance announced that they will increase tariffs on about $60 billion of U.S. goods on June 1, 2019. List 1 encompasses 2,493 line items which will be assessed duties at 25%. There are 3 other lists that have...