Asking The Right Question: Are You Trade Compliant? Very often, we talk with individuals who are focused on specific needs. They have questions like: “How do I get an ITAR license?” or “What is the ECCN for my product?” Although these questions are valid and essential, sometimes companies need to step back and look at…
Updated 1/09/2020 Navigating The Confusing Landscape Of Distribution Statements Have you ever been frustrated or stymied by those DoD Distribution Statements concerning Critical Technology, which appear to prohibit U.S. contractors from sharing the data with their partners in Canada? Distribution Statements are technical documents If so, you’re not alone! While Distribution Statements seem overwhelming, at…
I feel like it was just 1994 and the North American Free Trade Agreement (NAFTA) was ratified and I was hitting the road advising importers how to take advantage of the duty-free provisions. What a feat! U.S. industry had to learn the Rules of Origin, Tariff Shifts, Regional Value Content requirements and how to complete…
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…
On August 30th, BIS published Due Diligence Guidance regarding exports, re-exports, and transfers to Pakistan. With the increased concern regarding Pakistan’s nuclear program and risks of diversion, BIS is urging companies to conduct additional due diligence when it comes to transactions destined for Pakistan. The guidance highlights supplemental licensing requirements, as well as best practices…
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…
According to Treasury Department statistics, during the first six months of 2019, the Office of Foreign Assets Control (OFAC) has issued nearly $1.3 billion in penalties. That represents 18 settled cases and is an amount which is 17 times greater than all of 2018 (when there were seven settled cases.) The totals for OFAC penalties…
On June 20, 2019, the Department of Justice announced that Walmart and its wholly owned Brazilian subsidiary plead guilty and agreed to pay a combined criminal penalty of $137 million to resolve allegations of violations of the Foreign Corrupt Practices Act (“FCPA”). The fines include $728,898 in criminal penalties, $3,694,490 in criminal forfeiture, plus a…
Ever wonder why your license application is taking so long to be reviewed and approved? Many thoughts go through a Compliance Officer’s mind when the license process is taking longer than expected: “Did I make a mistake on the license application?” “Should I have provided more information?” “Did I miss something in my due diligence?”…
Import classifications are the cornerstone of every shipment. Without a correct classification, you cannot determine duties or tariffs. With trade compliance professionals wearing so many hats, classification is often an afterthought – just a number quickly slapped on the paperwork to get it off the dock. The result? Inconsistent and potentially incorrect classifications. Here are…