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…
Like many trade compliance professionals, I go out and peruse various trade compliance newsletters, the U.S. government agencies websites, and other media to keep up-to-date on compliance issues. Recently, my attention was caught by a case involving Darling Industries of Tucson, Arizona. A closer look at Empowered Officials On February 28, 2019, the Directorate of…
Late one Friday afternoon while speaking with a client who was about to leave on vacation, I heard the following question: “Do you know what a CF-28 Request for Information means?” Like many small- to medium-sized businesses struggling to understand the finer points of customs compliance, this client ran up against what is likely to be…
Understanding China’s New Export Laws Lately, everyone is focused on changes to U.S. export control regulations and related trade initiatives (such as the new tariffs and FIRRMA/CFIUS). Export Control Reform will shortly see the transitions of items from USML Categories I, II and III from the ITAR to the EAR. Likewise, the reforms to CFIUS are simply awaiting…
In recent weeks, we’ve seen significant activity from both the legislative and executive branches that could change the way foreign investment occurs in U.S. companies. These changes could also affect the export control compliance requirements of many companies who are targets of foreign investors. Keep reading for a brief history of CFIUS reviews, and the…
Just like cooler temperatures and falling leaves are the harbingers of autumn, so too are the notifications that will soon be arriving from U.S. Customs and Border Protection (CBP) that your company has been selected for a Focused Assessment. What can you do to prepare for one of these assessments? How can you ensure that…
Routed Export Transactions And Your Business Have you ever struggled to determine the responsibilities and parties in a routed export transaction? If so, you’re not alone! Routed transactions make even the most experienced exporters pause. They have been described as dreaded, confusing, mysterious, and complicated! What is a Routed Export Transaction? The difference between a…
We get a lot of questions about exporting titanium products and other metals from the United States to a foreign country. It’s no simple process, and it’s easy to slip into a violation of U.S. export control regulations. Recently, I sat down with one of our clients – Performance Titanium Group (PTG) – to discuss…