On November 21, 2021, DDTC published seventeen new FAQs concerning a variety of compliance topics, more specifically on debarment, export controls and voluntary disclosures. While the FAQs are an effort to clarify previously provided information, DDTC attempts to make clearer the rationale behind the requirements for disclosures and debarment.

Valuation is a common issue many importers face. All merchandise imported into the U.S. is subject to appraisement. The preferred method of appraisement is the transaction value and there are four critical areas that can affect the transaction value. Taking care to check for these areas of concern will help keep you safe from hefty fines and penalties.

Importers Be Aware – if you are importing products that could be caught up in an Antidumping and Countervailing Duties order then you need to be aware of the major changes to these regulations, which were issued by the Department of Commerce recently. The intent of the updated regulation is designed to help enforce import tariff evasion and Customs and Border Protection identification of importer circumvention of the defined additional U.S. tariffs.

What’s scarier than Halloween Kills? What might send shivers down your spine faster than a ghoulish costume? If your answer wasn’t “submitting a license”, then we might have something to learn from you! But if the idea of submitting an export license feels scary, then we might have a solution.

This past month we have seen multiple penalties handed down for illegal exports to prohibited destinations through the use of front companies and diversion. In three particular cases, the items were diverted to an end-user that was not originally disclosed and were shipped through an intermediary.