As the export agencies still strive to implement one system for export licensing and compliance, DDTC has come one step closer by creating a new on-line process for filing CJ requests. As of November 16 at 5 pm, DDTC will no longer accept paper filings for CJ requests. This morning, November 21, DDTC started accepting electronic filings through the new Defense Export Control and Compliance System (DECCS). This new system will replace DTRADE and EFS and will allow the user to save drafts and copy previously inputted data. Yay. Progress is made one small step at a time. (more…)
If you are importing a large volume of products from abroad and are not aware of the C-TPAT program administered by Customs and Border Protection (CBP), then you may want to consider the benefits of the program. C-TPAT is short for the Customs-Trade Partnership Against Terrorism, and participants in the program are six times less likely to undergo a security related cargo examination. Additionally, C-TPAT participants are four times less likely to be subject to a trade related examination than non-C-TPAT members. These significantly fewer cargo examinations help save importers time and money. (more…)
Sanctions against Cuba continue to lift. Effective this week, the Department of Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) have relaxed controls in several areas of trade and commerce with Cuba, including loosening restrictions on exporting to and importing from Cuba, carving out new allowances for U.S. persons entering into contingent contracts with Cubans, and opening new opportunities for American entrepreneurs in the civil aviation, construction, and health sectors. Among the changes is also a provision that will allow Americans to travel to Cuba to attend professional meetings and conferences related to tourism. (more…)
The Commerce Department issued great news for exporters and American workers last week. According to Commerce’s report, Jobs Supported by Export Destination 2015, American jobs supported by U.S. exports to current free trade agreement partners grew 22% from 2009 to 2015. In 2015, U.S. exports to these free trade partners supported more than three million American jobs. Exports to NAFTA partners account for approximately one-fourth of these jobs. (more…)
The Department of State and the Department of Commerce have revised several provisions of the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). Many of the changes are part of an ongoing effort to increase consistency between the terms used in the ITAR and the EAR.
The State and Commerce Departments have revised the standardized language for the destination control statement (DCS) that exporters are required to put on their shipping documents. Further, now exporters are only required to put the language on the commercial invoice. Gone is the requirement that exporters and freight forwarders take steps to include the statements on bills of lading, air waybills, and other shipping documents. The hope is to ease the burden on exporters and make the standard the same under both the State Department’s International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). (more…)
I know the title of this blog is Export Compliance Matters, but I feel compelled to provide evidence that import compliance is also becoming a serious compliance risk. Customs and Border Protection (CBP) just announced Friday that the US government is owed 2.3 billion dollars in antidumping and countervailing duties alone. Moreover, CBP has issued several “informed compliance” letters encouraging prior disclosure of customs violations by warning the trade community that the CBP and Immigrations and Customs Enforcement are enforcing trade violations. The issuance of the letters comes in tandem with more sophisticated auditing techniques that CBP has developed to catch violations, including using customs data provided by CBP’s Automated Commercial Environment (ACE). (more…)
Further weakening secondary sanctions, the Department of Treasury’s Office of Foreign Assets Control has issued a new license to allow non-U.S. persons to fly some U.S. aircraft to Iran for temporary sojourn. While General License J only applies to fixed-wing airplanes and imposes a number of conditions that must be met in order for non U.S.-persons to fly to Iran, the new license may mark the start of new opportunities for the civil aviation industry in Iran. (more…)
The Commerce Department this week announced the establishment of the Trade Finance Advisory Council (TFAC), the mission of which will be to advise the Secretary on how the U.S. may support small and medium-sized U.S. business secure financing so that they may export their products to overseas customers. (more…)
What are secondary sanctions?
Secondary sanctions apply to non-U.S. persons for wholly non-U.S. conduct that occurs entirely outside U.S. jurisdiction. Compare this to primary sanctions, which prohibit U.S. persons from engaging in specified activities with certain countries, entities, and persons. (more…)