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Archive for May 2017

Implementing Export Compliance Policies and Procedures

Once your company drafts (or revises) Export Compliance Policies and Procedures, you must ensure you take steps to implement these documents properly and that your company is fully compliant with the procedures outlined in them. Prior to finalizing the Policies and Procedures, companies should ensure there is no conflict between their practices and their written […]

CJs and CCATS

In instances where there is a question as to the classification or jurisdiction following the exporter’s self-classification, it is recommended that a State Department Commodity Jurisdiction (CJ) and/or a Commerce Department Classification Request (CCATS) be obtained for the items to be exported. Both classification submissions will allow for the confirmation of jurisdiction/classification, and thus allow […]

Classification/Jurisdiction of US Origin Items By a Foreign Entity

In certain cases, a foreign entity (i.e. foreign consignee, end user, etc.) may make a self-determination regarding the classification/jurisdiction of an item, including reclassifications based on Export Control Reform. If the U.S. exporter or manufacturer does not provide the foreign party with the classification, the foreign party is responsible for determining if the item is […]

Restricted Parties Screening

A key component to every company’s export compliance program should be screening of the U.S. government export sanctioned lists prior to shipment. Companies may choose to screen the lists prior to accepting an order, but that does not negate their responsibility to screen prior to shipment as well as parties may have been added after […]