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A common situation that U.S. companies may find themselves in is selling and shipping to a U.S. company, and then being asked to ship directly to a foreign company. This practice, known as drop-shipping, turns the U.S. company into an exporter and with it all the responsibilities of being the U.S. Principal Party in Interest (USPPI). When being asked to ship to a foreign company, you should first run all foreign parties to the transaction through all U.S. government Restricted Parties lists (this should also be done prior to shipment) to make sure there are no sanctions on any of the parties. The jurisdiction/classification must also be confirmed and licensing obtained, as necessary. As a reminder, foreign manufacturer’s supplied classifications can assist U.S. exporters in determining the classification, but cannot be relied upon solely. U.S. exporters should review and validate the export classification. Additionally, the destination control statement with the appropriate licensing authority/classification statement should also be included on export documentation.


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