Import/Export Training

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Presentation transcript:

Import/Export Training Managing the risks of Import/Export Activity 11/29/2018 L. Cvirko

Major Points Export/Import compliance Why, What , Where, Who and How Antiboycott Compliance Foreign Trade Zone (FTZ) CTPAT 11/29/2018 L. Cvirko

Export/Import Compliance-Why? Administrative: -Fines -Denial of Export/Import Privileges -Exclusion from practice -Seizure Criminal: -Imprisonment 11/29/2018 L. Cvirko

Export/Import Compliance-Why? Exporting/Importing is a privilege not a right. Objective: To ensure that we comply with the regulations from U. S. Department of Commerce U. S. Department of Treasury U. S. Department of Homeland Security 11/29/2018 L. Cvirko

Export/Import Compliance-What? ITAR (International Traffic in Arms Regulations) Import -Commodities Export - Commodities, technology, software Is a license required to Export? Currently all of our products are classified EAR99 No License Required (NLR) 11/29/2018 L. Cvirko

Export Compliance -ITAR International Traffic in Arms Regulations Even if customer is not export if they have a ITAR controlled product you cannot pass technical data, previously sent to you or technical data that may be sent to you in the future to a foreign person or country without prior approval from the U. S. Department of State. 11/29/2018 L. Cvirko

Export Compliance-Where? U. S. Embargoes apply to -Exports from U.S. -Exports and re-exports by U.S. foreign subsidiaries. Cuba, Iran, North Korea, Sudan, Syria 11/29/2018 L. Cvirko

Export Compliance-Who? Proscribed parties High Diversion Risk -Chemical/Biological warfare -Nuclear -Missile technology Proliferation concern questionnaire must be on file before a order can be shipped. It needs to be completed only one time. 11/29/2018 L. Cvirko

Export Compliance-Who? Red flags ( Know your customer) -Customer is unknown -Person with street address requesting 1 or 2 pieces. -Reluctant to provide end-use or end-user information -Ordered items not compatible with end-user’s information. 11/29/2018 L. Cvirko

Export compliance Red Flags The customer has little or now business background. A foreign exchange college student A freight forwarding firm is listed as the product’s final destination. 11/29/2018 L. Cvirko

Export Compliance Anti-boycott Clause -Indicates agreement to boycott anything to do with Israel. -Usually buried inside the letter of credit terms. - 11/29/2018 L. Cvirko

Export Compliance-How? It is a corporate responsibility -Policy -procedures -System generated documentation -Audit trail -Ultimate destination clause in EDI contracts, quotes, commercial invoice -Compliance training 11/29/2018 L. Cvirko

Export Compliance How do we ensure that we are not at risk? . Manual on web site with hyperlinks to detailed procedures. . Training including Outside Sales, Inside Sales, Engineering, Marketing, MIS, Accounting, Quality, Shipping. 11/29/2018 L. Cvirko

Export Compliance How do we ensure that we are not at risk? . Manual on web site with hyperlinks to detailed procedures. . Training including Outside Sales, Inside Sales, Engineering, Marketing, MIS, Accounting, Quality, Shipping and Purchasing. 11/29/2018 L. Cvirko

EXPORT COMPLIANCE Your Export Control Compliance Officer is Dawn Dooley, 864 843-2626, Ext 430 Any time you have a question please call 11/29/2018 L. Cvirko

Import Compliance Our CDM FTZ was Activated September 1 Kelly Holliday , FTZ Manager Brandy Rogers, FTZ Manager Alternate It will save $500K on foil duties annually. 11/29/2018 L. Cvirko

Import Compliance C-TPAT (Custom Trade Partnership Against Terrorism) -Homeland Security effort to maintain effective security through the global supply chain via a joint government-business initiative . -Not participating will lead to increased scrutiny of inbound shipments and increased clearance time through customs. - 11/29/2018 L. Cvirko

Import Compliance C-TPAT Continued -Requires -Application -Self- assessment of security guidelines developed by Customs and the trade community. -Documentation from suppliers of security guidelines. - 11/29/2018 L. Cvirko

Import Compliance -CTPAT We are not registered at this time. If you get a request please send to Kelly Holliday , 864-843-2626 , Ext. 332 11/29/2018 L. Cvirko