MASS Export Center – Oct 2011 October, 2011 1 MASS Export Center - October 2011 Scott Barney, Panalpina, Inc. Partners in Compliance USPPI and Forwarder.

Slides:



Advertisements
Similar presentations
Introduction to INTTRA-Act Shipping Instructions Q
Advertisements

International Trade Specialist World Trade center Kentucky
Welcome to plexiom! Thank you for taking a few minutes to see what we’re about. plexiom.com.
Purchase Order Export / Import Guidelines Presenters name.
Red Flag Rules: What they are? & What you need to do
Importer Security Filing We’ll Make It Work For You.
Document WHAT EXPORT SHIPPING DOCUMENTS DO I NEED? –vary widely according to the country of destination and the type of product being shipped. –Failure.
Chapter Nine: International Commercial Documents
Chapter 9: Performance of Import and Export Contract
© Copyright 2009 by Mike Allocca. All rights reserved. Import & Export Compliance Import & Export Management UVM – Oct 22, 2009.
1. 2 Telephoning 3 INTRODUCING YOURSELF Good morning Let’s start Shall we start Let’s get down to work.
Dale C. Kelly Assistant Division Chief Data Collection
PACE Technologies – 3601 E. 34 th St. Tucson, AZ Telephone: FAX: ExitNextBack
1 CHAPTER XXXI INT'L FREIGHT FORWARDER & ELECTRONIC EXPORT INFORMATION  International Freight Forwarder  Electronic Export Information.
1 Routed Export Transactions June 2013 Name Place, date United States of America Routed Export Transactions June 2013 Freight Forwarders – Routed Export.
2000 U.S. Census Bureau Foreign Trade Statistics Regulations 15 CFR Part 30 **** U.S. Principal Party in Interest and Forwarding Agent Responsibilities,
Foreign Trade Statistics Regulations 15 CFR Part 30 Exporter/Forwarding Agent Responsibilities Provisions for Power of Attorney/Mail Shipments & Software.
Export Controls CBP is Turning up the Heat and the “ICE” is Not Melting April 2008 NCURA Western Regional Conference Adilia F. Koch.
How to Determine If You Need a Commerce Export License Relatively small percentage of total U.S. exports require a Validated License Most products are.
Reduce Exporting Stress withAES. l Electronic Filing of Shipper’s Export Declarations (SEDs) l Electronic Filing of Carrier Outbound Manifests What Is.
Do You Need an Export License? Purpose of Export Controls To serve the national security, foreign policy, nonproliferation, and short.
U.S. Customs and Border Protection (CBP) Outbound Issues Webinar
Name of Course Semester Instructor Name Name of Presentation / Business Name Business Type: EMC/ETC (Import, Export or Both) Name of Group Member 1 Name.
U.S. Census Bureau Reduce Exporting Stress with AES Automated Export System Branch Foreign Trade Division U.S. Census Bureau.
Foreign Trade Division AES Compliance Seminar
1 Foreign Trade Statistics Regulations U.S. Census Bureau Foreign Trade Division Regulations, Outreach and Education Branch.
NCBFAA WEBINAR ADVANCE TRADE DATA ELEMENTS March 1, 2007 Moderated by Mary Jo Muoio and Alan R. Klestadt.
Foreign Trade Division Trade Promotion Coordinating Committee 1 September 2012.
1 Omari Wooden Trade Ombudsman U.S. Census Bureau Foreign Trade Division Foreign Trade Regulations & Automated Export System.
1 Brown Bag Luncheon Series Training 09/25/2008 EXPORT CONTROLS AT YALE.
Export Control Basics James E. Peterson, Ph.D. Associate Vice Chancellor for Research Office of Sponsored Research.
1 NAEP 2009 Annual Meeting Sarah Reynolds American River Intl. Import / Export Compliance Workshop.
The General Rules of Interpretation
PAMS Export Control Page UTHSC Campus –Wide Business Managers Meeting May 17, 2012.
1 Omari Wooden Trade Ombudsman U.S. Census Bureau Foreign Trade Division Automated Export System Overview.
Export Controls Marci Copeland Office of Research Export Control Administrator.
MASS EXPORT CENTER Export Control Reform - ECR Automated Export System - AES December 10, 2013 Moe Mitchell.
The Role of the Freight Forwarder
2000 U.S. Census Bureau Regulations Update Foreign Trade Division September 2000.
Trade Security Importer Security Filing We’ll Make It Work For You Mary Jo Muoio Senior Vice President Barthco Trade Services, division OHL President.
Advice for Internal Compliance Programmes Billy Au Principal Trade Officer Head of Strategic Trade Controls Branch Trade and Industry Department The Government.
Arpil 19-22, 2004Export Compliance Training1 Export Compliance Management December 10, 2013.
U.S. Customs and Border Protection JFK International Airport
Millitech Proprietary Exploring Export Development Opportunities: Selling Compliance By Cindy Peeters TCO/FSO/Director of Corporate Services.
AES NOW and 2014 Presented for Export Expo 2013 December 10, 2013 by Harvey Waite, OCEANAIR Inc.
1 Foreign Trade Regulations Highlights Texas Brokers Association, Inc. Jerry Greenwell September 24-27, 2008.
Export Control Administrator Orientation February 22, 2013
MASS EXPORT EXPO: “EXPORT LOGISTICS TOOLKIT” EXPORT DOCUMENTATION AND AES FROM A PRACTITIONERS POINT OF VIEW, FORWARDER MANAGEMENT AND LETTERS OF ENGAGEMENT.
AUTOMATED EXPORT SYSTEM PRESENTATION PRESENTED BY: HARVEY R. WAITE, II Partner, Director of Regulatory Compliance and Security OCEANAIR, Inc. December.
Routed Export Transactions
2000 U.S. Census Bureau Regulations, Outreach & Education Branch * * * * Regulations Update Foreign Trade Division October 2000.
© Goulston & Storrs All rights reserved. MA Export Center Export Expo: Strategic Planning for Export Compliance Operations December 9, 2014 Kerry.
AES Seminar Compliance with the Export Administration Regulations (EAR) in AES EEI Filings.
Copyright 2013 GHSP | A JSJ Company Trade Compliance Working Together to Provide Compliant Documentation.
Reduce Exporting Stress withAES. l Electronic Filing of Shipper’s Export Declarations (SEDs) l Electronic Filing of Carrier Outbound Manifests What Is.
Differences between customs brokers and customs carriers Differences between customs brokers and customs carriers Baku, April 8, 2016 TAIEX Workshop on.
Concerned Industry - How To Reach Them Werner Haider EXPORT CONTROL OF DUAL-USE ITEMS AND ARMS: INDUSTRY OUTREACH (Sofia, May 2006)
Office of Export Enforcement Bureau of Industry and Security (BIS) U.S. Department of Commerce Anthony Levey Special Agent in Charge Los Angeles Field.
Tradewatch 2011 February 17, Tradewatch 2011 Feb. 17, 2011 Paulette Kolba, Panalpina, Inc. Partners in Compliance Exporter and Forwarder Challenges.
Overview of Department of Commerce Export Controls for Chemical and Biological Items.
Export Control Reform Implementation: Status and Non-U.S. Party Considerations 1.
U.S. CUSTOMS AND BORDER PROTECTION LOS ANGELES / LONG BEACH SEAPORT.
FTR & ACE Transition Update Theresa Gordon International Trade Management Division U.S. Census Bureau.
Export Control Laura Langton, PhD Export Control Manager
AUTOMATED EXPORT SYSTEM PRESENTATION
U.S. Customs and Border Protection (CBP) Outbound Issues Webinar
Export controls & Partners Healthcare
Export Compliance Update and Utilizing ACE to Manage Compliance
Import/Export Training
EXPORT CONTROLS AT UW-MADISON
Presentation transcript:

MASS Export Center – Oct 2011 October, MASS Export Center - October 2011 Scott Barney, Panalpina, Inc. Partners in Compliance USPPI and Forwarder Challenges MASS EXPORT CENTER 2011 – AES Compliance Update

MASS Export Center – Oct 2011 October, I bet we all have some stories to tell!

MASS Export Center – Oct 2011 October, What Shipper’s might hear… “Jamie doesn’t work here anymore.” “I can’t find the file.” “I’ll correct the invoice tomorrow.” “No, it’s ‘NLR’ because it doesn’t need a license.” “What’s an ECCN? Just provide me with the Schedule B so I can file AES and get your cargo out.” “I don’t have to provide you with anything except the ITN.” I’m sure you’ve heard plenty more…

MASS Export Center – Oct 2011 October, What forwarder’s hear… “The Commerce Control List? I don’t know what you’re talking about.” “Here’s the invoice – just assign a Schedule B Number and get the freight out. It’s not my problem.” “No, I will not give you my EIN.” “You’re the only forwarder asking me for that information. I’ll call another forwarder to move the cargo.” “Just move the cargo – I’ll get the documents to you tomorrow.” My personal favorite: “You are my compliance department. That’s what I’m paying you for.”

MASS Export Center – Oct 2011 October, We all face challenges Shipper challenges and concerns about forwarders Level of compliance knowledge Inconsistencies between branch offices, and even within offices Risk (control of cargo, end users) Accuracy of data (AES Transmissions, L/C Documentation, Billing, etc.) … and many more, I’m sure. Forwarder challenges Staff (number, quality, turnover) Continuous training and education Pressure from customers to move the cargo Workload Uneducated Shippers (and Consignees) Educating global network

MASS Export Center – Oct 2011 October, Mutual Challenges  Getting senior level attention to Compliance  Managing Compliance Risk  Increased Government Enforcement  Educating foreign parties (your buyers, our network) about far reaching US regulations  Interpreting regulations that are written ambiguously  Dealing with conflicting government regulations

MASS Export Center – Oct 2011 October, Partners in Compliance (Overcoming the challenges)

MASS Export Center – Oct 2011 October, Working closely together Recommendations for Exporters Engage the Forwarder … even on the ‘dreaded’ Routed Export Transaction Ask questions about their Compliance and Training Programs. Do they have a program? Talk to the Compliance Officer – connect shipper & forwarder compliance people. … especially if you have controlled or licensed products. How do they monitor accuracy? Do they take corrective action?

MASS Export Center – Oct 2011 October, Focus on Account Implementation During the implementation process:  Take a minute to discuss the documentation that you provide. What does it look like? Are the products on the Commerce Control List? Should the forwarder expect to see ECCNs? Licensing? Where does it appear on the documents? When will that information be provided to the forwarder?  Who will be filing data into AES? USPPI or Forwarder? If it’s the USPPI, when and how with the ITN be provided. Ask the forwarder for the transportation data elements.  What information will the USPPI need back. When, how often?

MASS Export Center – Oct 2011 October, Obtain written authorization from your Principal before filing AES!! From the USPPI on Standard Export Transaction From the FPPI (Foreign Principal Party in Interest) on a Routed Export Transaction. Obtain all of the required data element in writing from the USPPI The ECCN box is blank on this SLI. Does that mean that the product is EAR99 or has an ECCN controlled for AT purposes only? Or could it mean that the exporter didn’t know what to fill in, so they left it blank?? Recommendations for Forwarders

MASS Export Center – Oct 2011 October, OBTAINING WRITTEN INFORMATION FROM THE USPPI (US PRINCIPAL PARTY IN INTEREST) Name, Address and EIN (Tax ID)# Schedule B or HTS Numbers, Schedule B units, number of units and value Goods foreign or domestic origin (per Schedule B/HTS) Commercial commodity description EAR99 or ECCN. License, License Exception or Exemption, or NLR (No License Required) designation. Any information that affects licensing. Related Parties (Y/N)

MASS Export Center – Oct 2011 October, Don’t be afraid to ask questions  Are their products on the CCL (Commerce Control List) ?  Are their products on the USML (US Munitions List)?  ITAR Controlled – State Department Licenses (or Exemptions) are required to all destinations.  Do they ever have licenses (Commerce-BIS, State-ITAR, OFAC, etc.)  If they do, we should ask them to always provide a copy to us with their documentation. If ITAR – State Department License:  Have they listed your forwarder name on the license.  Who will lodge the license with CBP? Critical that this is clearly stated.  Offer Guidance if the USPPI doesn’t understand what you are asking.

MASS Export Center – Oct 2011 October, More Questions  Do they ever ship to Embargoed Countries?  Cuba, Iran, North Korea, Sudan (North), Syria  Shipments of Humanitarian or Ag/Med (Agricultural or Medical) may be allowed with OFAC license.  How will they provide the information to the forwarder?  SLI? Commercial Documents?  They must provide all required information: Schedule B, ECCN (Export Control Classification Numbers)  Get examples of documents where they will provide the information. It is sometimes extremely difficult to work with exporter’s documents so it is good to know in advance where to look for the information. Don’t be afraid to say ‘No’ to a customer? If you advise a customer that you cannot ship product to Iran without a license, it is NOT OK to then ship it to Dubai just because the customer asked you to.

MASS Export Center – Oct 2011 October, Partners in Compliance It’s always about communication!!

MASS Export Center – Oct 2011 October, THANK YOU We’re all in it together… Scott Barney Area Export Compliance Consultant, USA Panalpina, Inc. Tel: ext