Schlumberger Subsidiary Pays $232.7 Million for “Facilitation”

Just last month, Schlumberger Ltd. (Schlumberger), subsidiary Schlumberger Oil Field Holdings Ltd. (SOHL), agreed to pay over $232.7 million in penalties to the United States for violations of the International Emergency Economic Powers Act (IEEPA).  Of this amount, $155,138,904, represented a criminal fine. For a number of reasons, we agree with the Justice Department that …

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Braumiller Consulting Group Offers Total Turnkey Outsourcing

Sometimes the most efficient solution for our clients involves extending our partnership to provide them with one or more compliance specialists dedicated exclusively to their business, whether that means part-time or full-time, temporary or permanent, even working off-site, or at their office facilities. In a total “turn-key” relationship, we can provide: Auditors (Customs, Export, FCPA) …

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Fokker and Schlumberger: The Value of Voluntary Self-Disclosure

U.S. government agencies rely heavily on companies worldwide to voluntarily self-disclose export violations.  The sheer volume of international transactions makes involuntary enforcement unmanageable.  Two export violation cases in 2015 highlight the value and risks of Voluntary Self-Disclosure (VSD). Export violations can involve corporate and individual culpability in civil penalties and criminal prosecution.  The Feb. 5 …

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Understanding the Use of Self-Produced / Intermediate Materials in the NAFTA Qualification Process

Under the NAFTA Rules of Origin, General Note (GN) 12 of the HTSUS, when non-originating materials are used to produce a final product in a NAFTA country, in order for that final product (also referred to as the “Good”) to qualify for NAFTA preferential treatment, the non-originating materials must undergo either a change in tariff …

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Internal Controls for Export Compliance – Let’s Borrow from Customs & COSO

A number of years ago I attended a 2-day workshop conducted by U.S. Customs.  The agency was discontinuing the Compliance Assessment Team approach to conducting audits, and was going to a new method based on what they termed the COSO model. The workshop described the model they were adopting and how it would be used …

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Joe Cortez joins Braumiller Consulting as Senior Trade Advisor!

Joe brings over 35 years of Federal Service experience to Braumiller Consulting Group, LLP. He is the former U.S. Census Bureau’s International Trade Ombudsman and Chief for the Regulations, Outreach, and Education Branch with the United States Census Bureau’s International Trade Management Division.   In this position, he worked on regulatory matters pertaining to the Foreign …

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Cuba and the Potential New World

It’s been six decades of diplomatic separation between Cuba and the U.S., and Barack Obama and Cuban leader Raul Castro nevertheless found a way to sit down together recently in Panama and make a public display of their talks at a regional summit, moving one step closer to restoring diplomatic ties.