The Impact of Export Control Reform on an Electronics Subcontractor

Acme Electronics (Acme) is a medium-sized company in the U.S. that makes products (primarily circuit board assemblies and wiring harnesses) used in commercial and military aircraft. Acme occasionally sells these products to aircraft manufacturers, but most of its sales are to major U.S. and foreign subcontractors to aircraft manufacturers. Acme has a pretty straightforward process …

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Blue Lantern Highlights the Need for a Strong Compliance Program

The Department of State, through the Research & Analysis Division (RAD), Office of Defense Trade Controls  Compliance (DTCC), Bureau of Political-Military Affairs (PM) operates an end-use monitoring program called Blue Lantern. The Blue Lantern program monitors the end-use of defense articles, defense services, and brokering activities to ensure that “the recipient is complying with the requirements …

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2012: A Busy Year for Customs and Border Protection

U.S. Customs and Border Protection (CBP) recently released a summary of its activities in Fiscal Year 2012, which the agency says was marked by “historic levels of personnel, technology and resources” dedicated to the Southwest border, coupled with efforts to facilitate legitimate trade and travel. “In 2012, the men and the women of CBP played …

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Making a “Made in USA” Claim – First Understand the Basics

Both the Federal Trade Commission (FTC) and U.S. Customs and Border Protection (CBP) have responsibilities related to the use of country-of-origin claims. While the FTC regulates claims of U.S. origin under its general authority to act against deceptive acts and practices, foreign-origin markings on products (e.g., “made in Japan”) are regulated primarily by CBP. This …

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An Update on Export Control Changes for Commercial Satellites

Recent movement toward loosening export controls for commercial satellites and related items has that sector of U.S. industry crossing its fingers. Notably, the President recently signed into law an act loosening export controls. The National Defense Authorization Act of Fiscal Year 2013 (“the Act”), signed on January 2, is a signature step in the movement …

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Conducting Business in Mexico in 2013…..Is it Safe?

Last month, I covered the ever-growing competitive landscape between manufacturing in Mexico and manufacturing in China. Interestingly, some of you inquired about the obvious risks (non-Customs related) involved with manufacturing in Mexico, so I thought I would take a look at the current climate. It’s a given that Mexico’s war on crime is  a point …

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Trade between the United States and Mexico: Securing the Supply Chain

The trade of goods and services between the United States and Mexico is an essential component of both countries’ economies. As of 2011, the trade of goods and services with Mexico totaled $500 billion. Mexico was the second largest market for exports of U.S. goods, and the third largest supplier of goods imported into the …

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Bureau of Industry and Security “Outreach visits”: An Opportunity to Shape Up

On Feb. 5, 2010, a small company named Capintec, Inc. received a seemingly cordial and routine “outreach visit” from Bureau of Industry and Security (BIS) special agents. What appeared to be a harmless and informative visit turned out to be the Trojan horse that led to a $23,000 fine assessed against Capintec for unauthorized shipments …

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Adrienne Braumiller and Bruce Leeds to speak at the 12th Annual Partnering for Compliance- East Coast Conference

DATE: February 20, 21 & 22, 2013 *Reservations are limited to the first 200 paid registrants. COST: Pre-registered and prepaid before Monday, February 4th, 2013- $450.00, Non-U.S. Government. $150.00 U.S. Government Employees All registrations received after Monday, February 4th, 2013- $495.00, Non-U.S. Government. $190.00, U.S. Government Employees LOCATION: Pegasus Ballroom (Student Union Building), University of Central …

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Adrienne Braumiller to speak at 39th NCBFAA Annual Conference

  Adrienne Braumiller will speak at Educational Workshop In Conjunction With 39th NCBFAA Annual Conference “Success Built on Knowledge” 11:45 a.m. to 1 p.m. CCS Session: CBP Audit Triggers / What’s New with CBP Audits? Thursday, April 11th, 2013 For information and registration: https://www.ncbfaa.org/  

Adrienne Braumiller to Speak at Ohio International Trade Assistance Center

Ohio International Trade Assistance Center announces Adrienne Braumiller to speak on “Comparing and Contrasting the Similarities and Differences between the Free Trade Agreements”. You will learn what to do and what not to do to comply with the Free Trade Agreements (FTAs) which companies are utilizing daily. March 5th , 2013 10:00 to 11:30 a.m. …

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USTR Seeks Comment on Withdrawal of GSP for Bangladesh

Last month, a fire in a Tazreen Fashion factory in Bangladesh left 112 workers dead and a host of U.S. lawmakers questioning whether Bangladesh should continue to enjoy preferential treatment under the Generalized System of Preferences (GSP). The United States Trade Representative (USTR) is now seeking commentary on the effects of removing Bangladesh from the …

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Classification Pointers – Deconstructing “Parts of General Use”

A fundamental rule associated with classifying merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is found under the General Rules of Interpretation, Rule 1, which provides in part: “classification shall be determined according to the terms of the headings and any relative section or chapter Notes.” One of the primary functions of …

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New Legislation Opens up Russian Trade Opportunities, But Facing Backlash

A bill overwhelmingly approved by Congress and signed by President Obama last month is expected to greatly expand export opportunities for American businesses by normalizing U.S. trade with Russia. But some fear it could also lead to strained relations between the two countries because of a provision in it that would punish Russian officials accused …

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A New Year’s Resolution: Ensuring Your Company Has a Strong Export Compliance Program

The beginning of a new year is an appropriate time to reflect upon your company’s export compliance controls and ensure the procedures you have in place adequately protect your company. Export compliance programs generally seek to prevent the company’s own unauthorized exports, but often fail to account for the entities and people actively seeking to …

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