Evolving Compliance with Evolving Russian Sanctions

The current crisis with Russia over the occupation of Crimea and Russia’s military build-up near eastern Ukraine has prompted various national governments, including both the U.S. and E.U., to impose additional sanctions on Russia, creating new challenges, to say the least, for both U.S. companies and their foreign subsidiaries. Recent statements from those close to …

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NAFTA Article 303 & IMMEX, a Mexican Perspective

In Mexico, the Administración Central de Auditoría de Operaciones de Comercio Exterior from the Servicio de Administración Tributaria is starting to audit and enforce the application of North American Free Trade Agreement (NAFTA) article 303 against those companies participatimg in Industria Manufacturera, Maquiladora y de Servicios de Exportacion (IMMEX). IMMEX is a duty deferral program …

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Women in Compliance Awards

We are pleased to announce that during the Women in Compliance Awards held in London on March 20, 2014, Braumiller Law Group was highly commended for Best Regulatory Law Firm of the Year. The firm’s founder, Adrienne Braumiller, was also nominated for a “Lifetime Achievement Award” for her years of service to the compliance industry, …

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Braumiller Law Group is pleased to announce that Christos Linardakis, Attorney Senior Counsel , will be rejoining the firm heading up the Chicago office

I am excited about my future with Braumiller Law Group. I have now had the opportunity to work on the client side (corporate), as well as on the entrepreneurial side of international trade, and I much prefer working with an aggressive, and lean boutique firm such as Braumiller Law. Together again, I expect great things …

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A Brief Overview of IMMEX and NAFTA Article 303

Currently, there are over 6000 companies operating under the IMMEX regime in Mexico.[1] The IMMEX play an important role in the Mexican economy, and therefore, the Mexican government promotes them among foreign investors by providing several benefits and advantages for companies that participate in the program. Generally, companies participating in IMMEX can temporarily import raw …

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CBP Announces Modification of National Customs Automation Program (NCAP) Test Concerning ACE Cargo Release for Ocean and Rail Carriers

As many importers are aware, CBP’s Automated Commercial Environment (ACE) will soon replace the Automated Commercial System (ACS) with upcoming deadlines including May 1, 2015 for the mandatory use of ACE for filing all electronic import and export cargo manifest data, and November 1, 2015 for the mandatory use of ACE for all electronic cargo …

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China Files Anti-Dumping Dispute Against U.S. at WTO

China recently filed a dispute against the U.S. at the World Trade Organization (WTO) biennial conference in Bali on December 3, 2013.  The dispute centers on that country’s disagreement with the method the U.S. uses in calculating whether exports from China violate anti-dumping measures. China brought its dispute to the WTO by using the mechanism …

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Challenging DDTC and BIS: The Administrative Procedure Act

We are well aware of the frustration many exporters face when managing the challenges created by export control regulations.  These regulations are vast, difficult to dissect, and at times, exceedingly vague.  To make matters worse, exporters do not always agree with DDTC and BIS on their interpretation of the regulations or with the administrative actions …

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MX Customs Law Amendments

Mexican Congress recently amended various articles of the Mexican Customs Law.  These amendments mainly focus on the customs clearance process, Customs brokers, Strategic Bonded Zones, and customs inspections.  The purpose of these amendments is to create a more modernized customs system that includes advanced technology and simplification procedures aimed at facilitating and expediting international trade …

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“First Sale” doctrine at Risk under Draft European Union Customs Code Implementing Act

Under the Consolidated preliminary draft of the European Union Customs Code (“UCC”) Implementing Act issued January 13, 2014, proposed language provides “For the purposes of Article 70(1) of the Code, the value of the goods shall be determined at the time of acceptance of the customs declaration on the basis of the transaction occurring immediately …

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Non-Recurring Charges – They Look Like an Assist But Aren’t

Acme Corporation negotiates with a non-US supplier to manufacture products that will be imported into the US.  Acme gives the supplier detailed specifications for the products.  The supplier says that it can make the products but will need to either modify its existing tooling or purchase new tooling in order to make the product to …

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Record Keeping Overseas: Is it a good idea?

There are a variety of reasons companies may be tempted to run their record keeping operations offshore.  For example, with a myriad of national and international governing bodies overseeing global trade, some US companies may consider consolidating all compliance functions into a central location with responsibility over ensuring compliance with the international trade laws from …

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Updates in Export Control Reform

On January 2, 2014, the Department of State and Department of Commerce published the third set of final rules implementing the next significant changes in the ongoing Export Control Reform (ECR) initiative. Similar to the previous final rules, these rules primarily involve the transition of items from the International Traffic in Arms Regulations (ITAR), United …

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ITAR Brokering Practical Challenges Pre-Export Control Reform

As defense manufacturers, exporters, and brokers await the issuance of new brokering rules, many continue to struggle with the very grey areas currently found in Part 129 of the International Traffic in Arms Regulations (ITAR). Much is left to interpretation when it comes to reporting and prior approvals. And, as is often the case, the …

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The Trusted Trader Program

For over a year now, Customs has periodically mentioned the development of another pilot program which seeks to increase the agency’s flexibility and company specific understanding of trade compliance and supply chain security. The new program, which is currently named the Trusted Trader Program, would consolidate the Customs-Trade Partnership Against Terrorism Program (C-TPAT) with the …

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