Import Valuation

By: Bonnie M. Kersch, Senior Trade Advisor, Braumiller Consulting Group Determining the appropriate value for merchandise that you import can be a tricky task.  In general, you need to start by determining the basis of appraisement that is appropriate for your situation.  I’ll list them below but note that you should try to use the …

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How COVID-19 is Impacting U.S. Sanctions and Export Controls

By: Devin Sefton, Senior Associate Attorney, Braumiller Law Group Since the emergence of COVID-19 in the U.S. beginning in February of 2020, there is general uncertainty over how the pandemic could affect the regulatory landscape, including regulations relating to U.S. sanctions and export controls.  A review of the actions taken to date suggest that little …

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CBP’s Forced Labor Initiative: Will this Affect your Supply Chain?

By: Jennifer Horvath, Partner, Braumiller Law Group The U.S. government, including Customs and Border Protection (CBP), has recently put an emphasis on preventing forced labor in global supply chains. For instance, On March 11, 2020, the House Rules Committee introduced a new bill that would create a rebuttable presumption regarding forced labor in Xinjiang, China. …

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Industry in the Midst of COVID-19

By: Vicky Wu, Senior Associate Attorney and Megan Mohler, Associate Attorney, Braumiller Law Group The U.S. aerospace and defense industry is feeling the impact of the COVID-19 pandemic as individuals and companies are trying to adjust to coronavirus recommendations.  While U.S. companies remain operational, many have experienced supply chain disruptions leading to concerns that contractual …

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NIST 800-171: Cybersecurity, CUI/CDI and ‘CMMC’, Part II: How to execute NIST within your business

By: Christos Linardakis, Of Counsel In Part I of our NIST 800-171 series, we discussed various aspects of complying with DFARS 252.2014-7012 (NIST 800-171 compliance), including certifying under systems like EXOSTAR, identifying gaps within your systems (IT, procedural and physical), capturing CUI/CDI data (if you were paying attention in class, you should know what these …

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Executive Order Places Reporting Burden on Express Couriers and Customs Brokers to Report Importers

By: Adrienne Braumiller, Founder & Partner, Braumiller Law Group On Friday, January 31, 2020, President Trump issued an executive order reiterating the policy of the United States regarding persons who facilitate imports of merchandise in direct violation of Federal laws and calling for the Secretary of Homeland Security to issue a notice of proposed rule-making …

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Supply Chain – Speed Kills: What is driving this, and where is the speed coming from?

By: Ron Spencer, Trade Consultant and former COO of several major brands Consumers are driving the marketplace, and they have high expectations. “When can I get it?” Consumers have an insatiable appetite for speed. Just a few years ago, Dell made the news that you could get a customized laptop in just a few weeks. …

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Airbus SE Export Settlement Agreement: What can be learned from their mistakes?

By: Christos Linardakis, Contributing Author I’m sure by now, you’ve read, or at least heard of, the Airbus SE multi-billion dollar settlement with U.S., French and UK authorities, for FCPA and Export violations—the largest penalty that I can recall in my 30+ years in international trade! Although, I’ve had extensive experience in anti-bribery and anti-corruption …

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Classification: A Necessary Evil or Helpful Tool?

By: Bonnie M. Kersch, Senior Trade Advisor, Braumiller Consulting Group Determining the correct classification of goods is arguably paramount to any good trade compliance program.  However, many companies misclassify their goods at an astonishing rate.  While this may be good for business for trade compliance consultants like myself, it isn’t good when it comes time …

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Department of Homeland Security Announces Actions to Combat E-Commerce Counterfeiting

By: Paul Fudacz, Partner, Braumiller Law Group U.S. Department of Homeland Security (DHS) data shows that between the years 2000 and 2018, seizures of counterfeit goods at U.S. borders have increased 10-fold, from 3,244 seizures per year to 33,810.  In response to this surge, in April of last year, the Trump Administration published its Memorandum …

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Updated VSD Policies: How Could this Affect you?

By: Jennifer Horvath, Partner, Braumiller Law Group While the United States Trade Representative is currently inundated with Section 301 exclusion requests, the Department of Justice’s (DOJ) National Security Division’s (NSD) recent update could be encouraging an influx of voluntary self-disclosures (VSDs) to the U.S. export agencies and the DOJ in the near future. NSD has …

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Japan-US Free Trade Agreement – Not All it Appears to Be

By: Bruce Leeds, Senior Counsel, Braumiller Law Group On Jan. 1, 2020 the Japan-United States Free Trade Agreement went into effect.  The agreement provides duty-free, or reduced duty treatment, for certain Japanese imports into the U.S. and certain U.S. exports to Japan.  The implementation details were printed in the Federal Register on Dec. 30, 2019 …

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