The Bureau of the Census (USBC) Proposed Rule: Foreign Trade Regulations: Overall Impact of the Removal of Electronic Export Information Filing Requirements for Shipments Between the United States and Puerto Rico and the Virgin Islands
Comment:I support removal of EEI filing requirements for shipments between the US and Puerto Rico and the Virgin Islands. US territories should not be treated as separate countries.
I recently participated in another KPMG TradeWatch webinar on export compliance smart practices for audits and corrective actions. The presenters packed a lot of useful information into 60 minutes. Here are some highlights.
Employ transactional testing to determine areas of greatest risk including: licensed shipments, end destinations, end users, freight forwarders, jurisdiction and classification determinations, denied party screening.
Periodic Self Testing using:
Internal Controls- Do they provide visibility?
Internal Processes- Are they appropriate for the level of business?
Systems- How are compliance updates handled?
Personnel- Is staff trained in export compliance responsibilites? What is escalation protocol?
External Factors- What procedures and communication is in place for third parties and supply chain partners?
Consider voluntary self disclosures as part of corrective actions. VSDs can help mitigate fines and penalties.
I recently reviewed two research papers for the Transportation Research Board in my role as a member of the Standing Committee on International Trade and Transportation.
While I recommended acceptance of both of these papers, they have not yet been published, so I may name them in a future post. These studies are academic in nature, highly technical, and contain plenty of statistics. They obviously won’t be of interest to everyone but they do make contributions to the literature in their fields. I am pleased to have had the opportunity to review these papers and am very impressed by the amount of work done by the authors.
Working remotely has become the norm with obvious advantages in cost savings and productivity. Managing remotely also brings challenges. While it is easy to move information and analyze data from any location, the human element is different. Without “face time” one of the big risks is miscommunication. Some basic management skills can help improve performance.
Here is a proven method for your toolbox. The links of the performance chain can are useful for day to day management and problem solving.
Expectations– Are goals and deliverables crystal clear? Don’t assume. Feedback– Information which is specific, timely, and relevant. Not just an annual review. Resources– Time, tools, and staffing to do the job right. Skills/Knowledge– Is training needed? Managers often point to training as the solution to problems. However, if employees know how to do the job training may not be the answer to performance issues. Look to the other links of the chain. Capacity– Does the person have the physical and mental ability to do the job with training? If not, reassign or terminate, and screen new hires more carefully. Incentives– What rewards are most meaningful to the workforce? These include money, benefits, flex time, etc. and will vary for individuals. Incentives are external and provided by the company. Motivation– Internal and personal to each employee. Top performers are self motivated. For others the idea is to bring out their motivation through incentives, training, or simply clearer expectations and feedback.
New to management? The performance chain is a good starting place. Experienced manager? Old dogs can learn new tricks.
From BIS (Bureau of Industry and Security) website….
GENERAL EXPORT LICENSE FAQS
Does my shipment require an export license? Maybe. A U.S. export license requirement from the Department of Commerce can be triggered by several important factors specific to your transaction: the actual item (commodity, software, or technology) that will be exported, where it is going, who is going to use it, and what they will be using it for. If any of these factors change in your transaction, the license requirements may change.
The customs broker license examination (CBLE) is scheduled for October 8, 2020, as previously announced in the Federal Register notice (84 FR 71440) published on December 27, 2019. CBP will administer two examination sessions: one in the morning and one in the afternoon, the times will be announced soon. CBP’s highest priority is the health and safety of all test-takers and CBP personnel. Information will be added concerning the CBLE as soon as possible, please regularly check this website for updates regarding the October 8, 2020 examination. If you have questions please email Headquarters Broker Management Branch at brokermanagement@cbp.dhs.gov.
Updated: July 28, 2020
The CBLE registration is scheduled to open early on August 3, 2020 and will close on September 8, 2020.
David J. DiSanto • 1stDiSanto & Associates, Inc. Consulting in Supply Chain Analysis & Optimization2w • 2 weeks agoWould you buy airline stock now ?400,000 Jobs Lost at Airlines During Coronavirus Pandemicaviationpros.com • 2 min readAbout 400,000 airline workers have been fired, furloughed or told they may lose their jobs due to the coronavirus, according to Bloomberg calculations. The aviation industry has suffered more than most as the pandemic destroys ticket sales and strips..
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Good question Dave. Would be a great investment if you pick the right airline.Like Mitch Kostoulakos, LCB’S comment
The Bureau of Industry and Security is a good resource for export compliance information and training.
This two-day virtual program is led by BIS’s professional counseling staff and provides an in-depth examination of the Export Administration Regulations (EAR). The program will cover the information exporters need to know to comply with U.S. export control requirements on commercial goods. We will focus on what items and activities are subject to the EAR; how to determine your export control classification number (ECCN); steps to take to determine the export licensing requirements for your item; when you can export or reexport without applying for a license; export clearance procedures; and record keeping requirements.
As I have written in previous posts, it is a mistake to leave export compliance in the hands of your shipping department. Shippers are under time pressure to get shipments out the door and often do not have sufficient knowledge or training to avoid mistakes. In addition shippers rarely have the authority to stop shipments if they spot red flags and this can have big consequences. So don’t give shippers the responsibility for compliance without the authority.
Many exporters automatically classify their shipments as EAR99 and NLR without checking that these designations are accurate. A little due diligence goes a long way so here goes.
Exporters, do you know how to determine your ECCN (Export Control Classification Number)? While it is true that many exported commodities can be designated EAR 99 and NLR (No License Required), it is important to first check for an ECCN. The correct ECCN is necessary in order to determine if a license is required for your shipments.
There are three ways to determine ECCN: 1) self classify, 2) consult manufacturers of commodities, 3) request a classification by BIS.
The CCL (Commerce Control List) Index @ bis.gov is a good place to start.
If you need help contact mitch@52.91.45.227
The U.S.-Mexico-Canada Agreement entered into force on July 1st.
Check the CBP website under Trade for a list helpful FAQs