There's A New OFAC Reporting Obligation for Rejected Transactions

Posted by Suzanne Richer on July 18, 2019

If you're a responsible importer or exporter, you know that denied party screening is essential to remaining compliant - and that if you get a flag on a shipment, you stop the shipment immediately to avoid penalities and fines. But new rules published last month by OFAC now require you to not only stop that shipment, but to alert the government of the denied party you've uncovered as well. 

The Office of Foreign Assets Control (OFAC) published the new rules on June 21, 2019 in the Federal Register, and they create a whole set of new reporting obligations for companies doing international business. Now you must go beyond scanning the destinations and prospective parties to the transaction against current sanctioned countries and the Prohibited Party lists - you must also report any resulting “rejected transactions” to OFAC within ten days after they occur.

That's a big process change, especially for companies with large trade volumes. Here's what you need to know to comply with these new OFAC obligations.

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Topics: Export Management, Export Compliance, Restricted Party Screening, Export Violations

Your Questions Answered: CTPAT New Minimum Security Criteria

Posted by Suzanne Richer on June 19, 2019

Customs and Border Protection’s (CBP) new CTPAT minimum security criteria are here, and the changes to the program bring CTPAT into alignment with fundamental AEO requirements. 

The Global Trade Academy was pleased to welcome CBP Branch Chief Carlos Ochoa to our webinar a few weeks ago to expand the discussion on how the program is aligning itself to new and existing threats not in place when CTPAT was first championed in the early 2000s. 

Check out Amber Road’s Global Trade Academy resource library to hear the original webinar. Here’s a recap of some of the most pressing questions posed during the program.

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Topics: Global Trade Academy, C-TPAT

Spring Cleaning: Get Your HS Code Right!

Posted by Suzanne Richer on April 24, 2019

Challenged with classification? Classifying the same product differently in one or more countries? Uncertain as to when a “kit” is a “kit for customs purposes” or when to classify a part with the machine and when not to? 

The Harmonized System (HS) is a global number, to 6-digits, that drives the duties, fees and taxes of a product upon importation, in addition to applicable protective measures (i.e.: antidumping). In addition, the HS number is the basis of many free trade agreement qualification processes. So why do so many companies raise their customs risk and classify some products differently when operating in more than one country?

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Topics: Import Compliance, Product Classification, Export Compliance, Global Trade Academy, Trade Compliance, Import Customs Filing

Free Trade Agreement Audits – Are Your Goods Really Duty Free?

Posted by Suzanne Richer on November 15, 2018

Claiming preferential treatment under any free trade agreement is fairly easy. Statements on the commercial invoice or accompanying certificates at the time of import are enough for your customs broker to claim the lower duty rate on your behalf. Proving eligibility of a reduced duty claim is quite the opposite, whether you are an importer, exporter, or the producer of the good.

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Topics: Duty Management, Product Classification, Free Trade Agreements, Bill of Material Qualification

C-TPAT – Modernizing Cargo Security Criteria

Posted by Suzanne Richer on October 23, 2018

Customs and Border Protection (CBP) has long been an advocate of transparency and risk reduction in global supply chains through the Customs-Trade Partnership against Terrorism (C-TPAT), a voluntary cargo security program for global transactions. Since its inception in 2002, C-TPAT has been the basis of how the government manages and monitors cargo security. 

The security threats the nation faced in 2002 are vastly different from today’s security and terrorism concerns. Each day brings a new cargo security concern based on more complex supply chains, and greater risk of data breaches and cyber-attacks. Changing players in company supply chains can also impact cargo security and put companies at risk.

To address today’s risk, CBP has released a more comprehensive cargo security program, with the support of the trade, to mirror the threats now prevalent in global supply chains. The newly released Minimum-Security Criteria (MSC) replace the previous Minimum-Security Guidelines (MSG), changing the landscape of the program for current members, and future volunteers to the program.

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Topics: Supply Chain Visibility, Global Supply Chain, C-TPAT

Importing from China? Your Products Could Be Hit With A 25 Percent “Special” Tariff!

Posted by Suzanne Richer on May 1, 2018

In a further indication that U.S. trade policy toward China has stiffened, the Trump Administration has initiated a punitive tariff action against China under Section 301 of the Tariff Act. Section 301 empowers the White House to impose additional import tariffs on the products of countries who maintain discriminatory policies against U.S. products and services.

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Topics: Import Management, Product Classification, Global Trade Academy

Pivotal Trade Initiatives: Increased Duties & The Global Supply Chain Impact

Posted by Suzanne Richer on February 6, 2018

The importing community is reacting to the recently announced tariff increases based on a recommendation from the United States International Trade Commission. This led to President Trump’s move to add a 30% tariff on solar cells and up to 50% for imported washing machines. The tariffs on the solar cells would decrease over a four-year period. 

The President is using Section 201 of the Trade Act of 1974, the so-called “escape clause” to take this action. This rarely used statutory provision empowers the President to grant temporary import relief, by raising import duties or imposing non-tariff barriers on goods entering the United States that injure or threaten to injure domestic industries that produce similar goods.  

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Topics: Import Management, Import Compliance, Trade Compliance

Duty Drawback Success Story: A $1.3 Million Return on Investment

Posted by Suzanne Richer on June 14, 2017

Duty Drawback represents one of Customs’ most long-standing benefits to firms, as it offers companies a refund of up to 99% of taxes, duties and fees paid when imported merchandise is exported or destroyed within certain timeframes. The concept is simple – match your import entry documents with the corresponding export docs, file for expedited payment processing, and voila! Money will flow into your bank account.

As simple as it seems, drawback regulations are among the most complicated, and it is estimated that $2.8 billion dollars is left unclaimed by companies eligible for refund. Enter Amber Road’s Global Trade Academy – after attending the unique 3-day Duty Drawback Certificate Program, attendees have succeeded in securing incredible refunds for their firms.

One great success story is that of Tammy Anderson, Logistics Supervisor with an electronics firm, who in less than one year was able to secure $1.3 million dollars from her drawback program.  

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Topics: Import Management, Duty Management, Export Management, Import Compliance, Export Customs Filing

Rules of Origin Under Different Free Trade Agreements

Posted by Suzanne Richer on August 4, 2016

Not all Free Trade Agreements are the same, and one of the most frustrating differences is how they define Rules of Origin. How can you tell which products qualify for each agreement?

Don’t miss my presentation next week alongside Susan K. Ross, Partner at Mitchell, Silberbeg & Knupp LLP, as we discuss Rules of Origin Under Different Free Trade Agreements (FTA’s) at the NEI’s Second Annual Global Trade Educational Conference (GTEC)

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Topics: Trade Agreement Identification, Free Trade Agreements

Webinar Q&A: Framing the Total Landed Cost Picture

Posted by Suzanne Richer on July 15, 2016

On June 21st, Amber Road in conjunction with American Shipper broadcasted a webinar entitled, Framing the Total Landed Cost Picture. Our presenters, Suzanne Richer and Phanibhushan Reddy from Amber Road, received several questions throughout the webinar, but unfortunately we did not have time to address them all during the live broadcast. We have compiled their answers into a Q&A document - here is a preview:

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Topics: Landed Cost Calculation, Duty Management, Foreign-Trade Zones, Free Trade Agreements

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