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An $US 80,000 Invoice for a 5-Minute Shortcut

Yes, the U.S. Department of Commerce, Bureau of Industry and Security may have been shut down from December 20th 2018 until it re-opened this past Monday, but that did not stop Export Enforcement from levying an $US 80,000 charging letter and invoice to Ithaca, New York based Multiwire Laboratories, Ltd. for its failure to take five minutes out of its business day back in February 2014 and August 2015 when on two occasions it exported two Real Time Back Reflection Laue Cameras valued at $177,156 to the University of Electronic Science and Technology (“USETC”) of China based in Chengdu. Problem was, Multiwire had no export compliance screening (a five-minute routine […]

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U.S. Government Shutdown/Impact on Licensing

A note to our clients: Unfortunately, due to the U.S. government partial shutdown all export compliance filings with the Department of Commerce, Department of State and Treasury Department are  on hold and frozen (with the exception of urgent cases for direct needs by the U.S. military or humanitarian assistance). The official announcement from the BIS/SNAP-R filing site reads as follows: “Due to the lapse in funding affecting the Department of Commerce that occurred at 12:01 AM EST on Saturday, December 22, 2018, services at BIS are significantly curtailed, including requests for licenses, advisory opinions, and commodity classification except those that provide direct support to the U.S. military, humanitarian aid, or […]

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New Russia Sanctions: Arms Embargo + Prohibition/Policy of Denial for National Security Controlled BIS licenses.

On Monday August 27th the Department of State published a Federal Register announcement introducing new sanctions effective immediately on Russia. This round of sanctions is in retaliation for Russia’s violation of international law through the use of chemical weapons. The case refers to the March 2018 use of a military grade nerve agent that took place the United Kingdom in an attempt take the life of Sergei Skripal, a former Russian intelligence officer who was accused of working as a double agent for the UK. Two British nationals, one of whom later died, were exposed to the chemical agent. Under the new sanctions which are tied to the unlawful use […]

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The U.S. Trade Deficit with China: Separating Fact from Fiction

In recent weeks as the Trump Administration has ratcheted up protectionist tariffs on China, much of the line of argumentation coming out of the Department of Commerce and the Office of the US Trade Representative (USTR) has centered around the need to re-balance what is perceived to be an unfair widening of the U.S.-China trade deficit. However, what is important to note is that U.S. import statistics are highly misleading. As pointed out by Douglas A. Irwin in his book Free Trade Under Fire, in 2009 the United States imported iPhones from China at a per unit cost of $US 179 adding $US 1.9 Billion to the US trade deficit. […]

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USTR Solicits Public Comment (for possible exclusions) on Proposed List of $16 Billion of Chinese Goods To Be Subject to 25% Import Tariffs….TSI Global Consulting Can Argue for Exclusions.

The Office of the U.S. Trade Representative (USTR)  published in today’s Federal Register a notice for industry comments on $16 billion dollars of proposed section 301 tariffs to be imposed on Chinese products. The list of products slated to be subject to the tariffs (284 tariff lines baring exemptions) are noted in Annex C of the attached Federal Register announcement. An implementation date will be announced in the near future. Annex B of the attached notice denotes $34 billion dollars of Chinese goods that will be subject to 25% import tariffs effective July 6, 2018. These items have already been subject to public comment. If your company imports or purchases […]

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It’s Tariff Time…..Round and Round We Go

President Donald Trump and his Office of the U.S. Trade Representative (USTR) announced today (June 15, 2018) the imposition of 25% ad valorum tariffs on $34 Billion dollars, 818 tariff lines of imports from China. The tariffs become effective July 6, 2018. The list of items broken down by H.S. Code subject to this new round of tariffs can be found HERE. In the coming days USTR will be publishing a process for applying for company specific exclusions. If your company is impacted by these new tariffs and you would like to apply for an exclusion please contact TSI Global Consulting, LLC. An additional $16 Billion dollars, 284 tariff lines […]

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BIS Adds 33 Companies to the Unverified List

The Bureau of Industry and Security (BIS) announced today that 33 companies have been added to the Unverified List (UVL) [see Supplement 6 to Part 744 of the EAR]. The new additions include twelve companies in Russia, eleven in China, five in the United Arab Emirates, two in Canada and one each in Estonia, Pakistan, and Finland. As noted in previous blog postings, BIS adds persons to the UVL when they are unable to verify the bona fides of an entity through a pre-licensing or end use check. BIS often uses commercial officers in US embassies and Consulates as well as other US government officials to visit foreign entities that […]

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FEDEX Gets Hit by BIS for Shipments to Parties on the Entity List

Yes, even FEDEX can and does get hammered for Export Control violations. On April 24th, 2018 BIS reached a settlement for 53 violations of Part 764.2 of the EAR, namely facilitating unlicensed exports to parties listed on the entity list. The exports in question took place between July 1, 2011 and January 19, 2012 and involved shipments to Aerotechnic France SAS (“Aerotechnic”) and the Pakistan Institute for Nuclear Science and Technology (“PINSTECH”) both of whom were listed on the entity list when the exports occurred. The charging letter and accompanying settlement indicated FEDEX had used screening software that was not set for fuzzy logic and required full and exact names […]

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U.S. China Trade War…..More Details

As noted in our blog post of yesterday on April 9, 2018 the Chinese Ministry of Trade responded to the imposition of new US tariffs on steel and aluminum imposed by imposing new tariffs on 128 products of U.S. origin. According to the official announcement by the Chinese Ministry, effective April 2, 2018 new ad valorem tariffs of 15% were implemented on a wide range of U.S. origin fruits, nuts and steel products. New 25% duties were imposed on U.S. pork products and aluminum scrap metals. An unofficial English translation of the official Ministry of Commerce (MOFCOM) list of new Chinese tariffs already in force is noted below. Note that […]

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A Trade War on the Horizon?

In recent weeks several TSI Global Consulting clients operating in sectors ranging from strategic alloys to aerospace parts have expressed concern over the new protectionist trade policies of the Trump Administration. While the shift away from free trade towards a more domestic “America First” trade policy agenda should come as no surprise to those who have followed Trump’s rhetoric on trade prior to and following the election, recent policy actions do indicate a ratcheting up of commercial risk as rhetoric turns to action. To date, the only new United States tariffs that have been fully implemented as part of this current friction are the steel (additional 25% ad valorem) and […]

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