The Clinton List? U.S. Commercial Service Officials Should Know Better……

It is quite rare that I get an opportunity to leave the office and attend a U.S. government sponsored seminar on an export related topic. Perhaps I might best best off staying in the office after all. This morning I attended a seminar hosted by our local office of the Department of Commerce US Commercial Service, the folks from our government who promote exports. The guest speaker was an officer in the Commercial Section of the US Embassy in Colombia. Suffice it to say, little if any value was disseminated in the 1 hour very broad overview entitled “Doing Business in Colombia.” This was the umpteenth U.S. Department of Commerce Doing Business in seminar that I have attended over my 25 + year career, and frankly speaking likely my last as I think ITA needs to find a better way to spend their money. These seminars are all the same old rehash in which an Embassy counselor provides a very general country overview using macroeconomic data followed by a plug for using US government resources such as financing and risk insurance offered by the US Export-Import Bank. How many times have I heard the same old song? These gatherings provide exporters with little other than a very general country overview while glossing over the reality the trade is a complex exercise that involves technical review of multiple regulatory regimes both domestic and foreign (an assessment that needs to be done right for each and every export transaction in order to avoid potential draconian fines and penalties–something the Commercial Service people never seem to want to mention) and lots of regulatory grey area. The Commercial Trade Specialists at these gatherings have a way of making exporting seem easy, but reality is it is anything but easy.

The worst part of this morning’s seminar is that the speaker advised US exporters in attendance to be sure to screen against the “Clinton List.” What is the “Clinton List?” Not once did he mention that he was actually referring to the OFAC Specially Designated Nationals List or SDN. And not once did he mention the other Parties of Concern Lists (i.e. Entity list, unverified list etc.) which also MUST always be screened against prior to export. Apparently, in Colombia the SDN List is often referred to as La Lista Clinton, but it is bad business to use such unofficial jargon in a PowerPoint presentation when speaking to US exporters about such a potentially costly export compliance responsibility. At a minimum the PowerPoint should have made clear what this jargon was referencing, namely the SDN List! Admittedly, the Commercial Service provides some valuable services such as arranging trade missions and finding in-country distribution partners, and their Country Commercial Guides ARE filled with technical and useful data, but when it comes to disseminating high quality research through the use of these Doing Business in Country “X” seminars, I give the U.S. Commercial Service a grade of “D-.” At a minimum, one would think that trained Commercial Service folks would have a better understanding of the ins-and-outs of U.S. export compliance given that they are trained within the bowels of the same Federal agency that houses the Bureau of Industry and Security (BIS)! Bottom line is, I suppose if you need some basic information on Doing Business in Colombia you are better off having your morning coffee at your desk and using your time to troll the internet or read the Commercial Service Country Guide as opposed to gunning up your car and going to an ITA briefing that is little other than a networking gathering and a pitch to use US government resources to finance your exports.

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