In recent years TSI Global Consulting, LLC has developed an extensive practice assisting our clients to understand the complexities surrounding U.S. export controls, export licensing, tariff classification and a wide range of export/import compliance matters. A sample of export compliance related consulting engagements TSI Global Consulting has successfully performed over the past twelve years from 2010-2022 includes:
Aerospace/Export Classification:
Work on behalf of a U.S. aircraft parts exporter to classify against the Commerce Control List (CCL) an entire aircraft manufacturing program that included a 1970s era single engine aircraft inclusive of over 14,000 parts, components, blueprints, jigs and molds for sale to a commercial end user in the Peoples Republic of China. In another case, we handled the jurisdiction determination, classification and licensing of ground positioning equipment manufactured by a California company for export to the Royal Air Force (UK). In 2017 we advised on, drafted and did a third party BIS license filing for a $6 million dollar export license on behalf of a major US parts distributor to export C-130 parts to Latin America. More recently in 2020 we handled the advisory and licensing for a Florida based aerospace parts distributor on C-130 export to Argentina and we handled licensing for a California based distributors export of ECCN 9A610 military aircraft parts to the Malaysian and Indonesian Air Force. We assisted a US manufacturer to obtain an export license for original manufactured parts to be exported to Embraer (Brazil) for integration onto a major military aircraft platform. And over the period from 2019-2020 we have served as the lead export compliance consultant on EAR and ITAR licensing to the senior management of a Texas based OEM that has designed and produced unique first generation dual use (commercial/military) Unmanned Aerial Vehicle (UAV) system that competes with systems developed by Boeing.
Aerospace/Export Compliance Training:
Designed and presented onsite seminars and training to over fifteen U.S. manufacturers and exporters covering the recent export control reforms in the aerospace industry that incorporate the new “series 600” ECCNs for commodities, software and technology that has moved from the U.S. Munitions List (USML) to the Commerce Control List (CCL) . Presented module onsite to numerous companies in the defense industry including the senior management and sales force (over 30 personnel) at a U.S. 25 million dollar distributor of commercial and military aircraft parts, an original manufacturer of air frame parts for the C-130 military cargo plane. In 2022 TSI Global Consulting held a 2-day EAR/ITAR training onsite at the facilities of a west coast manufacturer of military aerospace ground support equipment.
Strategic Alloys/Oil & Gas-Licensing:
Work on behalf of a Florida based steel and metal alloy distributor to successfully obtain and export license from the U.S. Department of Commerce, Bureau of Industry and Security (BIS) for the export of aluminum round bars (ECCN 1C202) controlled for nuclear proliferation to Mexico for processing into tools used by a Fortune 500 U.S. corporation operating in the oil and gas industry.
Oil and Gas/Licensing:
Work on behalf of a $US 400 million dollar Houston, Texas based energy company to draft, file and obtain a BIS export license for export controlled nickel valves to the Saudi Arabia ARAMCO-SAMREF oil refinery.
Strategic Metals/Licensing:
Work on behalf of a U.S. based exporter of raw materials to draft, file and obtain a license from BIS to export $2 Million dollars of zirconium and hafnium controlled for nuclear proliferation to the Peoples Republic of China for manufacture of “getters” used as insulation for semiconductors and a wide range of commercial products. In 2017 we drafted and filed a $500,000 license on behalf of a US subsidiary of a Chinese owned company to export Hafnium for commercial end uses in China.
Semiconductors/Export Classification:
Work on behalf of a Singaporean based reseller of semiconductor tooling to determine ECCN classification and licensing requirements under the U.S. Export Administration Regulations (EAR) for semiconductor tooling warehoused in the United States and scheduled for export to South Korea and Singapore.
Semiconductors/Encryption Registration and Review:
Work on behalf of a Los Angeles based manufacturer of LCD display boards to classify encyrption capable microchips for export to the Peoples Republic of China. Drafted and filed an encryption registration application with the Bureau of Industry and Security through the SNAP-R system.
Crime Control Products:
Work on behalf of a California based wholesale/retail company to obtain a BIS export license to export fingerprinting dyes and inks to a distributor in Brazil for resale to the Brazilian police.
Military Electronics/ITAR:
Advise the senior management of a Panamanian company that brokers military electronics to the Panamanian government on their obligations as a broker of defense articles listed on the USML under Part 129 of the International Traffic in Arms Regulations.
Satellite Systems:
Drafted and filed a Commodity Jurisdiction for a Virginia based firm for technology used to track satellite interference locational sources. Worked on behalf of a US manufacturer to classify and successfully obtain an export license for an ECCN 9A515 formerly USML/ITAR part to be exported for integration into a foreign commercial satellite system.
Aerospace/Commodity Jurisdiction:
Work on behalf of a Connecticut based aerospace electronics manufacturer to draft and file a commodity jurisdiction review for a dual use breathing device used for high altitude flight simulation.
Medical Device/OFAC Licensing:
Work on behalf of a New England based manufacturer of medical devices to draft and file a license with the U.S. Treasury Office of Foreign Assets Control (OFAC) for export to a sanctioned country.
Machine Tools/Export Licensing:
TSI Global Consulting represents a major Pennsylvania based manufacturer of CNC machine tools exported under ECCN 2B201 and controlled for nuclear proliferation. In 2020 we also handled the licensing of CNC machine tools for semiconductor OEM that has operations in Malaysia. Over the years TSI Global Consulting has handled the export licensing and compliance work, advising on, drafting and filing for BIS export licenses for millions of dollars of CNC 5-Axis machines exported to China, Vietnam, Malaysia, the UAE, Bahrain, Kuwait and Saudi Arabia.
Cuba:
In 2017 TSI Global Consulting was retained to advise on licensing by a major hardware manufacturer to export building construction supplies to Cuba under BIS license opportunities provided by Export liberalization initiatives that were put in place to allow for some limited exports to the private sector in Cuba. We also assisted the company in navigating the Cuban Assets Control Regulations or CACR administrated by the US Department of the Treasury, Office of Foreign Asset Controls (OFAC).
Russian Sanctions Evaluation and Export Compliance Reviews for Pending Transactions:
Since 2017 one of our most common client phone calls has been “Can I export my [Computer, Medical Device, oil drilling equipment etc…] to my distributor or end user in Russia?” In recent months the U.S. government has been tightening the regulatory noose on the Russian government and Russian industry with ties to the Russian State. Specifically new economic sanctions imposed by both the U.S. Department of Commerce, Bureau of Industry and Security as well as the Department of the Treasury, Office of Foreign Assets Control (OFAC) has created the need for exporters to navigate a complex web of regulatory sanctions in evaluating the risk profile for potential export transactions. Over the past year, at TSI Global Consulting, we have performed “deep” Consolidated List Screens and evaluated several complex pending exports against the OFAC Russian/Ukrainian sanctions as well as Parts 736, 744 and 746 of the Export Administration Regulations (“EAR”) in order to “green light” our clients exports to Russian entities. On several occasions we have had to evaluate Red Flags and in a couple of cases we have had to reject potential transactions based on the excessive risk profiles of potential Russian partners. In most cases, we can mitigate risk to a level whereby we can green light the transaction after deep Consolidated List screening [taking the OFAC 50% Rule into account] along with extensive due diligence and use of specialized end user/end use based signed certifications
Source Channel, Distribution and Supply Chain Consulting
Our Mission : In the mid-1990s, a $50 million dollar New York based importer of unfinished woven cotton textiles approached our Jakarta-Indonesia office for assistance in developing new sources of supply for high volume imports. Sourcing high volumes out of Indonesia and Southeast Asian suppliers since the 1970s, this client had established a significant share of the US import market for greige fabrics used in the American apparel and home furnishing industries. However, by the mid-1990s the revolution in information technology, communications and transportation had turned this once highly profitable business into a fiercely competitive commodity trade. Most of the major Asian suppliers were limiting their export of raw materials, in favor of exporting higher value added dyed and finished textiles. The company sought our assistance in expanding their sourcing network by tapping into a little known middle market of medium sized Indonesian and Southeast Asian mill suppliers who had, for over a decade, been exporting to European buyers, but had yet to penetrate the US market. Our client’s strategy was to outmaneuver its New York based competitors by using TSI Global Consulting’s on-the-ground local expertise to tap into this new, lower cost, middle market network of high volume raw material suppliers.
Our Research and Implementation Efforts: Over a period of several years TSI Global Consulting negotiated and developed high volume exports from fifteen medium sized textile mills located in Indonesia, India and the United Arab Emirates. Our on-the-ground presence in the region during the mid to late 1990s served as a unique source of competitive advantage for our client. Based half a world away in New York, our client was able to focus their efforts on developing domestic sales while we spent countless hours investing the necessary time and effort in upfront face-to-face meetings with the management of Asian mill suppliers in order to develop their supply chain.
Results: Between 1995 and 2000, this new sourcing/distribution chain designed and paved by TSI Global Consulting, fueled new exports to our client in excess of four million dollars per year. Cost and freight (CNF) export prices from our middle market suppliers averaged 15-20% below prices offered by the large, well established Jakarta based mills whom our client and their competitors had been sourcing from since the 1970s. This new sourcing network gave our client a significant cost advantage relative to its competitors who had no access to TSI Global’s supply chain that had been built up over a period of years through investment in highly localized on-the-ground relationship building processes. Throughout the late 1990s, we replicated this model for several other American clients including a large South Carolina based home furnishings manufacturer.
Export Development and Foreign Market Entry Consulting
Our Mission: Working on behalf of a well established Indiana based manufacturer of household cleaning supplies currently marketed across the United States in major retailers including Wal-Mart, Target, Home Depot, Ace Hardware and Lowes, TSI Global Consulting was contracted to arrange a week long customized trade mission to Mexico City and Monterrey, Mexico for the firm’s senior management. Our client’s objective was to explore and develop product distribution in Mexico.
Our Research and Implementation Efforts: Along with partner organizations in both Mexico City and Monterrey, TSI Global provided turnkey organization of five intensive days of business development meetings with senior managers in the buying offices of lead Mexican retailers and distribution companies including among others Wal Mart Mexico, Organizacion Soriana, Casa Saba, Total Home, Gigante, Carrefour Grandes and Grupo Corvi.
Results: While Mexican distribution is an ongoing work-in-progress for our client, TSI Global’s path breaking customized trade mission has provided the company with a foothold in the Mexican market and several million dollars per year of potential new sales and distribution opportunities.
Other TSI Global Consulting Projects (in-country experience):
- Vietnam: Foreign Direct Investment (FDI) feasibility study for Greenfield plant (textiles)
- Indonesia (Sumatra): Foreign Direct Investment feasibility study (palm oil plantation)
- Dominican Republic: Product distribution (cotton textiles)
- Haiti: Construction machinery distribution
- Bangladesh: Product distribution and supply chain development (denim fabric)
- Thailand: Product distribution (textiles and apparel)
- Japan: Trade show turn-key management
- Hong Kong: Trade show turn-key management
- India: Supply chain development (cotton textiles)
- Indonesia: Export development seminars/consultative services
- Indonesia: Anti-dumping Advisory Services
- Indonesia: Negotiation of technology licensing agreements
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