1. Import/Export Training
Managing the risks of Import/Export Activity
11/29/2018
L. Cvirko

2. Major Points Export/Import compliance Why, What , Where, Who and How
Antiboycott Compliance
Foreign Trade Zone (FTZ)
CTPAT
11/29/2018
L. Cvirko

3. Export/Import Compliance-Why?
Administrative:
-Fines
-Denial of Export/Import Privileges
-Exclusion from practice
-Seizure
Criminal:
-Imprisonment
11/29/2018
L. Cvirko

4. Export/Import Compliance-Why?
Exporting/Importing is a privilege not a right. Objective:
To ensure that we comply with the regulations from
U. S. Department of Commerce
U. S. Department of Treasury
U. S. Department of Homeland Security
11/29/2018
L. Cvirko

5. Export/Import Compliance-What?
ITAR (International Traffic in Arms Regulations)
Import -Commodities
Export - Commodities, technology, software
Is a license required to Export?
Currently all of our products are classified EAR99 No License Required (NLR)
11/29/2018
L. Cvirko

6. Export Compliance -ITAR
International Traffic in Arms Regulations
Even if customer is not export if they have a ITAR controlled product you cannot pass technical data, previously sent to you or technical data that may be sent to you in the future to a foreign person or country without prior approval from the U. S. Department of State.
11/29/2018
L. Cvirko

7. Export Compliance-Where?
U. S. Embargoes apply to
-Exports from U.S.
-Exports and re-exports by U.S. foreign subsidiaries.
Cuba, Iran, North Korea, Sudan, Syria
11/29/2018
L. Cvirko

8. Export Compliance-Who?
Proscribed parties
High Diversion Risk
-Chemical/Biological warfare
-Nuclear
-Missile technology
Proliferation concern questionnaire must be on file before a order can be shipped. It needs to be completed only one time.
11/29/2018
L. Cvirko

9. Export Compliance-Who?
Red flags ( Know your customer)
-Customer is unknown
-Person with street address requesting 1 or 2 pieces.
-Reluctant to provide end-use or end-user information
-Ordered items not compatible with end-user’s information.
11/29/2018
L. Cvirko

10. Export compliance Red Flags
The customer has little or now business background.
A foreign exchange college student
A freight forwarding firm is listed as the product’s final destination.
11/29/2018
L. Cvirko

11. Export Compliance Anti-boycott Clause
-Indicates agreement to boycott anything to do with Israel.
-Usually buried inside the letter of credit terms. -
11/29/2018
L. Cvirko

12. Export Compliance-How?
It is a corporate responsibility
-Policy
-procedures
-System generated documentation
-Audit trail
-Ultimate destination clause in EDI contracts, quotes, commercial invoice
-Compliance training
11/29/2018
L. Cvirko

13. Export Compliance How do we ensure that we are not at risk?
. Manual on web site with hyperlinks to detailed procedures.
. Training including Outside Sales, Inside Sales, Engineering, Marketing, MIS, Accounting, Quality, Shipping.
11/29/2018
L. Cvirko

14. Export Compliance How do we ensure that we are not at risk?
. Manual on web site with hyperlinks to detailed procedures.
. Training including Outside Sales, Inside Sales, Engineering, Marketing, MIS, Accounting, Quality, Shipping and Purchasing.
11/29/2018
L. Cvirko

15. EXPORT COMPLIANCE Your Export Control Compliance Officer is
Dawn Dooley, , Ext 430
Any time you have a question please call
11/29/2018
L. Cvirko

16. Import Compliance Our CDM FTZ was Activated September 1
Kelly Holliday , FTZ Manager
Brandy Rogers, FTZ Manager Alternate
It will save $500K on foil duties annually.
11/29/2018
L. Cvirko

17. Import Compliance C-TPAT (Custom Trade Partnership Against Terrorism)
-Homeland Security effort to maintain effective security through the global supply chain via a joint government-business initiative .
-Not participating will lead to increased scrutiny of inbound shipments and increased clearance time through customs. -
11/29/2018
L. Cvirko

18. Import Compliance C-TPAT Continued -Requires -Application
-Self- assessment of security guidelines developed by Customs and the trade community.
-Documentation from suppliers of security guidelines. -
11/29/2018
L. Cvirko

19. Import Compliance -CTPAT
We are not registered at this time.
If you get a request please send to Kelly Holliday , , Ext. 332
11/29/2018
L. Cvirko