TradeLane

The passage of the Trade Facilitation and Trade Enforcement Act of 2015 (signed in February 2016) seems to have prompted a renewed effort by CBP to enforce regulations regarding the importation of “Merchandise Produced By Convict, Forced, or Indentured Labor.”  We have seen many instances over the last few weeks where importers have received CF28s asking about steps the importer has taken to ensure that their supply chains are free of child, forced, or convict labor.  Some of the demands are exceedingly broad:

If you are being attacked by a stronger opponent, sometimes you need a strong shield. Korea Customs is such an opponent with all the power of the government behind them, how can importers protect themselves?  

One defensive shield available is the ‘ACVA’ program.

Ah, summer!  Fun, sun, smuggling, and conflict minerals. Around this time last year, a Chinese-owned gold mining company was gifting cash and guns to local militias, while at the same time smuggling approximately $17 million of gold out of the Democratic Republic of Congo (DRC).

If you happen to be reading this on a mobile device, you currently have gold embedded in an electronic circuit right beneath your fingertips…

 Most exporters of technology products have learned in the past, either through good corporate governance or a knock on the door by their local export control enforcement authority, that encryption is a sensitive subject (pun intended).

Within the European Union, most items incorporating encryption are classified as dual-use goods (when not Military items) and are subject to Export Control.

Within the EU, French authorities extend control of encrypted items beyond the export process to import as well.  Cryptographic items can move freely within French territory. However, supplying, importing, or exporting encrypted items are regulated activities.

I originally wrote this blog back in 2013 and it’s as important now as it was then. The landscape has changed a little, with NAFTA now front and center, but good trade compliance is still good business!

When your organization is faced with compliance issues that never seem to go away, an objective review by a third party may allow your company to focus on the aspects of the business that you do best. Importers and exporters are held accountable for compliance with Customs requirements, and must use “reasonable care” in their international trade processes.

What does this mean, and how do you know when it’s time to engage a trade compliance expert?