A Michigan company has been ordered by the Bureau of Industry and Security (BIS) to pay $575,000 in penalties for improperly classifying items subject to Export Classification Control Number (ECCN) 9B106.a. The items are allegedly controlled for missile technology (MT) reasons and were exported on 20 occasions over three years to the People’s Republic of [...]
On June 7, 2016, two non-prosecution agreements were reached in FCPA cases. One agreement was reached between the Securities and Exchange Commission and a Massachusetts-based internet services provider, in the amount of $652,452 plus interest. The SEC’s investigation led them to a foreign subsidiary that used bribes to induce Chinese officials to purchase more services [...]
We have recently encountered several cases where, for one reason or another, importers did not apply for retroactive GSP prior to the December 28th deadline. We have thoroughly researched the issue and we believe that it is possible in many instances to successfully apply for retroactive GSP – even now. If you or any importers have missed [...]
Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRIs), and the Additional U.S. Rules of Interpretation explain that “(c) a provision for parts of an article covers products solely or principally used as a part of such articles but a provision for “parts” or [...]
On April 27, 2016, the Department of Justice announced that Z Gallerie LLC, an upscale furniture seller, has agreed to pay $15 million to resolve a False Claims Act suit alleging Customs fraud. The United States alleged that Z Gallerie engaged in a seven-year scheme to evade antidumping duties of imported wooden bedroom furniture from [...]
Customs and Border Protection (CBP) has been in the process of expanding the role that the Centers of Excellence and Expertise (Centers) play in the import process. The Centers are hubs of knowledge established by CBP that are in place to aid CBP address issues related to ten different industry-specific categories. For example, the Center [...]
The release of the so-called Panama Papers and the launch of a pilot self-disclosure program for Foreign Corrupt Practices Act (FCPA) have added to the flurry of activity related to the FCPA. The Panama Papers are voluminous set of leaked documents that detail the existence and contents of private offshore accounts. The Securities and Exchange Commission [...]
Both the House and Senate recently passed a bill which modifies the process for enacting miscellaneous trade bills. Notably, the bill revamps the process for considering duty suspension and reductions found in chapter 99 of the Harmonized Tariff Schedule of the United States (HTSUS.) The revamped process will involve United States manufacturers submitting petitions to [...]
Although the Cuban embargo is still largely in place, opportunities for businesses and individuals have expanded greatly in Cuba. Most recently, On April 22, 2016, the United States expanded the list of goods and services produced by “independent Cuban entrepreneurs” which may be imported into the United States. The day before, the Office of Foreign [...]
The International Trade Commission (USITC) gave notice announcing the institution of investigations on imports of certain carbon and alloy steel cut-to-length plate from Austria, Belgium, Brazil, China, France, Germany, Italy, Japan, Korea, South Africa, Taiwan, and Turkey. The products covered by these investigations include certain carbon and alloy steel hot-rolled or forged flat plate products [...]