- May 1, 2017
- Posted by: Mark Stevens
- Categories: Customs, Export Administration Regulations, ITAR, Trade Controls 2015
Trade compliance is not always about keeping the customer happy. Yes I agree, all businesses should strive to meet or exceed customer expectations. However if the customer’s needs lead to errors or omissions to the regulations, then the compliance officer needs to halt the transaction.
Never leave compliance solely up to your shipping company, you are responsible. For instance look at Access USA Shipping, they recently agreed to a civil penalty of $27,000,000. You can read the full document here: https://efoia.bis.doc.gov/index.php/documents/export-violations/export-violations-2015/1102-e2490/file
Read the the Settlement Agreement, it lists the number charges and the violations, for example: Charges 1-129 15 C.F.R. §764.(h) – Evasion.
When you are done, go to the actual regulation and read the entire section on violations, it might surprise those nay saying compliance offers who don’t think they should be 100% compliant: https://www.ecfr.gov/cgi-bin/text-idx?SID=ae111c83dad6dc06cc8d002f90b0a0ce&mc=true&node=se15.2.764_12&rgn=div8