President Obama and the administration are moving full steam ahead to normalize bilateral relations with Cuba. On October 17, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) amended the Cuban Assets Control Regulations (CACR) and the Export Administration Regulations (EAR), respectively, to ease sanctions related to scientific collaboration, humanitarian activities, trade and commerce, and travel. Consistent with President Obama’s policy directive in December 2014 to chart a new course with respect to U.S.-Cuba relations, these amendments are aimed to create new opportunities for collaboration and commercial opportunities for Cubans and Americans. Specifically, new general licenses and authorizations were added to the regulations to allow for such transactions. Significant highlights are noted below.
You’ve worked out your classification strategy and your budget. Now it’s time to prepare. What does that entail? What information is required to conduct a comprehensive, efficient and accurate export classification project? How should the data be organized? These are important questions that will affect the success and timeliness of this critical compliance initiative.
Topics: Commodity Classification
Just as the summer heat cools, so too have activities at the West Africa Regional Training Center (WARTC) after a busy summer schedule. Since its inception in 2012, approximately 3,399 Law Enforcement professionals have passed through the halls of the WARTC. An important pillar of the West Africa Cooperative Security Initiative (WACSI) is to facilitate lasting relationships to buttress the future impact of our programming. For this reason, CTP actively invests in employing Alumni Coordinators to foster connections formed while at the center. One of the outreach tools to facilitate collaboration and information sharing among participants is the Alumni portal found on the WARTC website. Over the past several years, WARTC staff has engaged alumni through daily emails and via a monthly newsletter featured on the West Africa Regional Training Center website (www.westafricartc.org), which has paid great dividends for the program. We are elated to hear stories of cross border collaboration leading to successful investigations and the resolution of cases, as a result of connections made while at the WARTC. We would like to highlight the invaluable contributions of one WARTC staffer, Ms. Sarah Dadson who recently departed to pursue a master’s degree at New York University. Sarah kept alumni activities up and running during a staffing gap and her contributions were key in helping to double the staff handling alumni coordination activities. We wish her the very best in her future endeavors and hope our paths may cross again.
Commodity classification is critical. In fact, we call it Job #1 since most of your compliance requirements are based on these determinations. But classification projects are not all the same. Most companies use the “surge” approach, tackling the entire inventory all at once, be it dozens, hundreds or thousands of items. Other companies, for various reasons, can’t process everything at once and must rely instead on the “flow” method of classifying items only when they enter the Order Processing system. Both are valid and effective methods, giving companies the licensing requirements they need, but to help you pick your strategy, we’ll walk you through the pros and cons of wholesale “surge” classification versus the “flow-through” basis.
On August 17, 2016, the Bureau of Industry and Security and the Department of State published final rules (here and here) to harmonize the Destination Control Statement (DCS) required under §758.6 of the Export Administration Regulations (EAR) and §123.9 under the International Traffic in Arms Regulations (ITAR) respectively. As part of Export Control Reform (ECR) efforts, the agencies have sought to harmonize regulatory provisions that are intended to achieve the same purpose. The DCS is one example of an area where interagency coordination should reduce the burden on exporters.