Getting an A+ on Your AES Compliance Review
Jerry Greenwell, Ombudsman for the Census Foreign Trade Division, delivered an informative and entertaining session at the ICPA annual gathering recently. A few key points...
- Don't get confused by the lack of coordination between Incoterms and export regs etc. The only thing to understand is whether the export is buyer or seller-controlled.
- New on his presentation agenda...AES Compliance Review Program...help to avoid costly penalties and being sent to the principal's office, Office of Export Enforcement (ital added for emphasis).
- Best Practices to get an A+ on your compliance review...(I love this one), "Keep your contact data at the Census Foreign Trade Division up-to-date." Duh!
- Voluntary Self-Disclosure is also new...need to report a violation or potential violation? Score brownie points by self-disclosing.
- Routed export transactions (where the overseas buyer controls the movement of the cargo) are not good business practice.
- Option 4, post-departure filing is still under moratorium, "...and probabaly will not re-open..." (This is Jerry opinion.)
Jerry knows his stuff and is available for trainings for the cost of travel and a per diem. If you want to contact him directly call 301-763-6975 or e-mail him.

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