U.S. Foreign-Trade Zones Support Import Compliance, Cargo ... · Compliance, Cargo Security and Lean Logistics Corporate Initiatives By Brandi Hanback The Rockefeller Group The job

MANAGING IMPORTS & EXPORTS

FEBRUARY 2010 www.compliancemaven.com

ISSUE 01-11 WWW.COMPLIANCEMAVEN.COM FEBRUARY 2010

ALSO IN THIS ISSUE....U.S. Foreign-Trade Zones Support Import Compliance, Cargo Security and Lean Logistics Corporate Initiatives continued..............................2, 3Ask The Experts..............................................................4Writing Trade Compliance SOP’s...Where is itBest to Obtain Assistance?............................................5Routed Exports - Two Areas not Typically Considered...................................................................6, 7Additional Reporting Requirements Underthe EAR.........................................................................7, 8Valuation Determination for Sample Shipmentsand Non-Purchased Goods.......................................8, 9The Importance of Record Keeping......................9, 10PACMAN Annual Meeting.........................................11Import-Export Managers’ Calendar.....................12, 13Upcoming Educational Seminars...............................14Website Feature of the Month.....................................15

U.S. Foreign-Trade Zones Support Import Compliance, Cargo Security and Lean Logistics

Corporate Initiatives

By Brandi HanbackThe Rockefeller Groupwww.rgftz.com

The job of a trade compliance manager is often a thankless role, compounded by current challenges in a strained economy of getting companies to invest in initiatives such as compliance and cargo security. If there appears to be no tangible positive impact to the bottom line, the threat of fines, penalties and delays (the frequent tools of compliance managers) find little favor or are put off in favor of ever existent more urgent priorities.

Foreign-trade zones (“FTZ’s”) offer a creative ap-proach to the problem by saving the company money while integrating trade compliance into business operations and supporting streamlined international supply chains.

There are many ways to save money through use of FTZ’s and, thanks to some new initiatives by the U.S. Foreign-Trade Zones Board, getting an FTZ can be faster and less costly than in the past. For compa-nies engaged in site selection for a new facility, there are many existing FTZ locations in key industrial markets for consideration.

In terms of FTZ trends, liberalization of trade in certain industries such as the textile quota phase-out, have opened up new opportunities to industry

sectors that are associated with relatively high import duties and traditionally have not been able to take full advantage of FTZ’s.

The first step is to quantify the opportunity. Saving money in an FTZ involves duty deferral, reduction and/or elimination. Instead of paying import duty when a shipment arrives and clears a United States port of entry, duty payment is deferred until the mer-chandise is withdrawn from the zone for consump-tion in the United States.

CONTINUED ON PAGE 2



FTZ’s are secure areas requiring physical security as well as access and inventory controls. Most modern operations have the necessary security already in place as part of Customs-Trade Partnership Against Terrorism (“C-TPAT”) processes or to protect em-ployees and merchandise. As such, FTZ’s comple-ment and support secure supply chains. Partici-pants in C-TPAT should know that U.S. Customs and Border Protection recognizes use of U.S. FTZ’s as a C-TPAT best practice.

For trade compliance managers looking for a carrot instead of a stick to get corporate and operations personnel on board, FTZ’s may provide a win-win.

CONTINUED ON PAGE 3

2

U.S. Foreign-Trade Zones continued…In a distribution environment, merchandise from over-seas may be deconsolidated and inspected and in some cases, repairs, repackaging, labeling and marking may be performed in the FTZ to prepare the goods for final sale.

Many companies choose to use the FTZ program to support a location in the United States as a global re-gional hub, supplying the U.S. market as well as other smaller markets in the broader region. For products exported out of the FTZ, import duty is eliminated entirely replacing administratively burdensome and costly drawback programs or money simply left on the table due to lack of coordination between import and export transactions. Companies also eliminate duty in FTZ’s by creating an interim inspection point where goods determined to be unsaleable are either returned to the vendor prior to Customs entry or destroyed in the FTZ.

For those companies that manufacture, assemble, process and even kit in an FTZ, duties may be further reduced. With proper authorization from the U.S. Foreign-Trade Zones Board, importers may elect to pay duty at the lower rate of a finished good when applicable, as compared to the higher rate of imported components. FTZ’s encourage value added activity in the United States by equalizing the duty treatment that foreign producers receive when importing finished goods from abroad. While FTZ users may qualify for a lower duty rate, the foreign value remains the same because importers do not have to add the value of any U.S. labor or domestic inputs applied in the FTZ.

In addition to duty savings, FTZ usage as part of an integrated supply chain strategy can result in lower inventory levels and expedited movement of goods to and from the zone. Direct delivery provides for import-ed shipments to move in bond directly from the port of unlading to a U.S. manufacturing or distribution facility. By not undertaking Customs entry at the time of arrival, certain types of delays associated with entry documentation reviews can be eliminated, although all advance manifest data requirements still apply and all merchandise is subject to cargo security reviews.

Outbound, FTZ users may qualify for weekly entry procedures allowing for one weekly entry summary for all goods shipped from the FTZ over a seven day

period. For high volume, 24/7 operations, weekly entry equates to flexible and just in time delivery schedules to customers as well as fewer Customs entries. Delaying and reducing the number of Customs entries can reduce administrative savings in the form of Customs broker filing fees and mer-chandise processing fees. By filing Customs entries after goods have been physically received, verified and shipped, importers find that FTZ’s support their Customs compliance efforts by allowing for more accurate Customs reporting and reduced post entry adjustments and amendments.

Companies can also position themselves to real-ize FTZ benefits throughout the supply chain for inventory moves between facilities using zone-to-zone transfers. Transfer of title can be performed in an FTZ, providing flexibility in support of vendor managed inventory strategies. For new or expanded capital investments in the U.S., certain FTZ benefits also apply to imported production equipment for use in the zone. Given the high value and extended timeframe for shipping, assem-bly and testing of production equipment associated duty benefits can be significant.

Some of the best news about FTZ’s for importers is that FTZ’s are flexible and operationally feasible. For most companies, implementation of an FTZ means little or no operational changes. For exam-ple, foreign and domestic merchandise can be com-mingled so products can continue to be stored by SKU if record keeping and reporting processes sup-port product identities. Record keeping approaches such as First-In, First-Out by SKU optimize deferral savings and keep floor operations efficient.


FEBRUARY 2010 www.compliancemaven.com 3



4

Ask The ExpertsMIE’s ‘Ask the Experts’ team -- Kelly Raia, Vice President & Senior Consultant, Randi Keenan, Assistant Vice President and Senior Consultant and Sarah Reynolds, Senior Consultant, all from The World Academy -- answer readers’ import or export related questions. This month’s column is by Sarah Reynolds and Kelly Raia. Readers may submit questions to [email protected] -

Question: If I am exporting an item classified as EAR99, do I have to worry about my customer overseas re-export-ing the item? If so, how would I be able to control that process?

Answer: If your item is EAR99, meaning it is not found on Commerce Control list (CCL) and not regulated by an Export Control Classification Number (ECCN), the controls placed on EAR99 items by the Bureau of Industry and Security are not as strict as they are for items found on the CCL. For items found on the CCL, re-exports are controlled and the end use and end user should be disclosed to the USPPI for their review and discretion prior to export. An item may not be licensable to the first country of export but may be licensable to the country it is re-exported to. For controlled items it is the responsibility of the USPPI to be aware of these possibilities and to put controls in place to minimize this type of compliance exposure by obtaining an end user certificate for one. For EAR99 items, the Bureau of Industry and Security concerns regarding national security are not as great however; they are concerned with these items being exported to an embargoed country or to an individual or entity on the denied parties list

Under Export Administration Regulations Part 758, for items that are found on the CCL, it is mandatory that the desti-nation control statement be entered on the invoice and on the bill of lading, air waybill or other export control docu-ment that accompanies the shipment from its point of origin in the U.S to the ultimate consignee or end user abroad. I recommend utilizing this statement for EAR99 items also so that the consignee is aware that they must comply with U.S. regulations and that diversion contrary to U.S. law is prohibited such as re-exporting an EAR99 item to an embar-goed country. Depending on the volume of your exports and if it is manageable, I also recommend asking your cus-tomer to confirm that they are the ultimate consignee and end user of your product. This way you are able to supervise and control the export process to the best of your knowledge.

Question: Our company provides a service on a part. Basically we drill a hole into metal. Our customer is asking us to provide a NAFTA Certificate of Origin for the part? I’m uncomfortable with this as we’re not the manufacturer. What’s your take on this?

Answer: I totally agree with you. If you are not the manufacturer, how do you “have knowledge” the part qualifies for NAFTA. Additionally, you are not privy to much of the information. Maybe your customer’s supplier bought it from out of the country! Follow your instincts.



By Neil Lenok

Now that 2010 is upon us, some individuals with trade compliance responsibility may have given themselves a professional New Year’s resolution of implementing SOP’s (Standard Operating Procedures) for their companies. If you are one of these individuals, or perhaps you have been charged by senior management to write SOP’s, I’d like to offer some guidance on how best to proceed.

Implementation of specific import and export trade compliance SOP’s can mitigate and hope-fully prevent problems (i.e. fines/penalties) that you may have in the event of a CBP or BIS audit. Just by having compliance SOP’s in place for you import and export operations (prepared by a company recognized by CBP or BIS as an expert in the field), and being able to present these to CBP or BIS during a random audit, may be helpful in reducing the time government audi-tors stay at your facility. This is an important component of proving to the government you are meeting your requirement for due diligence and reasonable care standards. These SOP’s need to be in “lay man” terms so they can be followed by all personnel involved in the import and export process… from sales, to order entry, to shipping and customer service. It is also important to offer training to all personnel involved in the sup-ply chain on these newly implemented SOP’s to ensure everyone understands the importance of them and the consequences for not adhering to them.

There are many qualified consulting companies and law firms that specialize in assistance with implementation of SOP’s. When seeking a com-pany for this type of assistance, it’s always best to find a company that offers a complete “turn key operation”. What I mean by this is you want to hire a company that will identify weak areas in regard to trade compliance in your entire sup-ply chain operation through an audit process or “Facilities Review”. The firm should then be able to develop SOP’s to address these “weak areas” and put together an action item plan addressing the hot issues (30 day action items, 60 day, etc.) all the way to areas that can be addressed over a

6 -12 month period. The firm should stay involved in the process of implementation of the SOP”s, and facilitate training and education among the staff to ensure all personnel understand why these SOP’s have been developed.

You may also want to identify a company that can as-sist with technology solutions as part of these SOP’s. As an example, one of the SOP’s may be the need to perform a Denied Party search on all export ship-ments. If the firm you have hired to assist with the SOP’s can also offer a software solution in this area, it can be very beneficial and cost effective as you will have negotiating leverage in the other areas the company can offer you if you are utilizing several of their services. You might even select a consulting company that offers freight forwarding services and you can “trade” off freight business for other ser-vices. This is a real benefit, as you need to utilize a freight forwarder anyway, so being able to barter for other services can be most cost effective (especially in consideration of the difficult economy).

There are also a number of government websites that can be helpful in obtaining information in this area… such as the BIS website at http://www.bis.doc.gov. On the BIS website there is also an option where you can be directed to the Export Manage-ment System to help you with export compliance issues. The website address is http://www.bis.doc.gov/forms/emsinquiryform.html.

It is also important to work with a company that does not make you feel like a small fish swimming in the ocean. There are many mid-size consulting or legal firms that can assist with writing and imple-menting SOP’s. While you may have been sold on this service from a principal from one of the major consulting or law firms, you need to find out who will be on the team doing the work for your com-pany. You want to ensure the team or individual working on this project for you has experience in the field and is not some rookie just out of school.

If you are interested in looking for qualified com-panies to assist in the writing of compliance SOP’s, please contact the PACMAN association at [email protected] for a listing of companies rec-ommended by industry professionals.

Writing Trade Compliance SOP’s...Where is it Best to Obtain Assistance?



6

By Randi Keenan

As most of us know, a routed export is where the Foreign Principal Party in Interest (FPPI) chooses the U.S. Freight Forwarder/agent to move a ship-ment overseas. In a routed export transaction, the U.S. Freight Forwarder is responsible for filing EEI/AES.

Most of us are also aware of the risks associated in a routed export transaction. The main risk is that you relinquish control over your shipment at the point in time when you tender the shipment to the forwarder/agent acting on behalf of the FPPI. And, as most of us are aware, this is especially concern-ing when the shipment is covered under an export license.

While there are many obvious risks associated with routed exports, there are two areas that are not typi-cally considered when agreeing to routed transac-tions with the customer overseas. The first area of concern is related to the INCOTERM agreed to for that transaction, and the second area of concern is for HAZMAT shipments.

First, let’s look at how the Incoterm affects a routed export transaction. Assume you are shipping to a customer overseas, and you both have agreed on a routed export transaction with the Incoterm be-ing FOB Houston port. Under the FOB Incoterm, the seller is required to clear the goods for export. Clearing goods for export includes the filing of AES. This is a direct contradiction to what con-stitutes a routed export transaction. So, the next question becomes…how is this type of transaction handled in a way that it protects the USPPI (US Principal Party in Interest…or the company in the USA that will receive the primary benefit of the export transaction, monetary or otherwise)? The answer will vary depending on many factors such as your relationship with the FPPI, your ability to file AES, or your trust in the forwarder or agent be-ing used by the FPPI…to name a few.

The two most practical ways to handle this would be to either (a) Do all possible to control the export by not agreeing to a routed export transaction; or (b) Incorporate wording in the contract of sale to include verbiage that deviates from the Incoterm. Since Incoterms are not “regulations/law” and are merely rules to conduct international business to ensure everyone is on the “same page”, it is permit-ted for either party to request to the second party to amend the responsibility and liability of a chosen and agreed to Incoterm. If you choose option (b), the express wording must be agreed to by the for-eign buyer (FPPI), in writing. The wording should clearly represent the specific areas agreed to that deviate from the Incoterm being used in the trans-action. The issue of Incoterm vs. Routed Exports (and real-ly any export transaction) must be looked at closely to ensure the USPPI can meet the requirements of their responsibilities and liabilities under the cho-sen Incoterm and the chosen transaction type.The second issue we need to look at pertains to international routed exports of commodities that are considered Dangerous Goods or Hazmat. Since 9/11, the U.S. DOT (PHMSA) has added a compo-nent to the hazmat regulations regarding the secu-rity of hazmat shipments. Obviously, some types of hazmat pose a great threat to our country if in the hands of a terrorist minded person or persons. Because of this inherent risk, many companies are required by law to prepare and adhere to a writ-ten “Hazmat Security Plan”. The plan must detail security procedures for all parts of the supply chain (domestic or international). The procedures must be given to employees in the form of training. The procedures incorporate details on truck routes and use of carriers among other criteria.

Based on this requirement, we can now bring this back to routed exports. As mentioned previously, when engaged in a routed export transaction, the USPPI typically loses control of the shipment once it is tendered to the FPPI agent or freight forwarder in the USA. If you are adhering to a hazmat plan, you must be sure your written security plan incor-porates control of hazmat shipments in a routed export.

The risk would be this: You have a written secu-rity plan outlining all your procedures on how you keep your hazmat shipments out of the hands of those who intend to do harm. If you turn over your shipment to a freight forwarder acting on behalf of

CONTINUED ON PAGE 7

Routed Exports - Two Areas not Typically

Considered...



Editorial Advisory Board

Marilyn-Joy Cerney, Esq. Gerry Doyle Robert Core Marie Cabral Attorney Attorney Foreign Trade Zone Mgr Imp/Exp Compliance Dir Cerney Associates, PC Doyle & Doyle L’Oreal USA America II Electronics, Inc. Kay Georgi Thomas A. Cook Karen West Lydia Moya-Kiste International Trade Attorney Managing Director CEO Imp/Exp Compliance Mgr Washington, DC Office American River Int’l Earth Customs Inc. Unipart Services America (Export Controls/Trade Remedies) Earth Cargo Inc. Partner, Arent Fox PLLC Jerina Barutis Customs Attorney

an FPPI, and the shipment is stolen…or worse…it is the cause of damage or death, the DOT will be looking closely at your plan to see where it failed. If you fail to incorporate this aspect of risk into your security plan, you could be severely penalized for an inadequate security plan. Moreover, the bad press would not be a good thing.

These are just two of the frequently overlooked aspects of agreeing to a routed export transaction. As with any compliance topic or issue, DUE DILLI-GENCE is a key to keeping you above water in this turbulent ocean of compliance. Be sure you know all the little “nooks and crannies” of whatever terms you are agreeing to in your transaction. Be sure to evalu-ate all of your responsibilities and liabilities before signing on the dotted line.

For further information on this subject, please contact Randi Keenan at [email protected].

Routed Exports...continued...

By Kelly Raia

So your company is exporting products that fall under a specific Export Commodity Control Number and may require an export license. You check out the available License Exceptions on the Commerce Control List and review the specific requirements under 15CFR740. You luck out on this one, as your product quali-fies for a license exception to your customer’s destination country. You prepare your letter of instruction for your forwarder, including, of course, the applicable ECCN and license exception. You hit the send button and proudly check that shipment off your to do list.

But wait…did you read the small print…you know that nasty little italicized section of the License Exceptions that lists “additional report-ing requirements of 743”? Yes, that small print does matter. The usage of certain License Ex-ceptions requires additional reporting require-ments.

The additional reporting requirements specifi-cally refer to the Wassenaar Arrangement. “The Wassenaar Arrangement was established to contribute to regional and international

CONTINUED ON PAGE 8

Additional Reporting Requirements Under the

EAR



8

Valuation Determination for

Sample Shipments and Non-Purchased Goods

Additional Reportingcontinued…

security and stability, by promoting transparency and greater responsibility in transfers of conven-tional arms and dual-use goods and technologies, thus preventing destabilising accumulations” according to the Wassenaar website. http://www.wassenaar.org .

The participating countries of the Wassenaar Ar-rangement are:

Argentina, Australia, Austria, Belgium, Bulgaria, Canada, Croatia, Czech Republic, Denmark, Esto-nia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Japan, Latvia, Lithuania, Luxem-bourg, Malta, Netherlands, New Zealand, Norway, Poland, Portugal, Republic of Korea, Romania, Russian Federation, Slovakia, Slovenia, South Af-rica, Spain, Sweden, Switzerland, Turkey, Ukraine, United Kingdom and United States.

15CFR743.1 specifically outlines which ECCNs exported under License Exceptions require such reporting. Each Commerce Control List Category has ECCNs requiring such filing.

Wassenaar Reporting under the EAR, requires two copies of the following information to be submit-ted:

• ECCN and paragraph reference• Number of units in the shipment• Country of ultimate destination

These reports must be made on a semi-annual ba-sis. General information concerning the Wassenaar Arrangment and reporting obligations is available from the Office of Strategic Trade and Foreign Policy Controls: 202-482-0092.

So remember, before you cross that export off your to do list, make certain you don’t have to add in your semi-annual reporting!

By Rennie Alston

The supervision and control of proper import declared values related to imported shipments are a very important aspect of any international trade compliance program. CBP is tasked with ensuring proper valuation and classification of imported products in their efforts to protect the revenue of the United States, while enforc-ing supervision of the compliance reporting of statistical data. Many importers have embraced the compliance requirements related to value by monitoring their purchase order unit values and ensuring that those values are consistent with import declarations at the time of entry. Further supervision and control efforts also ensure that the purchase price and declared values also match the price paid by the U.S. entities finance department related to the imported merchandise. There exists however, a large segment of the international trade arena that does not show the same level of supervision and control related to valuation management when the imported articles are sample shipments or non-purchased goods.

Many importers rely on industry common practices with the implementation of arbitrary values such as the infamous $10 sample value as an acceptable practice. Past and common prac-tices when using such arbitrary values, have worked and many international trade partici-pants believe that $10 is the standard reporting value for samples. The truth is that these articles are non-purchased items that are merely sent to the U.S. in the absence of a sale. The acceptance of this valuation concept could not be further from reality or from the truth. CBP does not have any valuation exemption standards for non-pur-chased items or sample merchandise. CBP relies on the methods of valuation to determine import

CONTINUED ON PAGE 9



values during the liquidation process for purchased and non-purchased items. CBP also expects import-ers to use the cited methods for valuation, referenced in Customs Federal Regulations Title 19 part 152 for determination in their individual compliance profiles. Accepting a nominal value that is put on the invoice by the foreign shipper is a non-compliant practice.

The common practice reason for indicating nominal values on imported samples shipments is to minimize the duty application on imported articles. This is also a non-compliant practice. There exist several types of entries that will result in a duty free importation for samples and non-purchased items regardless of value. It is imperative that valuation determination be included in the informed compliance realm of each trade participants education and training curriculum.

In Focused Assessment Audits performed by Customs and Border Protection, it is commonly reviewed as to how your company handles sample shipments. Valu-ation determination is a common inquiry in local port inquiries distributed on Customs Form 28 request for information. Proactively address this common issue of non-compliance, and avoid costly fines and penal-ties for under valuation and throwing off import trade statistics. It is recommended to incorporate informed compliance efforts and follow up with the establish-ment of written procedures to address the manage-ment and supervision of valuation determination.

Valuation Determinationcontinued…

By Sarah Reynolds

Whether you are an importer, exporter or service provider, record keeping is a critical component of any compliance program. Regardless of what our role is within the international supply chain, it is our obligation to comply with U.S. import and ex-port controls, and that control includes the require-ment for record retention.

For shipments imported into the commerce of the United States, the record retention requirement under CFR Title 19 Part 163 is five years from the date of entry, and for exports, including re-exports, it is five years from the date of export or expira-tion of an export license, as regulated by the Export Administration Regulations and the International Traffic in Arms Regulations. The applicable gov-ernment agency would depend on the nature of the shipment.

Failure to keep proper records could result in fines and penalties for many reasons. For instance, under Customs regulations CFR Title 19 Part 163, pen-alties may be assessed for negligence or willful failure to keep records. These penalties could be quite substantial and in the area of anywhere from $10,000.00 to $100,000.00 depending on the viola-tion.

Proper record keeping is a protection plan for the importer, exporter and service provider. Without being able to produce records upon demand by a U.S regulatory agency, how would one be able to provide a defense or demonstrate compliance? If an import or export shipment is under inquiry by a government agency, proper record keeping would provide evidence of how a transaction was handled and substantiate the steps that were taken in order to ensure compliance with U.S rules and

CONTINUED ON PAGE 10

The Importance of Record Keeping



10

regulations, such as denied party screening, obtaining an end user certificate and classification of an product, just to name a few.

Record keeping is the foundation on which a compli-ance program should be built upon. Measures should be put in place to capture the documentation and events that take place throughout a transaction com-mencing with the initialization of an order through to delivery and payment. Whether your transaction is an import or export, these measures and record retention regulations need to be taken into consideration and do apply to your international transaction.

Compliance management is critical these days as the government agencies are out in full force enforcing the rules and regulations, and all parties to the transaction; the importer or exporter, freight forwarder, customs broker and carrier, fall under this scope of enforce-ment. One transaction, depending on its nature, may be under the scope of more than one government agency. A licensable, hazardous materials export transaction may be regulated either by the Bureau of Industry & Security, Department of State or Treasury, depend-ing on the type of commodity or license required, the Department of Transportation and U.S Customs. All relative documentation must be retained and provided upon demand, if so requested, by any one of these government agencies.

A successful compliance program is one that does not limit record keeping solely to the documentation of a transaction, but one that includes the implementation and maintenance of written standard operating proce-dures, documented training and education, all mitigat-ing factors, and a demonstration of due diligence and reasonable care.

The personnel involved in the international supply chain must receive training relative to their responsi-bilities and that training must include the importance of record retention. Understanding the importance of each document relative to the transaction as it pertains to U.S. regulatory requirements and the individual’s role within the supply chain link, provides a height-ened awareness of the uniformity needed in order to achieve and maintain a successful record keeping program within the organization.

A transaction may include the involvement of many departments within a company such as; purchasing, sales, customer service, shipping and receiving, and without the support and compli-ance of all parties concerned, proper and complete records cannot be maintained.

The records of a freight forwarder, customs broker and carrier also play a critical role to the transaction. If a transaction is being queried by a government agency, chances are the freight forwarder, broker and carrier will be brought into the scenario either by the government agency or the customer (importer or exporter) requesting as-sistance in the form of providing possible missing documentation on their side, or for guidance in the recollection of the circumstances that trans-pired during the course of the transaction. Proper record keeping on the part of the service provider will greatly assist the customer in their time of need and will certainly be expected of the service provider by the customer. Freight forwarders, customs brokers and carriers are also susceptible to fines and penalties and held accountable to comply with U.S. rules and regulations.

Best practices for a successful record retention program should include:

• Training and education• Checklists to ensure inclusions of all required

documentation prior to closing a file• Paying attention to detail• Documenting pertinent information relative

to the transaction• Providing and obtaining instructions in writ-

ing• Records maintained in an organized manner

and stored in a designated area • Written standard operating procedures ad-

dressing record retention

A company cannot afford to underestimate the im-portance and need for complete and proper record retention. It is best to be proactive, rather than reactive, as being reactive could be quite costly taking into consideration the fines and penalties being imposed for non compliance with U.S. rules and regulations. Taking proactive steps to ensure compliance can be comparable to an insurance policy that one hopes never to have to make claim against. Therefore, set up those policies and pro-cedures and get filing!

Record Keepingcontinued…



The Professional Association of Import/Export Compliance Managers In Association with The World Academy announce their:

Annual Educational Conference

May 12-13, 2010

Marriott Newark Liberty International AirportNewark, NJ

The Professional Association of Import/Export Compliance Managers, in association with The World Academy, present a conference to emphasize the need for you and your company to become serious about import/export com-pliance and global security management.

Wednesday, May 12, 5:30 pm - 7:30 pm: Registration and Welcome Reception – An opportunity to meet and net-work with industry leaders.

Thursday, May 13, 9:00 am - 5:00 pm: A Full day of programs and panels. Hear from U.S. Customs, BIS, FDA and Industry Experts about managing a compliant and secure global supply chain. You will also have an opportunity to present your questions or concerns during the afternoon question and answer session.

$195.00 for PACMAN Members and $295.00 for non-PACMAN Members

Don’t delay – register today!!

For further details and registration information, please visit the PACMAN website: www.compliancemaven.com, The World Academy website: www.theworldacademy.com or call 1-877-PACMAN8

or 1-877-265-0070.



12

Contact:www.theworldacademy.com

Email: [email protected]

Advanced Import/Export Operations, Documentation & Compliance Management

March 1-2, San Jose, CAApril 12-13, Newark, NJ June 22-23, Detroit, MI

Best Practices in Managing Export Licensed Transactions: A Workshop for Brokers & Forwarders

February 26, Los Angeles, CA May 14, Newark, NJ

C-TPAT Certification Training Workshop

February 9, Orlando, FL April 14, Newark, NJMarch 3, San Jose, CA June 10, Chicago, IL

Drawback Workshop

April 13, Newark, NJ June 22, Chicago, IL

Establishing Import/Export Compliance Procedures

March 22-24, Newark, NJ May 17-19, Newark, NJ

Hazardous Materials Training

Marcvh 24-25, Newark, NJ

How to Ship Lithium Batteries by Air

February 12, Orlando, FL March 26, Newark, NJJune 21, Detroit, MI

Importer Security Filing (ISF) Compliance & Related Global Management Security Procedures

February 8, Orlando, FL March 4, San Jose, CA

INCOTERMS and Related Global Trade Issues

February 11, Orlando, FL April 16, Newark, NJ March 5, San Jose, CAJune 11, Chicago, IL June 25, Detroit, MI

Letters of Credit

April 19, Newark, NJ May 27, Newark, NJ

Managing HTS (Harmonized Tariff Schedule)

February 10, Orlando, FL April 15, Newark, NJ June 24, Detroit, MI

PACMAN - Import/Export Compliance Certification Workshop & Exam

February 25-25, Los Angeles, CA May 11-12, Newark, NJMay 13, Newark, NJ (Annual Meeting)

IMPORT-EXPORT MANAGERS’ CALENDAR



IMPORT-EXPORT MANAGERS’ CALENDARMarch - June, 2010 Webinar Schedule

**ALL WEBINAR TIMES ARE EST**

March 8, 2:00 pm - 3:00 pm

Record retention management and production upon demand for importers and exporters

March 15, 2:00 pm - 3:00 pm

Preparation for Focused Assessment Audit

April 5, 2:00 pm - 3:00 pm

HAZMAT General Awareness Training (certificate received for general awareness functions only)

April 30, 2:00 pm - 3:00 pm

C-TPAT Revalidation

May 10, 2:00 pm - 3:00 pm

Exporting to Sanctioned Countries

May 24, 2:00 pm - 3:00 pm

ISF compliance management "Are you prepared to manage the total ISF Compliance responsibility as an Importer?"

June 21, 2:00 pm - 3:00 pm

Compliance overview for senior management - addresses all compliance issues in an overview format for senior man-agement

June 28, 2:00 pm - 3:00 pm

How to manage international trade compliance risks in a routed transaction

Contact:www.theworldacademy.com

Email: [email protected]



14

Upcoming Educational Seminars --

BIS: www.bis.doc.gov

February 22nd-23rd Export Control Forum Irvine, CAMarch 2nd-3rd Complying with U.S. Export Controls Arlington, VAMarch 4th Encryption Controls Arlington, VAMarch 9th-10th Complying with U.S. Export Controls Chicago, ILMarch 11th How to Develop and Export Mgmt and Compliance Program Chicago, ILMarch 18th-19th Complying with U.S. Export Controls Del Mar, CA

American Management Association (AMA): www.amanet.org

February 17th-19th Import/Export Procedures & Documentation Chicago, ILMarch 29th-31st Import/Export Procedures & Documentaiton San Francisco, CAJuly 26th-28th Import/Export Procedures & Documentation Chicago, ILOctober 4th-6th Import/Export Procedures & Documentation Atlanta, GA



Publisher: Rennie Alston ~ Editoral Staff: Randi Keenan, Kelly Raia, Sarah Reynolds ~ Managing Editor: Tracy Lenok

Managing Imports & Exports (ISSN 1553-0752) is published monthly for $437 per year by the PACMAN Association, 614 Progress Street, Elizabeth, NJ 07201. © 2009. PACMAN Association All rights reserved. A one-year subscription includes 12 monthly issues plus regular fax and e-mail transmissions of news and updates. Copyright and licensing information: It is a violation of federal copyright law to reproduce all or part of this publication or its content by any means. The Copyright Act imposes liability of up to $150,000 per issue for such infringement. Information concerning illicit duplication will be gratefully received. To ensure compliance with all copyright regulations or to acquire a license for multi-sub-scriber distribution within a company or for permission to republish, please contact PACMAN’s corporate licensing department at 877-PACMAN8, or email [email protected]. Periodicals postage paid at Newark, NJ and additional mailing offices. POSTMASTER: Send address changes to PACMAN Association, 614 Progress Street, Elizabeth, NJ 07201, 877-PACMAN8 or e-mail [email protected]

Website Feature of the Month

http://www.whitehouse.gov/This informative website contains various issues fac-ing our nation. It also has links to President Obama’s weekly address, photos, current issues, previous speeches made by the President as well as a blog. There is a tab that allows you to send an email to the White House. Who knows, you may even get a per-sonal reply from the President.



MANAGING IMPORTS & EXPORTS PERIODICALS 614 Progress Street Elizabeth, NJ 07201

SUBSCRIBE TODAY!□ YES! Please enter my subscription for 12 issues of the PACMAN Association’s Report on Managing Imports & Exports, which also entitles me to electronic access to current and all back issues in the newsletter section of www.compliancemaven.com for $437 – plus $16.95 shipping & handling.*

□ YES! I’d like to save $175 on a two-year subscription for $699 – plus $33.90 shipping & handling.*

□ Enclosed is my check for $______________□ Bill me/my company□ Charge my:□ VISA□ MasterCard□ AMEX□ Discover

Card#_____________________________________________Exp. Date______________

Signature:________________________________________________________________

Tel:_____________________________________________________________________

Name/Title_______________________________________________________________

Company________________________________________________________________

Street___________________________________________________________________

City________________________________________State_______ Zip______________

E-Mail__________________________________________________________________

______Send my subscription via e-mail

MAIL TO: PACMAN Subscription Department 614 Progress Street Elizabeth, NJ 07201

Phone: 1-877-PACMAN8 or fax to 201-265-0071

*By purchasing an individual subscription, you expressly agree not to reproduce or redistribute our content without our permission, including by making our content available to non-subscribers within your company or elsewhere.

We value your comments and suggestions.....please email us at [email protected]

16

Documents

U.S. Foreign-Trade Zones Support Import Compliance, Cargo ... · Compliance, Cargo Security and Lean Logistics Corporate Initiatives By Brandi Hanback The Rockefeller Group The job