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ACE: Auditing Your Export History

Co-Authored by Sharath Patil If a company or individual believes they have violated export control regulations and the U.S. government is unaware of this violation, proactively and voluntarily disclosing the potential wrongdoing can substantially reduce penalties. A key component of filing a successful voluntary self-disclosure (“VSD”) is uncovering and providing the correct data. Diaz Trade […]

Exporting 101 – Introduction to Export Controls

On April 30, 2021, the Bureau of Industry and Security (“BIS”) announced that it had fined FLIR Systems, Inc. $307,922 for an egregious violation of the Export Administration Regulations (“EAR”) for misrepresentations made in commodity jurisdiction (“CJ”) requests. A BIS spokesperson said: “BIS will not tolerate exporters that provide inaccurate or incomplete representations related to […]

ISF PENALTIES HAVE OFFICIALLY ARRIVED: SELF FILE AND SELF POLICE

Back in July, 2013, we warned CBP would start enforcement efforts for Importer Security Filing (ISF) violations. What’s ISF Again? The ISF rules require importers and vessel-operating carriers to provide additional advance trade data on cargo shipments to CBP 24 hours prior to vessel lading, pursuant to Section 203 of the Security and Accountability for Every Port […]

BEWARE – Liquidated Damages WILL be Imposed for 10+2 Violations

For those who thought CBP’s “measured and commonsense” approach for those that weren’t fully complying with the Importer Security Filing (ISF or 10+2) rules would last forever, think again! Effective, July 9, 2013, CBP advised it would start the liquidated damages phase of the Importer Security Filing (ISF) enforcement process. CBP will now make use of the newly […]

January 26, 2010 – Do You Have An ISF Plan?

During the annual Customs Symposium, which took place December 8-10, 2009, Richard DeNucci, the Director of Customs Office of Field Operations, Trade Initiatives, discussed how CBP will enforce ISF(Importer Security Filing, aka 10+2) penalties, beginning January 26, 2010, and provided interesting statistics thus far. ISF will require both importers and carriers to submit additional information […]

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