Cuban Regulations and Recent Easing of Activities in Cuba

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Cuban Regulations and Recent Easing of Activities in Cuba"

Transcription

1 Cuban Regulations and Recent Easing of Activities in Cuba As you are aware, the President has implemented several initiatives to ease the 50-year-old US embargo with Cuba. This was announced on December 17 th, A. Agencies The Cuban Regulations are primarily administered by the US Treasury Department, Office of Foreign Assets Control (OFAC). This agency s regulations control funding and the authorizes types of activities that are permitted through General Licenses, which limit approved activities to academic research and exchanges, sporting competitions, cultural activities, and humanitarian efforts. A new focus, less applicable to SI, is support for activities related to entrepreneurship, energy efficiency, environmental programs, and support for democracy initiatives. These activities are approved under Support for the Cuban People. OFAC also debars parties by placing them on government denial lists and our activities cannot benefit government agencies directly. For groups that do not fit into specific categories, OFAC issues specific licenses. The US Department of Commerce, Bureau of Industry and Security (BIS) shares responsibility for approving the export of items that is eligible without a license under the new rules, such as building materials and telecommunications equipment, whether donated or sold commercially. B. Activities that are permitted without a specific license Both agencies have expanded provisions where an export license is not required. OFAC calls them General Licenses and BIS calls them License Exceptions. The embargo is technically still in effect. It is through the addition of new General Licenses and License Exceptions that the President eased the embargo without requiring legislation by Congress. C. SI Approval of Activities with Sanctioned Countries What this means for SI-affiliated person is that it is necessary to formally assess that the proposed SI activity in Cuba to ensure it qualifies for one of the General Licenses under OFAC rules or that export of equipment meets BIS license exceptions. How to Determine if My Activity Qualifies? The SI-affiliated person should contact the ECO and prepare a brief description of the activity in writing to be detailed on our Export Compliance checklist. This description should include the dates of travel, the activities, and if the traveler is bringing or returning with funds or items.. The ECO then makes a determination whether the activity can be classified as eligible for a General License or License Exception or if a specific license is required. The new regulations mandate that persons engaging with Cuba keep a written record, which is accomplished at SI on the Export Compliance Checklist. The ECO can make a determination in writing Cuba FAQs 1

2 that an activity or export meets a General License or License Exception, or if a specific license is required. D. Goals of New Easing The regulations encourage people-to-people contact when organized by formal settings through academic, cultural, sporting and religious organizations. The new General Licenses have eased the types of qualifying activities, the type and amount of funding, the ability to export and import items, etc. These are explained below: General Licenses for Approved Travel OFAC no longer requires travel to be arranged by specifically approved travel companies. A traveler may use their US passport and may make travel arrangements with any travel company offering services. A visa from Cuba is required. Travelers are no longer prohibited from using US funds and may use US-issued credit cards when traveling. Bringing items for Research Support for Cuban People Specific activities related to cultural and research organizations have been broadened. Researchers may bring items tools of the trade needed for their research and leave the items in Cuba for up to 2 years. NOTE: Items that are export controlled require a specific license from BIS and might not be approved. Tools for building and agricultural activities are permitted when benefitting Cuban People, not any government organizations. Types of Groups that are authorized Cultural, religious, academic and sporting groups may travel. Conferences Open conferences that have international in participation qualify for a general license. Personal communication devices General License CCD (Part of EAR) permits the import of 17 categories of communication devices (cell phones, laptops, routers, digital cameras, security software, etc.) into Cuba either for donation or for sale that enhance access to internet, upgrades current communication and provides access to news bureaus to general public. The item must be an Export Control Classification Number of EAR99 or controlled at Anti Terrorism level. No items on the Commerce Control List or US Munitions List can be exported to Cuba. Imports from Cuba to the US: Cuba FAQs 2

3 Travelers may bring up to $400 worth of items back from Cuba, not to exceed $100 in alcohol and cigars. Gift parcels to Cuba Multiple packages can now be consolidated into a bulk shipment. Q: How much money may I spend in Cuba? A: There is a limit of $10,000 per family group. FAQs Q: Can I use US credit cards? A: Yes. Q: Can I leave equipment in Cuba for several months? A: You can bring items related to your research that are not export controlled and leave them for up to two years. Q: Can I add a few days vacation to my research visit? A: Any extra days need to be approved by OFAC. Only normal downtime likes a weekend between two weeks is permitted. Q: When a US researcher is visiting, can he/she bring microphones? A: As long as EAR99 or Anti-Terrorism controlled only and the equipment stays no more than 2 years. Q: Can we pay Cubans for related services? A: The ECO would have to know what the services are and consult with OFAC. Q: How much can we pay Cubans for services? Cuba FAQs 3

4 A: It is limited to $2000 per quarter. Q: Can we bring tools? A: As long as they are used for private sector hammers, tools or to support your research and they are not on any export control list. Q: Assuming an item is EAR99 how do we prove that item is sold to private sector? A: The regulations have no specifics, use normal due diligence. Q: Can we import items from a third country into Cuba? A: Reexports from a 3 rd country of more than 10% US origin items, exports of items on CCL, and items with more than a de minimis require an export license. Q: Will personal computer product be eligible: i.e. tablets, pcs for import into Cuba? A: US regulations permit the export. You need to check Cuban regulations for the import. License Exception CCD authorizes computers and mobile phones for non-government end-users. Q: What is permitted under temporary sojourn? A: The sojourn must meet FAA requirements. Unlikely they would approve other than a temporary sojourn. Q: There is not a lot of information about permitted carriers for passenger or charter vessels. Can US flagged vessels be permitted for travel to Cuba? A: Please direct this question to OFAC. Q: Are all mass market encryption items considered a consumer product? Are they okay for License Exception CCD? A: Not automatically, License Exception CCD specifies 17 categories of items. Cuba FAQs 4

5 Q: Can we export malware software and items? A: They are eligible for License Exception CCD if the software is going to individuals. Q: What changed for exports? A: Personal Communication Devices do not need to be donated. Gift parcels can be consolidated into bulk shipments. Q: Is there a hot line for questions about Cuba? A: There is not a specific hotline, call Exporter Services in DC and CA. Q: Can we make payments directly to a Cuban person? A: If the payment is directly related to an activity that is approvable under a General License, yes. If it is not directly related, the ECO will have to check with OFAC to confirm if a license is required, such as paying an employee of an academic institution to do side work to assist with research to determine if the activity is approvable for funds transfer and if the person is not a member of the Cuban government. 17 Items that can be exported to Cuba without an export license (license exception CCD : CONSUMER COMMUNICATIONS DEVICES (CCD) (a) Authorizations This section authorizes the export or reexport of commodities and software, either sold or donated, to Cuba or Sudan subject to the requirements stated herein. This section does not authorize U.S.-owned or - controlled entities in third countries to engage in reexports of foreign produced commodities to Cuba for which no license would be issued by the Department of the Treasury pursuant to 31 CFR (b) Eligible commodities and software Commodities and software in paragraphs (b)(1) through (17) of this section are eligible for export or reexport under this section to Cuba or Sudan. Commodities in paragraph (b)(18) of this section are eligible for export or reexport under this section to Sudan only. (1) Consumer computers designated EAR99 or classified under Export Control Classification Numbers (ECCN) 5A992.c or 4A994.b; (2) Consumer disk drives and solid state storage equipment classified under ECCN 5A992 or designated EAR99; Cuba FAQs 5

6 (3) Input/output control units (other than industrial controllers designed for chemical processing) designated EAR99; (4) Graphics accelerators and graphics coprocessors designated EAR99; (5) Monitors classified under ECCN 5A992.c or designated EAR99; (6) Printers classified under ECCN 5A992.c or designated EAR99; (7) Modems classified under ECCNs 5A991.b.2, 5A991.b.4., or 5A992.c or designated EAR99; (8) Network access controllers and communications channel controllers classified under ECCN 5A991.b.4 or designated EAR99; (9) Keyboards, mice and similar devices designated EAR99; (10) Mobile phones, including cellular and satellite telephones, personal digital assistants, and subscriber information module (SIM) cards and similar devices classified under ECCNs 5A992.c or 5A991 or designated EAR99; (11) Memory devices classified under ECCN 5A992.c or designated EAR99; (12) Consumer information security equipment, software (except encryption source code ) and peripherals classified under ECCNs 5A992.c or 5D992.c or designated EAR99; (13) Digital cameras and memory cards classified under ECCN 5A992 or designated EAR99; (14) Television and radio receivers classified under ECCN 5A992 or designated EAR99; (15) Recording devices classified under ECCN 5A992 or designated EAR99; (16) Batteries, chargers, carrying cases and accessories for the equipment described in this paragraph that are designated EAR99; (17) Consumer software (except encryption source code ) classified under ECCNs 4D994, 5D991 or 5D992.c or designated EAR99 to be used for equipment described in paragraphs (b)(1) through (b)(16) of this section; (c) Eligible and ineligible end-users (1) Organizations. (i) This license exception may be used to export or reexport eligible commodities and software to and for the use of independent non-governmental organizations in Cuba or Sudan. (ii) The Cuban Government or the Cuban Communist Party and organizations they administer or control are not eligible end-users. (iii) The Government of Sudan is not an eligible end-user for any item exported or reexported pursuant to this license exception except for consumer software that is authorized under paragraph (b)(12) or (b)(17) of this section and that is distributed free of charge. Cuba FAQs 6

7 (2) Individuals. This License Exception may be used to export eligible commodities and software to and for the use of individuals other than the following: (i) Ineligible Cuban Government Officials. Ministers and vice-ministers; members of the Council of State; members of the Council of Ministers; members and employees of the National Assembly of People's Power; members of any provincial assembly; local sector chiefs of the Committees for the Defense of the Revolution; Director Generals and sub-director Generals and higher of all Cuban ministries and state agencies; employees of the Ministry of the Interior (MININT); employees of the Ministry of Defense (MINFAR); secretaries and first secretaries of the Confederation of Labor of Cuba (CTC) and its component unions; chief editors, editors and deputy editors of Cuban state-run media organizations and programs, including newspapers, television, and radio; or members and employees of the Supreme Court (Tribuno Supremo Nacional). (ii) Ineligible Cuban Communist Party Officials. Members of the Politburo; the Central Committee; Department Heads of the Central Committee; employees of the Central Committee; and the secretaries and first secretaries of provincial Party central committees. Cuba FAQs 7

Cuba Sanctions: 10 Important Changes

Cuba Sanctions: 10 Important Changes Wednesday, February 18, 2015 Cuba Sanctions: 10 Important Changes Ten key changes to US sanctions and export regulations for Cuba. LATINVEX SPECIAL Latham & Watkins New regulations will facilitate trade

More information

CHAPTER IV: SECTION 7 COMPLIANCE WITH U.S. SANCTIONS

CHAPTER IV: SECTION 7 COMPLIANCE WITH U.S. SANCTIONS REVISED 10/19/12 CHAPTER IV: SECTION 7 COMPLIANCE WITH U.S. SANCTIONS Policies and Procedures of Society of Exploration Geophysicists with respect to Membership, Publishing Activities, and Scholarships

More information

U.S. DEPARTMENT OF THE TREASURY

U.S. DEPARTMENT OF THE TREASURY U.S. DEPARTMENT OF THE TREASURY FREQUENTLY ASKED QUESTIONS RELATED TO CUBA This document is explanatory only, does not have the force of law, and does not supplement or modify the Executive Orders, statutes,

More information

U.S. DEPARTMENT OF THE TREASURY

U.S. DEPARTMENT OF THE TREASURY U.S. DEPARTMENT OF THE TREASURY FREQUENTLY ASKED QUESTIONS RELATED TO CUBA This document is explanatory only, does not have the force of law, and does not supplement or modify the Executive Orders, statutes,

More information

Obama Administration Further Eases Restrictions to Aid Implementation of Cuba Policy

Obama Administration Further Eases Restrictions to Aid Implementation of Cuba Policy Client Alert September 22, 2015 If you read one thing... U.S. sanctions relief implemented September 21, 2015, consolidates previous actions to roll back U.S. sanctions, reflecting the administration s

More information

Table of Contents 738.1 INTRODUCTION (CCL) STRUCTURE

Table of Contents 738.1 INTRODUCTION (CCL) STRUCTURE Commerce Control List Overview and the Country Chart Part 738 page 1 Table of Contents 738.1 INTRODUCTION... 1 738.2 COMMERCE CONTROL LIST (CCL) STRUCTURE... 1 738.3 COMMERCE COUNTRY CHART STRUCTURE...

More information

SUMMARY: The Department of the Treasury s Office of Foreign Assets Control (OFAC) is

SUMMARY: The Department of the Treasury s Office of Foreign Assets Control (OFAC) is This document is scheduled to be published in the Federal Register on 01/27/2016 and available online at http://federalregister.gov/a/2016-01559, and on FDsys.gov DEPARTMENT OF THE TREASURY Office of Foreign

More information

Introduction To Commerce Department. Export Controls U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES

Introduction To Commerce Department. Export Controls U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES Introduction To Commerce Department Export Controls U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES Overview The Department of Commerce s Bureau of Industry and

More information

Harvard Export Control Compliance Policy Statement

Harvard Export Control Compliance Policy Statement Harvard Export Control Compliance Policy Statement Harvard University investigators engage in a broad range of innovative and important research both in the United States and overseas. These activities

More information

United States House Foreign Affairs Committee. February 4, 2015

United States House Foreign Affairs Committee. February 4, 2015 Written Testimony on OFAC s Cuba Regulatory Changes of John E. Smith Deputy Director of the Office of Foreign Assets Control United States Department of the Treasury United States House Foreign Affairs

More information

U.S. DEPARTMENT OF THE TREASURY AND DEPARTMENT OF COMMERCE ISSUE RULES IMPLEMENTING CHANGES IN U.S. POLICY ON CUBA

U.S. DEPARTMENT OF THE TREASURY AND DEPARTMENT OF COMMERCE ISSUE RULES IMPLEMENTING CHANGES IN U.S. POLICY ON CUBA January 20, 2015 U.S. DEPARTMENT OF THE TREASURY AND DEPARTMENT OF COMMERCE ISSUE RULES IMPLEMENTING CHANGES IN U.S. POLICY ON CUBA To Our Clients and Friends: On January 15, 2015, the United States Department

More information

http://www.bis.doc.gov

http://www.bis.doc.gov If you ship a commercial item from the United States to a foreign destination, your transaction is likely to be subject to the jurisdiction of the U.S. Department of Commerce. The Bureau of Industry and

More information

1. Not Subject to the EAR and Defense Article. (1) Reserved. (2) Reserved

1. Not Subject to the EAR and Defense Article. (1) Reserved. (2) Reserved 1. Not Subject to the EAR and Defense Article 734.3 (a) (NO REVISION) (b) The following are not subject to the EAR: (1) (NO REVISION) (2) (NO REVISION) (3) Information and software that: (i) Are published,

More information

United States Export Controls on Internet Software Transactions. John F. McKenzie Partner, Baker & McKenzie LLP

United States Export Controls on Internet Software Transactions. John F. McKenzie Partner, Baker & McKenzie LLP United States Export Controls on Internet Software Transactions John F. McKenzie Partner, Baker & McKenzie LLP August 2010 Table of Contents 1. Introduction...1 2. The Concept of an "Export" for Export

More information

CUBA: ABOUT U.S. SANCTIONS AGAINST CUBA. Updated January 24, 2012

CUBA: ABOUT U.S. SANCTIONS AGAINST CUBA. Updated January 24, 2012 CUBA: WHAT YOU NEED TO KNOW ABOUT U.S. SANCTIONS AGAINST CUBA This document is explanatory only and does not have the force of law. The Cuban Assets Control Regulations (31 C.F.R. part 515) contain the

More information

Policy and Procedures Date: 08-24-11

Policy and Procedures Date: 08-24-11 Virginia Polytechnic Institute and State University Policy and Procedures Date: 08-24-11 Subject: Export and Sanctions Compliance Policy Definitions 1.0 Policy 2.0 Oversight 3.0 Responsibilities of Faculty,

More information

COMPUTER & INTERNET. Westlaw Journal. Expert Analysis Software Development and U.S. Export Controls

COMPUTER & INTERNET. Westlaw Journal. Expert Analysis Software Development and U.S. Export Controls Westlaw Journal COMPUTER & INTERNET Litigation News and Analysis Legislation Regulation Expert Commentary VOLUME 31, ISSUE 1 / JUNE 13, 2013 Expert Analysis Software Development and U.S. Export Controls

More information

Table of Contents 734.1 INTRODUCTION 734.1 INTRODUCTION... 1 734.2 IMPORTANT EAR TERMS AND PRINCIPLES... 1 734.3 ITEMS SUBJECT TO THE EAR..

Table of Contents 734.1 INTRODUCTION 734.1 INTRODUCTION... 1 734.2 IMPORTANT EAR TERMS AND PRINCIPLES... 1 734.3 ITEMS SUBJECT TO THE EAR.. Scope of the Export Administration Regulations Part 734 - page 1 Table of Contents 734.1 INTRODUCTION... 1 734.2 IMPORTANT EAR TERMS AND PRINCIPLES... 1 734.3 ITEMS SUBJECT TO THE EAR.. 4 734.4 DE MINIMIS

More information

Table of Contents 758.1 THE ELECTRONIC EXPORT INFORMATION (EEI) FILING TO THE AUTOMATED EXPORT SYSTEM (AES)

Table of Contents 758.1 THE ELECTRONIC EXPORT INFORMATION (EEI) FILING TO THE AUTOMATED EXPORT SYSTEM (AES) Export Clearance Requirements Part 758-page 1 Table of Contents 758.1 THE ELECTRONIC EXPORT INFORMATION (EEI) FILING TO THE AUTOMATED EXPORT SYSTEM (AES)1 758.2 AUTOMATED EXPORT SYSTEM (AES)... 5 758.3

More information

Export Control Compliance Procedure Guide June 8, 2012

Export Control Compliance Procedure Guide June 8, 2012 Export Control Compliance Procedure Guide June 8, 2012 1 TABLE OF CONTENTS Contents TABLE OF CONTENTS... 1 SUMMARY... 2 INTRODUCTION... 3 SCHOOL POLICY... 4 EXCLUSIONS... 4 WHAT IS AN EXPORT?... 4 CONDUCTING

More information

Export Controls: What are they? Why do we care?

Export Controls: What are they? Why do we care? Export Controls: What are they? Why do we care? Laura Langton, PhD Export Control Manager langton@wustl.edu 314-747-1378 http://research.wustl.edu/complianceareas/exportcontrols What is an Export? Release

More information

Export Control Management System

Export Control Management System Export Control Management System Export Controls are federal regulations and laws that restrict the export of certain controlled technologies in order to restrict access to goods and technology that have

More information

SUMMARY: The Department of the Treasury s Office of Foreign Assets Control (OFAC) is

SUMMARY: The Department of the Treasury s Office of Foreign Assets Control (OFAC) is This document is scheduled to be published in the Federal Register on 01/16/2015 and available online at http://federalregister.gov/a/2015-00632, and on FDsys.gov DEPARTMENT OF THE TREASURY Office of Foreign

More information

Counterterrorism and Humanitarian Engagement Project

Counterterrorism and Humanitarian Engagement Project Counterterrorism and Humanitarian Engagement Project OFAC Licensing Background Briefing March 2013 I. Introduction 1 The U.S. Department of Treasury s Office of Foreign Assets Control (OFAC) administers

More information

U.S. Department of Commerce Bureau of Industry and Security. How to Classify Your Item

U.S. Department of Commerce Bureau of Industry and Security. How to Classify Your Item U.S. Department of Commerce Bureau of Industry and Security How to Classify Your Item How is my Item Classified for Export Control Purposes? Commerce Control List ( CCL ) Export Control Classification

More information

Policy on Export of Physical and Intellectual Property Export Controls

Policy on Export of Physical and Intellectual Property Export Controls ~y.~@ Foundation for Tne State U "Ilvtl'S' V ~f NaN YOI< College of OptoInetry Policy on Export of Physical and Intellectual Property Export Controls Date: 04/26/2012 Revision: 1.01 Purpose and preamble

More information

John P. Barker, Raul R. Herrera, Arturo Caraballo, and John B. Bellinger III September 2015. Introduction

John P. Barker, Raul R. Herrera, Arturo Caraballo, and John B. Bellinger III September 2015. Introduction Obama Administration Promulgates Further Revisions to Cuba Regulations Designed to Encourage Economic Engagement and Other Exchanges Between the US and Cuba John P. Barker, Raul R. Herrera, Arturo Caraballo,

More information

Assets Control ( OFAC ) is amending the Cuban Assets Control. Regulations to implement a provision of the Omnibus

Assets Control ( OFAC ) is amending the Cuban Assets Control. Regulations to implement a provision of the Omnibus DEPARTMENT OF THE TREASURY Office of Foreign Assets Control 31 CFR Part 515 CUBAN ASSETS CONTROL REGULATIONS AGENCY: Office of Foreign Assets Control, Treasury. ACTION: Final rule. -------------------

More information

Second Annual Impact of Export Controls on Higher Education & Scientific Institutions

Second Annual Impact of Export Controls on Higher Education & Scientific Institutions The following presentation was presented at the Second Annual Impact of Export Controls on Higher Education & Scientific Institutions Hosted by Georgia Institute of Technology In cooperation with Association

More information

CIRCULAR 2012. TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL

CIRCULAR 2012. TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL CIRCULAR 2012 TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL July 2012 CIRCULAR 2012 Subject TABLE OF CONTENTS Page I. Overview 3 II. Service Provider

More information

CIRCULAR 2012. TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL

CIRCULAR 2012. TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL CIRCULAR 2012 TRAVEL, CARRIER and REMITTANCE FORWARDING SERVICE PROVIDER PROGRAM OFFICE OF FOREIGN ASSETS CONTROL July 2012 CIRCULAR 2012 Subject TABLE OF CONTENTS Page I. Overview 3 II. Service Provider

More information

Export Control Training: Who, What and When? IMPACT OF EXPORT CONTROLS ON HIGHER EDUCATION AND SCIENTIFIC INSTITUTIONS MAY 23-24, 2016

Export Control Training: Who, What and When? IMPACT OF EXPORT CONTROLS ON HIGHER EDUCATION AND SCIENTIFIC INSTITUTIONS MAY 23-24, 2016 Export Control Training: Who, What and When? IMPACT OF EXPORT CONTROLS ON HIGHER EDUCATION AND SCIENTIFIC INSTITUTIONS MAY 23-24, 2016 Export Control Training: Who, What and When? STEPHEN HALL, U.S. BUREAU

More information

GOODMAN GLOBAL GROUP, INC. EXPORT CONTROL AND SANCTIONS COMPLIANCE POLICY

GOODMAN GLOBAL GROUP, INC. EXPORT CONTROL AND SANCTIONS COMPLIANCE POLICY GOODMAN GLOBAL GROUP, INC. EXPORT CONTROL AND SANCTIONS COMPLIANCE POLICY Goodman Global Group, Inc. and our affiliates (collectively, the Company ) are committed to complying with all laws applicable

More information

Rules and Regulations

Rules and Regulations 1059 Rules and Regulations Federal Register Vol. 76, No. 5 Friday, January 7, 2011 This section of the FEDERAL REGISTER contains regulatory documents having general applicability and legal effect, most

More information

Federal Register / Vol. 80, No. 11 / Friday, January 16, 2015 / Rules and Regulations

Federal Register / Vol. 80, No. 11 / Friday, January 16, 2015 / Rules and Regulations Federal Register / Vol. 80, No. 11 / Friday, January 16, 2015 / Rules and Regulations 2291 Supplement No. 2 to Part 748 [Amended] 9. In Supplement No. 2 to part 748, remove and reserve paragraph (d). Dated:

More information

Table of Contents 746.1 INTRODUCTION

Table of Contents 746.1 INTRODUCTION Embargoes and Other Special Controls Part 746 page 1 Table of Contents 746.1 INTRODUCTION... 1 746.2 CUBA... 2 746.3 IRAQ... 5 746.4 NORTH KOREA... 8 746.5 RUSSIAN INDUSTRY SECTOR SANCTIONS... 9 746.6

More information

Export Control Compliance Program Guidelines January 2012

Export Control Compliance Program Guidelines January 2012 Export Control Compliance Program Guidelines January 2012-1 - TABLE OF CONTENTS Introduction... 3 Institutional Policy... 4 Federal Laws, Regulations, and Penalties... 5 Key Terms and Definitions... 8

More information

Export Control Laws Training Presentation FLORIDA INSTITUTE OF TECHNOLOGY

Export Control Laws Training Presentation FLORIDA INSTITUTE OF TECHNOLOGY Export Control Laws Training Presentation FLORIDA INSTITUTE OF TECHNOLOGY 1 Why Be Concerned with Export Control Laws Certain export control laws may apply to FIT research activities here and abroad. Failure

More information

Federal Register / Vol. 80, No. 182 / Monday, September 21, 2015 / Rules and Regulations

Federal Register / Vol. 80, No. 182 / Monday, September 21, 2015 / Rules and Regulations Federal Register / Vol. 80, No. 182 / Monday, September 21, 2015 / Rules and Regulations 56915 for all of the stock of New S. S s distribution of 80% of its property to P as part of the complete liquidation

More information

University of Maryland Export Compliance Program

University of Maryland Export Compliance Program April 6, 2015 Message from the Vice President for Research Export control is governed by a group of federal regulations intended to advance the national security, foreign policy, and economic interests

More information

Passengers Customs Guide

Passengers Customs Guide Passengers Customs Guide 2nd Version 2011 Public Document www.dubaicustoms.gov.ae INDEX Contact us: Website: www.dubaicustoms.gov.ae E-mail: client.relations@dubaicustoms.ae Toll-free number: 80080080

More information

Middle Tennessee State University. Office of Research Services

Middle Tennessee State University. Office of Research Services Middle Tennessee State University Office of Research Services Procedure No.: ORS 007: Export Control Date Approved: December 08, 2011 1. INTRODUCTION: It is the intent of Middle Tennessee State University

More information

Export Control Compliance Program Guidelines April 2015

Export Control Compliance Program Guidelines April 2015 Export Control Compliance Program Guidelines April 2015 UML Export Control Guidelines rev4-16-15.docx - 1 - TABLE OF CONTENTS Introduction... 3 Institutional Policy (Management Commitment)... 4 Federal

More information

Director of Logistics & Compliance James Hall

Director of Logistics & Compliance James Hall Minimizing Risk Exposure While Fully Utilizing Freight Forwarders Expertise To Effectively Apply Compliance In Challenging Locations Director of Logistics & Compliance James Hall What is Compliance Adherence

More information

Export Control Training

Export Control Training 2007 Export Control Training Office of Sponsored Research and Programs Missouri State University Missouri State University Research Security and Export Controls Compliance Manual 11/7/2007 1 As an employee

More information

THE WHITE HOUSE Office of the Press Secretary. FOR IMMEDIATE RELEASE August 30, 2010

THE WHITE HOUSE Office of the Press Secretary. FOR IMMEDIATE RELEASE August 30, 2010 THE WHITE HOUSE Office of the Press Secretary FOR IMMEDIATE RELEASE August 30, 2010 President Obama Lays the Foundation for a New Export Control System To Strengthen National Security and the Competitiveness

More information

Election messages communicated over the Internet during the writ period are election advertising only if they have a placement cost.

Election messages communicated over the Internet during the writ period are election advertising only if they have a placement cost. Factsheet The Canada Elections Act: Frequently Asked Questions for Labour Organizations Important Update Regarding Election Advertising on the Internet: Elections Canada has just published their July 2015

More information

CRS Report for Congress

CRS Report for Congress CRS Report for Congress Received through the CRS Web Order Code RS21775 Updated April 5, 2004 Cable Television: Background and Overview of Rates and Other Issues for Congress Summary Justin Murray Information

More information

Table of Contents 762.1 SCOPE 762.2 RECORDS TO BE RETAINED

Table of Contents 762.1 SCOPE 762.2 RECORDS TO BE RETAINED Recordkeeping Part 762--page 1 Table of Contents 762.1 SCOPE... 1 762.2 RECORDS TO BE RETAINED... 1 762.3 RECORDS EXEMPT FROM RECORDKEEPING REQUIREMENTS... 3 762.4 ORIGINAL RECORDS REQUIRED... 4 762.5

More information

EXPORT COMPLIANCE MANUAL

EXPORT COMPLIANCE MANUAL EXPORT COMPLIANCE MANUAL Prepared By: John Fusco of Locke Lord LLP (07/21/2015) Approved By: Rick Parent - Export Compliance Mgr. Revision B TABLE OF CONTENTS Page 1. ASTRO-MED INC. REGULATORY COMPLIANCE

More information

REGULATORY ADVISORY March 9, 2015

REGULATORY ADVISORY March 9, 2015 REGULATORY ADVISORY SIGNIFICANT UNCERTAINTIES AND RISKS REMAIN FOLLOWING U.S. GOVERNMENT S EASING OF CUBA SANCTIONS TO AUTHORIZE NEW TELECOMMUNICATIONS-RELATED TRANSACTIONS Kent Bressie, Cecil Hunt & Danielle

More information

Companies Need to Take a "Layered Approach" to Sanctions Compliance: US and EU Expand Sanctions Against Russia

Companies Need to Take a Layered Approach to Sanctions Compliance: US and EU Expand Sanctions Against Russia Companies Need to Take a "Layered Approach" to Sanctions Compliance: US and EU Expand Edward Krauland, Meredith Rathbone, Richard Battaglia, Jeffrey Cottle, Guy Soussan, Maury Shenk, Alexandra Baj, Jack

More information

EXPORT CONTROL GUIDELINES FOR STAFF

EXPORT CONTROL GUIDELINES FOR STAFF EXPORT CONTROL GUIDELINES FOR STAFF Created: June 2010 Reviewed: September 2013 Reviewed: April 2015 Maintained by the Office of Sponsored Programs 1 List of Commonly Used Acronyms BIS CCL CJ DDTC EAR

More information

FREIGHT FORWARDER GUIDANCE

FREIGHT FORWARDER GUIDANCE U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES EXPORT MANAGEMENT AND COMPLIANCE DIVISION FREIGHT FORWARDER GUIDANCE February 2012 Freight Forwarder Guidance Members

More information

Office of Export Enforcement Bureau of Industry and Security (BIS) U.S. Department of Commerce

Office of Export Enforcement Bureau of Industry and Security (BIS) U.S. Department of Commerce Office of Export Enforcement Bureau of Industry and Security (BIS) U.S. Department of Commerce Sidney M. Simon Special Agent in Charge New York Field Office Export Enforcement s Mission Protect National

More information

EXPORT CONTROLS COMPLIANCE

EXPORT CONTROLS COMPLIANCE Responsible University Official: Vice President for Research Responsible Office: Office for Export Controls Compliance Origination Date: May 1, 2014 EXPORT CONTROLS COMPLIANCE Policy Statement Northwestern

More information

Country Sanctions Program

Country Sanctions Program ] Country Sanctions Program December 14, 2011 Margaret M. Gatti Louis K. Rothberg www.morganlewis.com Morgan, Lewis & Bockius LLP Ground Rules This webinar is not legal advice, which can only be established

More information

Pros and Cons of Doing Business with Cuba: Today & Tomorrow

Pros and Cons of Doing Business with Cuba: Today & Tomorrow CUBA EDUCATIONAL FORUM PUERTO RICO MANUFACTURERS ASSOCIATION (PRMA) Cuba: Reality Today and Opportunities in the Future Pros and Cons of Doing Business with Cuba: Today & Tomorrow Jay Brickman, Crowley

More information

EXPORT COMPLIANCE PROGRAM MANUAL. University of Delaware

EXPORT COMPLIANCE PROGRAM MANUAL. University of Delaware EXPORT COMPLIANCE PROGRAM MANUAL University of Delaware Revised 01/2013 List of Abbreviations APRRA BIS CCL CJ DDTC EAR ECCN EO URC ITAR OFAC RO PI SDN List TCP USML UD Associate Provost for Research &

More information

SI/SAO Export Compliance Training 1/9/2014

SI/SAO Export Compliance Training 1/9/2014 1 Why Compliance Matters Risks and Responsibilities Export Controls are Complex Understanding the Regimes and Agencies we must comply with What processes we are putting in place at SI to comply Identifying

More information

Action Affecting Export Privileges; ANVIK TECHNOLOGIES SDN. BHD., a/k/a Anvik Technologies; BABAK JAFARPOUR, a/k/a BOB JEFFERSON

Action Affecting Export Privileges; ANVIK TECHNOLOGIES SDN. BHD., a/k/a Anvik Technologies; BABAK JAFARPOUR, a/k/a BOB JEFFERSON Billing Code: 3510-DT-P Department of Commerce Bureau of Industry and Security Action Affecting Export Privileges; ANVIK TECHNOLOGIES SDN. BHD., a/k/a Anvik Technologies; BABAK JAFARPOUR, a/k/a BOB JEFFERSON

More information

3. Designed for installation by the user without further substantial support by the supplier; and

3. Designed for installation by the user without further substantial support by the supplier; and Commerce Control List Supplement No. 1 to Part 774 Category 5 - Info. Security page 1 CATEGORY 5 TELECOMMUNICATIONS AND INFORMATION SECURITY Part 2 INFORMATION SECURITY Note 1: The control status of information

More information

OFAC Office of Foreign Assets Control

OFAC Office of Foreign Assets Control OFAC Office of Foreign Assets Control What is it? The Office of Foreign Assets Control ( OFAC ) of the US Department of the Treasury is a law enforcement agency, not a regulatory agency. OFAC administers

More information

Introduction to Braumiller Schulz LLP Why Trade Compliance? Establishing an Internal Compliance Program (ICP) Contracting Services to Outside Experts

Introduction to Braumiller Schulz LLP Why Trade Compliance? Establishing an Internal Compliance Program (ICP) Contracting Services to Outside Experts Olga Torres, Associate Ol T A i t Braumiller Schulz LLP International Trade Law www.globaltradelaw.net Overview Introduction to Braumiller Schulz LLP Why Trade Compliance? Establishing an Internal Compliance

More information

Export Compliance Program Policies and Procedures Manual. Office of Research and Economic Development University of Wyoming

Export Compliance Program Policies and Procedures Manual. Office of Research and Economic Development University of Wyoming Page 1 of 37 Export Compliance Program Policies and Procedures Manual Office of Research and Economic Development University of Wyoming Office of Research and Economic Development Dept. 3355, 1000 University

More information

University of Louisiana System

University of Louisiana System Policy Number: M-(16) University of Louisiana System Title: EXPORT CONTROL Effective Date: October 26, 2009 Cancellation: None Chapter: Miscellaneous Policy and Procedures Memorandum The University of

More information

Export Controls Compliance

Export Controls Compliance Export Controls Compliance Division of Research The Research Foundation of State University of New York At Binghamton University The purpose of this document is to provide overall guidance on export control

More information

Regulatory Compliance and Trade

Regulatory Compliance and Trade Regulatory Compliance and Trade Global Transaction Services Cash Management Trade Services and Finance Securities Services Fund Services Regulatory Compliance and Trade 2007 These materials are provided

More information

Mastering Global Trade Compliance for Growth Through Export. Track 1 Session 3

Mastering Global Trade Compliance for Growth Through Export. Track 1 Session 3 Mastering Global Trade Compliance for Growth Through Export Track 1 Session 3 Julie Gibbs Director BPE Global Jgibbs@bpeglobal.com 415-595-8543 www.bpeglobal.com 2 Abstract It's not a small world after

More information

SECTION 3 RECRUITMENT AND STAFFING 3.05 UNCLASSIFIED EMPLOYEES

SECTION 3 RECRUITMENT AND STAFFING 3.05 UNCLASSIFIED EMPLOYEES SECTION 3 RECRUITMENT AND STAFFING 3.05 UNCLASSIFIED EMPLOYEES AUTHORITY: CIVIL SERVICE ACT AND REGULATIONS TREASURY BOARD POLICIES & PROCEDURES MANUAL COLLECTIVE AGREEMENT BETWEEN THE GOVERNMENT OF PRINCE

More information

Cuba Sanctions Update: Removal of Cuba from Terrorism List Will Result in Modest Easing of Trade Sanctions

Cuba Sanctions Update: Removal of Cuba from Terrorism List Will Result in Modest Easing of Trade Sanctions Cuba Sanctions Update: Removal of Cuba from Terrorism List Will Result in Modest Easing of Trade Sanctions A legal analysis prepared at the request of the Cuba Study Group 9 April 2015 By Stephen F. Propst,

More information

ROCHESTER INSTITUTE OF TECHNOLOGY EXPORT COMPLIANCE PROGRAM

ROCHESTER INSTITUTE OF TECHNOLOGY EXPORT COMPLIANCE PROGRAM ROCHESTER INSTITUTE OF TECHNOLOGY EXPORT COMPLIANCE PROGRAM Message of the Provost Rochester Institute of Technology is committed to full compliance with the laws and regulations of the United States,

More information

University of Virginia Export Compliance Management Program Manual

University of Virginia Export Compliance Management Program Manual University of Virginia Export Compliance Management Program Manual Revision Date: 4/22/2013 1 ACRONYMS AECA BIS CFR DDTC EAA EAR ITAR OEC OFAC PL RPS TCP USC Arms Export Control Act Bureau of Industry

More information

MOVING CAPITAL IN AND OUT OF CUBA: FINANCIAL TRANSACTIONS, BANKING, MONEY TRANSFERS & TAX LAWS APPLICABLE TO DOING BUSINESS IN CUBA

MOVING CAPITAL IN AND OUT OF CUBA: FINANCIAL TRANSACTIONS, BANKING, MONEY TRANSFERS & TAX LAWS APPLICABLE TO DOING BUSINESS IN CUBA MOVING CAPITAL IN AND OUT OF CUBA: FINANCIAL TRANSACTIONS, BANKING, MONEY TRANSFERS & TAX LAWS APPLICABLE TO DOING BUSINESS IN CUBA Jennifer Correa Riera Fuerst Ittleman David & Joseph PL jcorrea@fuerstlaw.com

More information

Fundamentals of International Trade Transactions & International Trade Compliance

Fundamentals of International Trade Transactions & International Trade Compliance Fundamentals of International Trade Transactions & International Trade Compliance 1 st Annual International Trade Conference University of Nebraska-Omaha Thompson Center April 12, 2016 INTERNATIONAL CONTRACT

More information

EXPORT CONTROLS AND RESEARCH AT WPI TRAINING PRESENTATION

EXPORT CONTROLS AND RESEARCH AT WPI TRAINING PRESENTATION EXPORT CONTROLS AND RESEARCH AT WPI TRAINING PRESENTATION EXPORT CONTROL LAWS WHAT ARE EXPORT CONTROLS? U.S. laws and their implementing regulations that govern the distribution to foreign nationals and

More information

OFAC Sanctions on Iran, Syria, Yemen, and Burma: Compliance Strategies

OFAC Sanctions on Iran, Syria, Yemen, and Burma: Compliance Strategies Presenting a live 90-minute webinar with interactive Q&A OFAC Sanctions on Iran, Syria, Yemen, and Burma: Compliance Strategies Meeting Strict and Rapidly Changing U.S. Sanctions Requirements TUESDAY,

More information

Control Considerations For Auditing the OFAC Affidavit Program

Control Considerations For Auditing the OFAC Affidavit Program Control Considerations For Auditing the OFAC Affidavit Program Cheryl Sincock, CAMS-Audit June 2014 Statement of Intent OFAC generally prohibits financial institutions from processing transactions involving

More information

U.S. Census Bureau Electronic Export Information Requirements When Sending Shipments Internationally

U.S. Census Bureau Electronic Export Information Requirements When Sending Shipments Internationally Postal Service 39 CFR Part 20 U.S. Census Bureau Electronic Export Information Requirements When Sending Shipments Internationally Agency: Postal Service. Action: Final Rule. Summary: New Foreign Trade

More information

Department of Defense DIRECTIVE. SUBJECT: Assistant Secretary of Defense for Public Affairs (ASD(PA))

Department of Defense DIRECTIVE. SUBJECT: Assistant Secretary of Defense for Public Affairs (ASD(PA)) Department of Defense DIRECTIVE NUMBER 5122.05 September 5, 2008 DA&M SUBJECT: Assistant Secretary of Defense for Public Affairs (ASD(PA)) References: See Enclosure 1 1. PURPOSE. This Directive: a. Reissues

More information

We greatly appreciate your attention to this request and look forward to further dialogue with OFAC on these issues going forward.

We greatly appreciate your attention to this request and look forward to further dialogue with OFAC on these issues going forward. Ms. Leslie Devereaux Sanctions Compliance & Evaluation Office of Foreign Assets Control U.S. Department of the Treasury Washington, DC Dear Ms. Devereaux (the Banker s Association for Finance and Trade)

More information

Deemed Exports and the Export Control Reform Initiative. Bernard Kritzer Director Office of Exporter Services. July 24, 2013.

Deemed Exports and the Export Control Reform Initiative. Bernard Kritzer Director Office of Exporter Services. July 24, 2013. Deemed Exports and the Export Control Reform Initiative Bernard Kritzer Director Office of Exporter Services July 24, 2013 Agenda Bernard Kritzer Director Office of Exporter Services Introduction Stephen

More information

Protecting the Value of Your Transaction y

Protecting the Value of Your Transaction y International Trade Due Diligence: Protecting the Value of Your Transaction y by Megan A. Gajewski, Susan M.C. Kovarovics, Michael D. Mellen and Christina A. Zanette You just closed a deal for your client,

More information

The Amendment of the Loan Agreement (for Business)/ Overdraft Facility Agreement (for Consumption)/ Money Mortgage Agreement*

The Amendment of the Loan Agreement (for Business)/ Overdraft Facility Agreement (for Consumption)/ Money Mortgage Agreement* The Amendment of the Loan Agreement (for Business)/ Overdraft Facility Agreement (for Consumption)/ Money Mortgage Agreement* No. Clause Reference Amendment Sanctions 1. Important notice Standard Chartered

More information

AGENCY: National Telecommunications and Information Administration, U.S. Department of

AGENCY: National Telecommunications and Information Administration, U.S. Department of This document is scheduled to be published in the Federal Register on 12/15/2015 and available online at http://federalregister.gov/a/2015-31516, and on FDsys.gov Billing Code: 3510-60-P DEPARTMENT OF

More information

City Clerk. Mission Statement

City Clerk. Mission Statement City Clerk Mission Statement The Office of the City Clerk is committed to pursuing excellence through trust, respect, caring, and by being accountable, transparent, and responsible, by following these

More information

A. 1. What is Implementation Day? When does the lifting of sanctions under the JCPOA go into effect?

A. 1. What is Implementation Day? When does the lifting of sanctions under the JCPOA go into effect? This document is explanatory only and does not have the force of law. Please see particularly the legally binding provisions cited below governing the sanctions. This document does not supplement or modify

More information

ANNEX 8A SCHEDULE OF THE UNITED STATES. Atomic Energy. Sector: Obligations Concerned: National Treatment (Articles 8.3 and 15.

ANNEX 8A SCHEDULE OF THE UNITED STATES. Atomic Energy. Sector: Obligations Concerned: National Treatment (Articles 8.3 and 15. ANNEX 8A SCHEDULE OF THE UNITED STATES Sector: Atomic Energy Atomic Energy Act of 1954, 42 U.S.C. 2011 et seq. Investment A license issued by the United States Nuclear Regulatory Commission is required

More information

Elsa Manzanares. Co-Chair, International Trade, Partner, Corporate

Elsa Manzanares. Co-Chair, International Trade, Partner, Corporate Elsa Manzanares Co-Chair, International Trade, Partner, Corporate Elsa Manzanares is an experienced international trade and compliance partner who advises clients on U.S. and international regulations

More information

INSURANCE AGENT AND BROKER COMPLIANCE WITH THE PATRIOT ACT ANTI-MONEY LAUNDERING REQUIREMENTS AND OFFICE OF FOREIGN ASSETS CONTROL REGULATIONS

INSURANCE AGENT AND BROKER COMPLIANCE WITH THE PATRIOT ACT ANTI-MONEY LAUNDERING REQUIREMENTS AND OFFICE OF FOREIGN ASSETS CONTROL REGULATIONS INSURANCE AGENT AND BROKER COMPLIANCE WITH THE PATRIOT ACT ANTI-MONEY LAUNDERING REQUIREMENTS AND OFFICE OF FOREIGN ASSETS CONTROL REGULATIONS This FAQ is not intended to provide specific advice about

More information

Remember To Comment On BIS' New Cybersecurity Export Rule

Remember To Comment On BIS' New Cybersecurity Export Rule Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com Remember To Comment On BIS' New Cybersecurity Export

More information

SYSTEM OF HIGHER EDUCATION PROCEDURES AND GUIDELINES MANUAL CHAPTER 16 EXPORT CONTROL AND ECONOMIC SANCTIONS POLICY

SYSTEM OF HIGHER EDUCATION PROCEDURES AND GUIDELINES MANUAL CHAPTER 16 EXPORT CONTROL AND ECONOMIC SANCTIONS POLICY SYSTEM OF HIGHER EDUCATION PROCEDURES AND GUIDELINES MANUAL CHAPTER 16 EXPORT CONTROL AND ECONOMIC SANCTIONS POLICY Section 1. Purpose... 2 Section 2. Policy Statement and Institution Policies... 2 Section

More information

BOSTON UNIVERSITY EXPORT COMPLIANCE PROGRAM MANUAL

BOSTON UNIVERSITY EXPORT COMPLIANCE PROGRAM MANUAL BOSTON UNIVERSITY EXPORT COMPLIANCE PROGRAM MANUAL List of Abbreviations AVPRC BIS BU BMC BUMC CCL CJ CRC DDTC EAR ECCN ITAR OFAC OGC OSP PI SDN List TAA TCP USML UECD Associate Vice President for Research

More information

EXPORT COMPLIANCE OFFICE (ECO) MANUAL

EXPORT COMPLIANCE OFFICE (ECO) MANUAL EXPORT COMPLIANCE OFFICE (ECO) MANUAL LIST OF ABBREVIATIONS BIS CCATS CCL CJ CMU CTTEC DDTC EAR ECCN ECO EO FBE FFRDC FRE IEEPA ITAR NREC NSDD OFAC ORIC RPS SDNL SEI TCP TWEA USML Bureau of Industry and

More information

OFAC Licensing: Exceptions to Economic Sanctions Prohibitions

OFAC Licensing: Exceptions to Economic Sanctions Prohibitions A Presentation by Hal Eren SIFMA s OFAC Compliance Symposium AXA Conference Center New York, NY November 6, 2008 11/5/2008 1 OFAC licenses: - authorize transactions and activities that are otherwise prohibited

More information

Standards for Information Security Measures for the Central Government Computer Systems (Fourth Edition)

Standards for Information Security Measures for the Central Government Computer Systems (Fourth Edition) Standards for Information Security Measures for the Central Government Computer Systems (Fourth Edition) February 3, 2009 Established by the Information Security Policy Council Table of Contents Standards

More information

LEGISLATIVE COUNCIL BRIEF RENEWAL OF DOMESTIC PAY TELEVISION PROGRAMME SERVICE LICENCE OF HONG KONG CABLE TELEVISION LIMITED

LEGISLATIVE COUNCIL BRIEF RENEWAL OF DOMESTIC PAY TELEVISION PROGRAMME SERVICE LICENCE OF HONG KONG CABLE TELEVISION LIMITED File Ref: CTB(CR) 9/6/10(04) Pt. 5 LEGISLATIVE COUNCIL BRIEF RENEWAL OF DOMESTIC PAY TELEVISION PROGRAMME SERVICE LICENCE OF HONG KONG CABLE TELEVISION LIMITED INTRODUCTION At the meeting of the Executive

More information

Billing Code: 4810-25. Guidance Concerning the National Security Review Conducted by the Committee

Billing Code: 4810-25. Guidance Concerning the National Security Review Conducted by the Committee This document has been submitted to the Office of the Federal Register (OFR) for publication and is currently pending placement on public display at the OFR and publication in the Federal Register. The

More information

Expanding Internationally with Confidence by Ensuring Global Trade Compliance

Expanding Internationally with Confidence by Ensuring Global Trade Compliance Expanding Internationally with Confidence by Ensuring Global Trade Compliance Justin Cook and Kendra Cook Canopy Consulting International (C2I) jcook@c2iconsulting.com / kcook@c2iconsulting.com www.c2iconsulting.com

More information