How does the reform of export control in the USA affect foreign purchases?

Over the past two years, online shoppers have encountered an unforeseen problem, namely the fact that some items previously available for purchase have suddenly appeared on the list of prohibited goods. For example, clothes in camouflage colors or individual fishing gear. The network here and there were debates about the reasons for such a change, but the truth, as always, was somewhere nearby and turned out to be quite banal - making changes to the legislation.

A few years ago, the US authorities launched a three-phase export control reform , which aims to streamline all existing norms and create a single automated mechanism to control the export of goods abroad, which will allow the authorities to conduct regular inspections and keep abreast of the export market. In August 2015, the reform entered into the second phase, and the federal authorities urge exporters to also bring their procedures in line with the new requirements.

What does this mean?
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90% of exported goods do not require licensing and are not subject to additional regulation. Only 10% of export turnover falls under the Commerce Control List ( CCL ), and such products will be assigned to ECCN ( Export Control Classification Number ). This number indicates the characteristics of the product, which make it possible to use it for military purposes, in nuclear energy, telecommunications and several other fundamentally important sectors. Each exporter is obliged to check the processed goods for compliance with the CCL and set the classification number (ECCN), if it has been assigned to the goods by the manufacturer.
Of course, buying, for example, Levi's jeans or the next volume of “Game of Thrones” on the American Amazon or Ibei, you should not look in the description of the ECCN lot. But if you are planning to purchase equipment or electronics, it will always be useful to look at the manufacturer's website and clarify information on the availability of the ECCN , in order to avoid rare, but still possible limitations. Or write to our support team, and we will be happy to clarify for you if possible the delivery of goods in advance, before purchasing it. Immediately you should postpone the idea of ​​buying in the US, say, a laser sight, camouflage uniform or a hidden camera, even if all these things were needed only for the recent Halloween masquerade.

We now return to products that do not have an ECCN (collective number EAR99 ) and are not subject to the export control list. Does this mean that if the goods are not regulated, they can be exported without thinking? Not really.
Before taking out any investment outside the United States, the exporter must ensure that the shipment does not violate existing embargoes or sanctions against the country of destination, that the recipient is not on the black list of persons denied export privileges, and finally that he does not have doubt in the possible misuse of the goods.
If countries with an embargo can be counted on the fingers of one hand, at least a dozen government agencies share the lists of banned persons.
For each of the lists, you must verify the recipient data, manually or through Denied Party Screening systems.



The same goal is followed by the rule “ Know your customer ”, which encourages exporters to confirm customer data, to be sure - the final recipient is the person whose data are specified in the order, and this is a real physical or legal person.

Do not forget about the rules of the International Air Transport Association ( IATA ) and the provisions of the Universal Postal Union ( UPU ). Forbidden investment in mailings are, among others, any drugs and medical equipment (including syringes, surgical needles, etc.), liquids over 1 liter (cumulative per package), combustible substances (eg perfume), any aerosols or merchandise under pressure (eg. airbags), etc.

Failure to comply with export control requirements, either intentionally or unknowingly, entails serious consequences for both the exporter and the recipient.

Our friends at MyUS were convinced of this in their own experience in 2013, when a law - enforcement and customs authorities raided the company’s warehouse. Few people know that the company-forwarder is still in judicial debate, trying to reduce the penalty imposed on them in the amount of 48 million dollars.
In addition to astronomical fines, violations of export laws threaten with long-term prison terms - up to 20 years for each violation found . Just recently, the Federal Court of New York pleaded guilty to three Russians accused of complicity in the illegal export of microelectronics from the USA to Russia. Recall that in the US, all penalties are summed up for every proven fact of a crime, which is why the former Procurement Manager of Arc Electronics, Alexander Posobilov, faces up to 185 years in prison.

Recipients of goods that were exported with violation, may be blacklisted, lost the right to export goods from the United States and partner countries, lose already existing foreign visas or be refused a visa in the future. In extreme cases, the recipients may also be brought to administrative and criminal responsibility in the territory of their country or be extradited to the United States.

As reforms affected LiteMF

As you understand, such important events in the affairs of export control did not leave aside our service. The fact that our company is a major exporter in the Russian Federation also leaves its mark in the light of the aggravated geopolitical situation .

As described in Supplement No. For example, it can be used as a rule. to ensure that there is a transaction for the transaction.

Recently, we were able to talk with representatives of the Bureau of Industry and Security ( BIS ), the Federal Bureau of Investigation ( FBI ) and the Office of Transportation Security ( TSA ) . During the conversation, we received valuable recommendations on compliance with the updated requirements of export controls, and it became clear that in the near future these organizations will conduct an audit of compliance with the export requirements of all market participants.
To ensure that our customers and their parcels avoid the unwanted attention of the authorities in the course of export, we are already striving to update our procedures and maximally check incoming and outgoing parcels for compliance with export rules. This means:

• to have at our disposal invoices for all goods in stock, including requesting and checking invoices for each independent purchase of the Mail Forwarding (MF) service;
• view the contents of all receipts for the presence of a prohibited investment;
• declare the content in strict accordance with the actual parameters of the attachment (name, description, price);
• Confirm that the account is owned by the person in whose name, email and phone the profile is registered;
• confirm the actual recipients in whose name the parcels are sent.

If your package has been delayed a little in the warehouse last week, we will immediately reply - yes, this is due to the optimization of new verification procedures. This time, all goods in the warehouse were checked immediately, which suspended their packing and shipping.
We thank you for your understanding and we assure you: all procedures that will be gradually introduced to meet export and import requirements serve your interests. Agree, it is better to spend 15 minutes to load the invoice for self-purchase of the MOF and learn about the restriction on the goods prior to shipment, how to lose an international visa due to a violation on export or to receive an administrative violation instead of buying on import (remember how in the Runet history with the Moto G smartphone? https://sites.google.com/site/darktermit/moto-g ).
To make the work of the warehouse even better, we put a lot of effort. However, change, even the most positive, temporarily slows the sending of parcels.

Happy shopping, friends, and safe!