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Routed Exports: Blindfolded and Walking Through a Minefield – What Could Go Wrong?

Routed Exports. Need I say more? There are few topics in the export compliance realm that stir more controversy! This is for good reason. The lines of responsibility can be blurry at times, and the differences in regulations can cause even the oldest, saltiest trade compliance professionals to tremble in their loafers. Not to worry – the Census Bureau is aiming to right all the wrongs we have suffered at the hands of regulations that are vague at best and conflicting at worst. The question is: will it happen? This webinar will take a look at the request for comments, suggestions from the trade community, and we’ll spend a good deal of time on the regulations themselves.

Here’s a good example to wrap your mind around: according to the Foreign Trade Regulations (FTR), in a routed export, unless authorized in writing, the U.S. Principal Party in Interest (USPPI) is not allowed to see the Ultimate Consignee data that is reported in the electronic export information (EEI). How does that line up with the USPPI’s requirement to know their customer? The easy answer is that you should know before the export filing, but it can still feel a bit unsettling. It’s as if the USPPI is blindfolded and led through the export minefield by the Foreign Principal Party in Interest (FPPI) and their authorized agent. So…how well did you discuss the dangers of the minefield? And how many mines are in the field you are crossing?

Routed exports aren’t all bad, though. The truth is that routed exports are a useful and sometimes necessary tool for some companies. In some situations, the best compliance solution may be a routed export. Things break down quickly, though, if there is not sufficient communication between all parties involved, including the necessary legal documentation. Even if an FPPI agrees to routed export requirements, they may heavily depend on a U.S. agent to meet those requirements – meaning there needs to be clear and consistent communication between the USPPI and the FPPI’s authorized agent.

Do you know where the mines are in your routed exports? If not, let’s play a little minesweeper and see if we can’t identify them!

This webinar will cover:

  • Definition of a Routed Export
    • Theoretically
    • Practically
    • Export Administration Regulations (EAR)
    • Foreign Trade Regulations (FTR)
  • Official Routed Export Guidance
    • From the Bureau of Industry and Security (BIS)
    • From the Census Bureau
  • Key Parties to a Routed Export
    • How the Risk and Responsibilities are Divided
    • Different Roles Under the EAR and the FTR
  • Routed Export Benefits and Pitfalls
  • Proposed Changes to Routed Exports
    • Request for Comments
    • The Main Considerations of Census
  • Review of Comments
    • Brief Overview of Submissions
    • Analysis of Various Stances in the Trade Community

This webinar will be very beneficial for US exporters, authorized agents, and foreign parties involved in routed exports, as well as any export compliance professional, supply chain professional, freight forwarder, and carrier wanting to expand their knowledge of routed exports. Finally, anyone in a situation choosing whether or not routed exports are right for them, this webinar will help identify the benefits and the pitfalls of routed exports.

Understanding the intricacies of a routed export can be difficult, and it has major implications as to who bears the burden and/or risk. The better you understand routed exports, the better you can protect yourself and your company from that risk.

This webinar will provide PowerPoint slides and include live video and commentary from Jonathan Young, who served as a military intelligence analyst before transitioning to an export compliance career in a corporate environment managing AES filings, export classification, and due diligence screening. Jonathan discovered early on that just understanding the juicy technical details is not enough, but communicating it to others is just as, if not more, important. He has trained groups ranging in size from one specialist to crowds of hundreds. Jonathan also has experience publishing documents, methods, and regulations used by the United States Air Force and Nissan North America.

Computer Requirements:

Please read the Webinar Terms and Conditions before you register.

Webinar Details

Recorded

May 14, 2019

Length

1 hour 30 minutes
Comprised of 1 hour of commentary and 30 minute Q&A session

Instructor

Cost

1 Participant:  $150.00
2-5 Participants:  $112.50 each
(25% discount for all participants)
6 or more Participants: $75.00 each
(50% discount for all participants)

ECoP® EAR or ITAR Renewal Credits

1

Event #: 13696

CES: 1.5

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