Is Self-Filing For Everyone?

With increased pressure to reduce costs and justify staff, importers often consider the option of self-filing entries. There are some advantages that immediately come to mind such as reduced entry fees and more control, but what about the disadvantages? Importers normally check the broker’s work as part of their compliance program. If the importer files the entry, who checks the importers work? We all make mistakes. We’d like to open up the forum and hear from our readers. What are the advantages and disadvantages of self-filing. Post your comments to this blog. We’ll publish the comments. In two weeks, we will create a list of advantages and disadvantages submitted by our readers.

Take our Self-Filing Poll located at the top right side of the page.

CBE Study Tip 12: CBP Directives

For many years, the Customs Brokers Exam only required the use of the HTSUS and the CBP Regulations; however, in 2004, CBP expanded its scope of materials to include Customs Directives and other reference materials. These materials are important because they provide guidance on activities brokers perform that aren’t included in the regulations. Since their addition, these resources have comprised 8% to 10% of the total questions on the exam. Because of the number of resources, it’s difficult to predict specific areas for testing. The best thing to do is to study all of it. We’ve provided the key highlights for the four most frequently tested supplemental resources.

1. Instructions for Preparation of CBP Form 7501

Although most entry summaries are completed electronically, it’s important to have a good understanding of the information contained in this document. By reading these instructions, you can complete a CBP 7501 by hand without the assistance of a computer. You should keep this document handy and review all blocks because it has been one of the most frequently tested supplemental resources since the implementation of the new CBP 7501 format in September 2005. Become very familiar with each block number, so you can easily reference it. Block 2 (Entry Type Code) and Block 31 (Net Quantity) are easy targets!



2. CD 3510-004 - Monetary Guidelines for Setting Bond Amounts

The purpose of the bond is to protect the revenue and ensure compliance. The amount of a bond is calculated using information on the bond application, the criteria in Part 113 of the CBP Regulations and the guidelines in this directive. This directive provides standardized guidelines for computing the bond amounts for all types of bonds. For the exam, it’s important to know how to calculate single entry and continuous bonds.

The first type of bond is the Activity 1, Importer or Broker Continuous Bond. The minimum amount of a bond in this category is $50,000.

For importers paying zero to $1,000,000 in duties and taxes, the bond should be computed as 10% of the duties and taxes paid for the previous calendar year and issued in increments of $10,000.

For importers paying over $1,000,000 in duties and taxes, the bond should be computed as 10% of the duties and taxes paid for the previous calendar year and issued in $100,000 increments.

The next type of bond is the Activity 1, Importer or Broker Single Transaction Bond. This bond is valid for one shipment and is computed in an amount not less than the total entered value of the merchandise plus all duties, taxes and fees, unless the merchandise falls into a special category. If the merchandise is subject to other government agency requirements such as the FDA or FCC, the bond will be computed in an amount of at least three times the total entered value of the shipment. In addition, the district director may set the single transaction bond amount at 10 percent of the total entered value for unconditionally free merchandise, which is not subject to the previously mentioned categories.

Note:
Not all of the government agencies are included in the list that requires a bond in the amount of three times the value of the shipment. If your goods are not regulated by one of the government agencies on the list, then the single entry bond will be written for value plus duty.




3. CD 3550-055 - Instructions for Deriving Manufacturer/Shipper Identification

Questions involving the manufacturer’s identification code “MID” should be some of the easiest to answer. Not only does this directive provide instructions on how to construct the code, but the information is also included in the CBP Form 7501 Instructions. Just memorize the rules for deriving the MID.

This code is commonly referred to as the MID or Manufacturer Identification Code. This technique is also known as keylining. On the broker’s exam from October 2005, a question required knowledge of the term keylining.

Customs requires the formation of a code from the name and address of the manufacturer.
The MID contains five components that are added together without spaces to create the code. The code can be up to 15 characters in length. The five components consist of the following information:


· Two letter abbreviation for the country of origin
· First three letters of the first name of the manufacturer
· First three letters of the second name of the manufacturer
· First four digits of the street address, and
· First three letters of the city name.

There are some general rules to consider.

· Ignore all punctuation
· Ignore single character initials. and
· Ignore the words “a”, “an”, “and’, “of”, and “the”.



4. 3550-067 - Entry Summary Acceptance and Rejection

Customs Directive 3550-067 provides guidelines for uniform acceptance and rejection of entry summaries. Five major areas of interest in this directive include the following:

· Collections Processing – Rejections
· Acceptance Review and Summary Processing
· Processing of Rejected Entry Summaries
· Time Limit
· Rejection Effect on Entry Summary Filing Time

This information is a little more complicated to grasp, so read each of the major areas and highlight key information.


Although we didn’t cover all of the directives and supplemental materials, they are not any less important. Remember the advice from the beginning of the article - the best thing to do is to study all of it.

We welcome your comments on these suggestions and encourage you to add your own ideas to this forum so that other students studying for the exam can benefit from your experiences. Check the Boskage Trade News regularly to find more useful news for international trade professionals! As soon as the Wizard obtains a copy of the test and has time to work out some preliminary answers, we’ll post them here for your review and comments.

Importers & Exporters Say The Darndest Things!

Let’s have a little fun this week. Have you ever heard one of your co-workers say something about international trade that made you want to hide under your desk, or something so funny you laughed aloud? Submit your shocking, scary and funny sayings to us! We will collect them until October 8th and publish the list the following week. We have provided a few to get you started.

1. I’m going to call Customs and demand they release our freight because I pay their salaries.
2. Can we just mark a couple of the pieces and send them to CBP? They won’t inspect all of them, will they? What happens if we don’t mark them?
3. Please destroy this email after reading it.
4. My customer won’t buy the socks if they are not made in the USA. Can I cut out the “Made in China” tag before shipping them to the customer?
5. We were told if we can’t figure out the exact classification to classify it under “other.”
6. The bearings were made either in Germany, England, Italy or France. Just tell Customs they were made in Germany.
7. Exporting is the opposite of importing.

Click on "Comments" to submit the "darndest things" you've heard about international trade.

CBE Study Tip 11: Free Trade Agreements

With the increase of free trade agreements between the U.S. and other countries, the number of questions on the CBE related to these agreements has increased. In fact, “Trade Agreements” often has its very own section of questions on the exam. Free Trade Agreements (FTAs) are international agreements made between two or more nations that relate to common trade or service issues. FTA’s reduce or eliminate all tariffs and other restrictions on substantially all the trade in goods between its member countries based on country of origin.

The information needed to answer questions about FTA’s is likely to be found in one of four places, the General Notes of the HTSUS, Chapters 98 an 99 of the HTSUS, 19 CFR Part 10 and 19 CFR Part 181. Memorize the titles of these General Notes and skim the text to become familiar with the topics covered in each. In your review of the programs, concentrate on the basic requirements such as tariff shift, de minimis and RVC requirements. Each program has different requirements regarding allowance of the special duty treatment, and some of these programs are subject to change. Most of these programs have very detailed requirements that must be met in order to claim the duty-free status. Additionally, these programs are often difficult to understand, and some have limited use in daily practice. Try not to be too overwhelmed when encountering these problems. If they appear too difficult, move and come back to them later.

Don’t overlook important terminology. Be sure to know the definitions for each of the following:

· Accumulation
· Direct Cost of Processing
· De Minimis
· Imported Directly
· Transshipment
· Regional Value Content RVC
· Tariff Shift
· Substantial Transformation

To view a list of the FTAs, the references to the HTSUS General Notes, SPI and CFR references, click HERE.

We welcome your comments on these suggestions and encourage you to add your own ideas to this forum so that other students studying for the exam can benefit from your experiences. Check the Boskage Trade News regularly for more helpful hints on studying for the Customs Broker Exam and other useful news for international trade professionals!

Check Out Border Wars and Border Simulation

Border Wars is a television show on The National Geographic Channel featuring CBP agents/officers as they enforce U.S. laws, fight terrorism and intercept persons trying to enter the U.S. illegally. In its second season, the show appears on Wednesday evenings at 9:00 pm Eastern Time. Check the schedule for more information on the show and upcoming episodes.

Would you like to experience a “day in the life” of a CBP officer working at a port of entry at the border? In this simulation, you will be able to select to patrol at a point of entry or in the desert. As an office at the port of entry, you will encounter people trying to enter the country and make decisions on whether to grant entry or do a more intensive investigation. Will you make the correct decision? On patrol, you will patrol on an ATV or in a helicopter and make life or death decisions. Click HERE to participate in the Border Patrol Simulation. Then click on “You Are A Border Agent” to start the simulation. Enjoy! Maybe CBP will create some additional simulations for other areas such as C-TPAT Validations, Focused Assessments and more!

CBE Study Tip 10: Valuation

Customs Valuation (19 CFR 152) is one of the most complex parts of the regulations. This section is one of the most frequently tested on the exam, and the questions are often long and time consuming to answer. When reading Part 152, it would be wise to read each section slowly in order to understand the complex terms discussed. Pay close attention to any examples provided because they help explain and demonstrate the complicated concepts. Highlight important areas of text. Make notes and lists in the margins. Locate the valuation questions in old exams and work through the questions. Make sure to mark each section of the regulations that was used in determining the answers.

Click HERE to view an outline of the most important valuation information found in 19 CFR 152. Read and highlight these sections in your copy of the regulations. Take this outline to the exam with you for a quick reference tool.

Stay tuned to Boskage Trade News for more helpful hints on studying for the Customs Broker Exam!

Government Spotlight: International Trade Administration

As part of the Department of Commerce, the International Trade Administration (ITA) promotes world trade and is the official U.S. government organization that coordinates all issues concerning trade development, international economic policy, and programs and trade administration. The ITA’s mission is to create prosperity by strengthening the competitiveness of U.S. industry, promoting trade and investment, and ensuring fair trade and compliance with trade laws and agreements. ITA ensures that U.S. industry’s commercial interests are represented in trade negotiations, bilateral and multilateral discussions, and the U.S. rulemaking process.

Unfair foreign pricing and government subsidies prevent the free flow of goods and adversely affect American business in the global marketplace. When that happens, the International Trade Administration can take enforcement actions. ITA’s Import Administration (IA) is the agency’s lead unit on enforcing trade laws and agreements to prevent unfairly traded imports and to safeguard jobs and the competitive strength of American industry.

The ITA provides information and services in some of the following areas.
· Antidumping
· Foreign Trade Zones
· General Export Assistance
· Steel Licensing


Click HERE to learn more about to topics covered by the ITA.

Check out the U.S. Export Fact Sheet containing an overview of various export statistics.

View Tradeology – the official ITA blog

CBE Study Tip 9: How to Use the HTSUS - Part 2

Classification is a skill that takes time to develop, but the more effort put into the process, the faster one will become more proficient. The actual process of classification is very complex, almost like reading a foreign language. It is important for both experienced and beginner to understand that the strategy for answering classification questions on the brokers exam is a little different from the process used for classifying goods for your companies on a daily basis. The basic steps discussed are similar to those used in daily transactions, but there is more to the process for those classifying goods on a regular basis. On the exam, you won’t be able to consult with experts or use the Cross Rulings Database. Remember, the average time allotted per question on the exam is three (3) minutes. In actual practice, you would likely spend more than three minutes trying to classify a product. The primary difference between classification on the exam and classification in a business situation is that the exam provides five (5) possible answers, and you know that one of those answers is correct. In real life, you aren’t provided with a set of answers in which you know for certain one is correct. Another difference is that classification questions found on the exam are intentionally complicated and sometimes tricky. Thus, there is a need for a slightly different strategy for answering the questions on the exam.

1. Read the question carefully and make note of the details.
The first step in answering any classification question involves a careful, thorough reading of the question and making note of the details provided. Some of the details may be critical to answering the question correctly. Remember, exam questions have been carefully worded and may be tricky, so some of the details may be not be necessary. You may want to highlight the details as you read the question.

2. Look up each answer and eliminate those that are clearly incorrect.
The second step for answering classification questions is to look up all the answer selections and eliminate those that are clearly incorrect. This process may be more difficult than it sounds. Classification questions are typically written in such a way that all or most of the answers appear to be correct. The best way to answer them is by a process of elimination. Consider the following example.

What is the classification of a woven nylon scarf measuring 55 cm x 50 cm?

A. 6214.30.0000
B. 6214.40.0000
C. 6213.90.1000
D. 6117.10.2030
E. 6117.10.6020

Notice that the answers are found in two different chapters, so it is likely that we will be able to eliminate one of the chapters. Indeed, we can eliminate Answers D and E easily because Chapter 61 covers knit articles and our scarf is woven.

3. Read Chapter and Section Notes
The third step is to review the Section and Chapter Notes to make sure that there is not any information there that would preclude one or more answers. Section and Chapter Notes provide valuable information about what items are specifically included and excluded as well as useful definitions. Because of the time constraints, it would be easy to skip the Notes; therefore, the writers of the Exam intentionally include questions that require the applicant’s ability to use the Notes. Remember, the Notes can be long and many of them will not be related to the classification you are checking. You must learn to scan the notes for significant headings and keywords. If you still have several potential answers at this stage, the Notes may help you make a determination between them. You should do this even if you only have one answer remaining after the elimination step. If you have eliminated all answers but one when you reach this step and find a Note that eliminates that answer, you will have to start over to find the answer you have eliminated incorrectly. Let’s go back to the scarf.

Answer B should be eliminated because the provision is for artificial fibers and our scarf is nylon, which is a synthetic fiber. If you did not know whether nylon was artificial or synthetic, Chapter 54 and 55 covering man-made fibers would help. It would appear that Answer A is the correct selection for our scarf; however, Chapter 62 Note 7 explains that scarves that measure less than 60 cm should be classified as handkerchiefs under 6213. This is a prime example of the importance of reading the Notes. If we had overlooked the Notes assuming that 6214.30.0000 specifically describing our product was correct, we would have answered the question incorrectly.


In most situations, you will be able to answer questions using these steps; however, there may be a few questions that require an additional step involving the application of the General Notes and/or GRI. For example, a question may require you to select the appropriate duty rate. Once you’ve located the appropriate HTS number, you will select a duty rate based on the country of origin. Given the origin, you may need to check the General Notes to determine if the country is included or excluded from certain free trade agreements.

Now that you are familiar with the organization of the HTSUS and have some tips on how to answer classification questions, it’s time to practice these skills. One of the best ways to practice for the exam is to take past exams. Old exams can be found on CBP’s website. For detailed instruction on classification and related topics, check out our online courses at bcpLearning.com.

Stay tuned to the Boskage Trade News for more helpful hints on studying for the Customs Broker Exam! The next article will cover “Valuation.” We also welcome any suggestions on topics you would like to see discussed.

Who Is In Charge Of Trade Compliance?

An important and somewhat sensitive question related to responsibility for compliance was recently asked of the ICPA membership. As companies look for ways to reduce the number of employees and cut costs, a function that doesn’t generate revenue, such as trade compliance, might have a big bullseye painted on it. We would like to take a short poll to determine how companies manage their trade compliance responsibilities. Participate in our poll located on the top right side of the blog and check back to see how your colleagues respond.

Trade compliance functions for my company are performed:

 Externally for imports
 Externally for exports
 Internally for imports
 Internally for exports
 Compliance? What Compliance?

Feel free to post your comments for and against outsourcing trade compliance.

CBE Study Tip 8: How to Use the HTSUS - Part 1

In Study Tip 7, we provided some suggestions on how to read the CBP Regulations. In this article, we provide some tips on the key components and arrangement of information contained in the Harmonized Tariff Schedules of the United States (HTSUS). The next article will provide some helpful information on how to answer exam questions.

If you want to pass the Exam, no subject is more important than classification. On each test, classification accounts for 15% - 25% of all questions asked. If you are not experienced in this process or have not dedicated sufficient study to this area, your chances of success are more uncertain. The good news is that by focusing on some basic skills, developing a strategy and answering questions from previous exams, both experienced and beginning students can achieve success! To begin your study of the HTSUS, you should familiarize yourself with the key components and arrangement of information found in the HTSUS. Then, organize your book in a way that allows you to find information quickly. The following points will assist you with these tasks.

1. Familiarize yourself with the components of the HTSUS.

The HTSUS is similar to the CFR in that it is a reference text and not the type of book that is read from page one to the end. It is important to be familiar with the major parts so you will know where to look for answers and what information is the most important to read.

· General Rules of Interpretation (GRI) – The GRI appear at the beginning of the HTSUS and provide the primary rules for classification.

· General Notes – Covering over 500 pages, the General Notes provide instructions on special duty programs, free trade agreements, duty rates and other information necessary for proper classification and calculation of duties. The first three General Notes are the most likely sources of Exam questions; however, you should be familiar with the topics covered by all of the notes.

· Section and Chapter Notes - The Sections and Chapters contain notes that appear at the beginning of each. Since these notes provide lists of goods specifically included or excluded from a particular section, chapter, heading or subheading and contain definitions of certain terms, it is important to read these notes when classifying imported products.

· Classification Tables - The Section and Chapter Notes are followed by pages of tariff numbers along with descriptions of the products, duty rates and any special rates associated with the tariff numbers. They also contain footnotes and quota code information that can be pertinent in classification questions.

2. Familiarize yourself with the arrangement of the HTSUS.

In the HTSUS, goods are logically arranged so they appear in headings beginning with the most basic substance, and ending with more advanced manufactured goods. This progression is found within the chapters and in the sections.

Section 11 is a good example of the progression. As indicated by the title, this section contains listings for textile and textile Articles. Chapter 50 contains silk threads, yards and fabrics, and Chapter 52 covers cotton threads, yarns and fabrics. Chapters 61, 62 and 63 contain articles that are manufactured from the silk, cotton and other raw materials covered in the previous chapters. Notice how the book progresses from a basic item—in this case silk and cotton—to the products obtained from the basic item.

3. Organize your HTSUS.

Similar to the hints we provided for the CFR, consider using tabs for your copy of the HTSUS. If you are looking for the chapter on cotton and you know that it's in the middle of the book, having a tab with the chapter number and cotton may enable you to locate the exact chapter more quickly. Here are a few suggestions for using tabs.

-Attach tabs to designate each of the 22 Sections, or
-Attach tabs to designate each of the 99 Chapters, or
-Use both Section and Chapter tabs
-Use tabs to mark the GRI and each General Note.
-Consider using different color tabs to designate different sections.

Note: Although you may use the online version of the HTSUS for your daily work, you will be required to use the paper version for the exam. Until the exam is over, try to use the paper version for all of your work and study related to classification. Developing this skill will make it easier for you to locate the correct answer on test day. You can go back to the online version after the exam!

Now that you are familiar with the key components and arrangement of information in the HTSUS, it’s time to learn techniques to answer exam questions. CBE Study Tip 9 will provide suggestions to help you prepare your strategy for answering classification questions on the exam. Stay tuned to Boskage Trade News for more helpful hints on studying for the Customs Broker Exam! Please feel free to add your comments, suggestions for topics you would like to see covered and other useful information to the blog!

Criminals Work Hard On Labor Day Weekend

While many honest hardworking Americans were enjoying a long three-day holiday, it was the perfect time for criminals to start working. You may have stopped your mail/newspapers, set the timers on the lights in your home and had your car checked out before hitting the road for the last big weekend of summer, but there is probably one thing you forgot to check….. your bank accounts.

What is the crazy Wizard talking about? Why would we need to check our bank accounts before the holiday weekend? Got paid on Friday and have money to spend, what else do we need to know? The short answer – criminals like to work on long weekends when the banks are closed. See where this is going or do you still think the Wizard must have partied too much last weekend? If a criminal gains access to your banking information, they can spend lots of your hard-earned money over a holiday weekend while you are away and the banks are closed. The thieves probably didn’t obtain this information while you were on vacation or even the week before. They may have obtained the information a month or more before the holiday, just waiting until the next time the bank takes a long weekend holiday. Whether using your bankcard information or your checking account numbers, the thieves know that banks will be closed, and people are less likely to check their accounts during the holidays. Another plus for criminals is that many people are paid on Fridays, so it is likely that the targeted accounts contain more funds on a Friday. Then how did the thief obtain your information?

Bank card skimmers are popular for recording bankcard numbers and PINs. Have you visited the ATM or bought gas using your ATM card lately? Check out this video to learn more about skimmers. Check fraud is the other growing method of robbing hard-working Americans of their money. There are numerous ways criminals can obtain your checking account and bank routing number to create new checks.

It was check fraud and unauthorized electronic debits that consumed the first 24 hours of the Wizard’s Labor Day Weekend. The Wizard reviews bank accounts online at least once a week. Last week the Wizard checked late Thursday night to verify a deposit had been made. All was well. The Wizard checked again for another deposit a little after 9 pm on Friday night and was shocked to find a lower than expected balance. Upon close inspection, the Wizard discovered that two very large purchases had been made at WalMart. Who spends over $1400 at WalMart? Not the Wizard! Of course, it was holiday weekend and the customer service department at the bank was closed for the day. How much more money was this thief going to take before the account could be closed? After talking to a helpful bank employee working late in another department, we started the ball rolling. If theft wasn’t bad enough, now the Wizard and the bank manager had to expend time canceling old accounts and setting up new ones. Not only is money being taken, which is a felony, but these crimes utilize a lot investigatory hours by fraud investigators from banks and the local law enforcement officers.

Next on the list was filing a report with the police department. These criminals almost always leave a paper trail, so the police detectives are on the case now. Fortunately, a branch of the bank was open on Saturday morning, and we were able to shut the accounts down, but not before “he” cashed two more checks. I say “he” because we were able to view the canceled checks. The checks contained the name, address and driver’s license number of a person who is NOT the Wizard, but the account and bank routing number belonged to the Wizard’s checking account. The interesting thing was that the check was imprinted with the name of a bank, but the bank shown not where the Wizard banks. Now, we have check fraud and unauthorized ACH debit cases open for the bank’s investigators to dig into. To further complicate matters, these crimes are considered felonies. The good news is the thief might do a little time. The bad news is the person will be less likely to find a job to become a productive citizen with a felony record, even if he really wanted give up his life of crime. Would your company hire someone with a felony record involving theft of funds? If you aren’t sure, customs brokers should check 19 CFR 111.53(e) and importers should review some of their C-TPAT guidelines. So, what will the criminal do to earn a living once convicted of a felony involving theft of funds?

The Wizard hopes you’ve enjoyed the long weekend. Just remember, check your accounts before and after a three-day weekend. Even though you are not working and banks aren’t open, the criminals are working hard to separate you from your hard-earned money.

What's New in Counterfeit Imports?

When people mention counterfeit goods, items such as Rolex watches, Gucci handbags, Nike apparel, CDs and other software come to mind. So, what is the latest trend in counterfeiting? Exercise Equipment. Why would someone want to counterfeit exercise equipment? How would a purchaser or user know the equipment was counterfeit? CBP states that counterfeit equipment may be manufactured overseas using inferior design and construction, and may contain substandard components, which could lead to pulled muscles and various other injuries. Counterfeited fitness products range from DVDs, to gym equipment and some of the products seen on infomercials. CBP notes that the AB Circle, Bowflex and P90X are the most frequent target for infringement.

In fiscal year 2009, CBP made 26 seizures related to counterfeit exercise equipment with a domestic value of approximately 834,000. In just the first five months of FY2010, CBP made 57 seizures with a domestic value of over $2 million. CBP indicates that counterfeit goods are commonly sold on eBay and Craigslist CBP encourages consumers to take a close look before purchasing or using exercise equipment and provided the following helpful hints.

· Consider the method of sale –check the manufacturer’s website for authorized retail outlets and/or websites. New equipment sold on eBay or Craigslist at a price significantly lower than the MSRP may raise a red flag.

· Look for a warranty – most reputable manufacturers provide warranties.

· Inspect the packaging – most genuine fitness products include nutritional guides and instructional manuals. Counterfeited goods may be missing instruction manuals or the manuals are poorly written.

You can find information about various products registered for protection by CBP by searching the Intellectual Property Rights Search (IPRS) database. For example, typing in “fitness” in the keyword block yields 71 results. For additional information about protection of intellectual property and trends in counterfeit goods, check out the following resources.

Stopfakes.gov

CBP – Intellectual Property Rights

Source:
Lynn Hollinger. (2010). Dangerous New Trend in Counterfeit Imports: Inferior, Dangerous Fitness Equipment. Frontline , pp. 13-14.

Export Reforms Update

Realizing that the current export control systems were not effective or efficient, the government has taken action to create a better system. In April, Defense Secretary Gates unveiled the plans to simply the export process by consolidating export functions. These changes included combining the CCL and USML, creating a single licensing agency to have jurisdiction over defense and dual-use items, creating a single agency to enforce export controls and implementing a new information technology system.

In Washington, D.C. this week, the Bureau of Industry & Security is holding a conference – Update 2010 Export Controls in Transition. It should be no surprise to see export reform as a key topic for this conference.

President Obama presented opening remarks concerning export reform via video. Similar to the information presented in April, the President reiterated the commitment to a single control list, a single set of licensing policies and a single information technology system. Although much of the reform requires new statutory authority approval by Congress, work is underway to put these processes in place. Slightly different from the initial announcement of a single agency to enforce export controls, the President announced the creation of the Export Enforcement Coordination Center to coordinate and strengthen enforcement activities and eliminate gaps and duplication between the relevant agencies. This leaves the question, will there be one enforcement agency or multiple enforcement agencies operating under the new EECC? From the comments in April, it sounded like one agency, but the use of the "coordination" language may mean something different is in store.

Commerce Secretary Gary Locke focused on the benefits of the new system, such as placing more focus on the high-risk dual-use technologies posing the highest risk to the U.S. and less scrutiny on an expanded list of items that carry little or no risk. Locke noted that reforming the licensing system will free up resources, such as enforcement agents who can focus on the on interdicting the high-risk exports. The main goal of the new initiative is to allow U.S. companies to be more competitive by reducing some of the time consuming government processes while allowing the government to focus on enforcement to keep America safe.

Stay tuned for more information on the progress of export reform!