3-Way Audit to Ensure Compliance of the EEI Transmission

In a recent discussion held at the 2009 AAEI Annual Conference, it was noted that exporters heavily rely on freight forwarders to file their EEI (Electronic Export Information) to the US Census Bureau. Many shippers hand over the filing to their forwarders without any type of follow up, although the US PPI (Principle Party of Interest) is still ultimately responsible for non-routed cargo information.

A suggestion made by an attending compliance director stated that exporters should conduct a 3-way audit of the EEI transmission at the end of each year, completing the following three processes:

1. Solicit freight forwarders for the data that was filed on the EEI transmission. Freight forwarders are required, by law, to turn over this information to the US PPI.

2. Obtain all data from Census. Exporters can request up to 12 months of free EEI data.

3. Gather the data sent to the freight forwarder by the US PPI and compare all three, making sure they match.

BIS studies Reasons for Under-Used Export Licenses

The U.S. Commerce Department’s Bureau of Industry and Security wants to know why so many export licenses that it issues to companies appear to be unused or used for less than the authorized quantity or value limits.

The agency said in a Federal Register notice of inquiry Friday that it’s “particularly interested in whether characteristics of the export license application review process induce applicants to apply for greater authorizations than they need and, if such is the case, any costs associated with such applicants.”

BIS issues licenses for exports subject to the Export Administration Regulations. Most licenses are valid for two years.

A recent BIS review of export data from the government’s Automated Export System indicated that by the end of calendar year 2007, 48 percent of the licenses issued
in calendar year 2005 for the export of commodities had not been used at all. The agency also found that some licenses may have been used for less than their full quantity or value.

In addition, BIS said it has no basis for estimating whether a similar lack of use or under-use exists with licenses for software or technology exports because these exports are often “intangible and, therefore, not reported in AES.”

The agency requested that industry comments be received by no later than May 4. For more details and contact information, access the BIS Federal Register notice.

To learn more, visit the US Bureau of Industry and Security at www.bis.doc.gov

Export Licensing Statistics & Common AES Filing Errors

In the January 2009 issue of the Census Bureau’s AES Newsletter, Bureau of Industry and Security Senior Trade and Industry Analyst Gerry Horner an update on export licensing and common Automated Export System filing errors. He noted that in calendar year 2007 U.S. companies exported $2.8 billion of licensed items and $14.2 billion of items under a license exception, representing 0.2 percent and 1.2 percent, respectively, of overall U.S. exports.

For more on export licensing and common AES filing errors, read the entire article by visiting http://www.strtrade.com/wti/wti.asp?pub=0&story=30189&date=2%2F4%2F2009&company=