I am always amazed about how many forwarders I speak with have so much difficulty understanding 15 CFR Part 30 rules (Foreign Trade Regulations: Mandatory Automated Export System Filing for All Shipments Requiring Shipper's Export Declaration Information). And I am floored of how many have never even heard of the EAR (Export Administration Regulations), BIS (Commerce Department's Bureau of Industry and Security) or OFAC (Treasury Department's Office of Foreign Assets Controls), much less know that there are regulations and requirements. Forget about understanding them.
And you may think this issue is just with very small forwarders. Yes, they are a large portion of the uneducated forwarding force, but even the very large ones most often lack the knowledge and understanding. The e-mails I sometimes receive on behalf of exporters are a disgrace, and I am embarrassed for the industry that I used to make a living from.
Since forwarders are the “middlemen” as you say, and there are only a few thousand of them, it would be so much easier of BIS and the Census Bureau to create some mandatory training and re-occurring certifications. We would be in so much better shape as a nation and as an industry. I know it is very difficult, almost impossible for BIS and Census to reach out to all the exporters, there are just too many out there.
But then again, when I speak to the administrators at Census or BIS, most recently two weeks ago during the BIS Update 2009, they have a hard time understanding the issues and difficulties and are not really keen on trying to go out and train all forwarders. Yes, they like these big settlements — but that should only be the beginning and a last resort.
The October Shippers’ Case Law (page 45) also had two interesting cases. Thanks for bringing these to the readers.
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| Saphir |
These things happen when we all are on “autopilot” letting computers, schedules and procedures run our business instead of some simple common sense applied by well-trained and knowledgeable people.
Albert Saphir
ABS Consulting, Weston, Fla.
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