Larry Friedman Presented Webinar for International Compliance Professionals Association
November 21, 2014
By: Lawrence M. Friedman
On November 12, Chicago-based partner Larry Friedman presented a webinar for members of the International Compliance Professionals Association. The presentation was entitled “Mysteries of Customs Law: Right to Make Entry and Customs Business.” Both of these topics are often misunderstood aspects of customs compliance. The right to make entry is limited to the owner, purchaser, or in some cases the consignee of the imported merchandise. Given the complexity of modern supply chains, it is not always clear that the Importer of Record identified on the entry documentation is one of these named parties. Happily, Customs and Border Protection has taken a reasonable approach by broadly interpreting the “owner” of the merchandise to be a party with a financial interest in the import transaction. While this definition covers many potential importers, it does not include merely nominal consignees such as freight forwarders and consolidators. The definition of customs business is important in the corporate context because only a licensed customs broker may conduct customs business on behalf of another party. That means that compliance staff for a company may not conduct customs business on behalf of related importers, even though it is an efficient way to improve compliance across the corporate family. Again, Customs has taken reasonable steps to provide guidance to the trade. In this case, Customs has differentiated between compliance activity and customs business. Individuals may provide compliance advice not amounting to customs business to others without a license. More details on these topics can be found in the presentation slides here. Over 400 people registered for the program, which was well received by those who participated.
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