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The Canada Border Services Agency (CBSA) has proposed a controversial amendment to the rules governing the valuation of imports into Canada under the Valuation for Duty Regulations. One of the items causing concern is a proposed change to the term “sale for export”. The CBSA stated the following in a consultation notice:
“This proposal would ensure that the value for duty of imported goods determined under the transaction value method is based on the sale that causes the goods to be exported to Canada, i.e. the last transaction in the commercial chain, irrespective of the chronological order of the sales. Under the proposal, the term "sale" would be constructed in a broad sense, which would include any type of arrangements that cause the goods to be exported to Canada.”
One concern is that the above broad definition of “sale for export” could lead to a situation wherein a subsequent domestic sale in Canada for a higher price for the merchandise being imported could be construed as the last transaction in the chain that caused the goods to be exported to Canada. This could then lead to higher determined valuation amounts and increased duty liabilities.
A multinational organization based in Bangkok, Thailand, has agreed to pay $20,000,000 to settle potential civil liability for 467 apparent violations of OFAC sanctions on Iran. Between 2017 and 2018, the company facilitated $291 million in wire transfers through U.S. financial institutions for the sale of Iranian-origin high-density polyethylene resin (HDPE), manufactured by a joint venture involving the parent company in Iran. HDPE is a robust resin used in various plastic products such as food and beverage containers, shampoo bottles, and industrial items. Concurrently, the company initiated U.S. dollar wire transfer transactions to settle the joint venture’s debts to third-party vendors.
BIS has released the newest iteration of their guidance on export enforcement. The “Don’t Let This Happen to You” guidance document is dated March 2024 and is 76 pages of important guidance for the export community. The opening letter states “Export controls have never been more important to our collective security interests than they are today.” Follow the link below to check out more details!
The U.S. Customs and Border Protection (CBP) has issued a Withhold Release Order (WRO) against work gloves manufactured in a Chinese company and its subsidiaries, based on evidence suggesting the use of convict labor. This action is part of the U.S. government's efforts to combat forced labor globally. With nearly 28 million workers suffering under such conditions worldwide, WROs are a means to deter companies from exploiting labor and to protect vulnerable populations. By enforcing laws prohibiting the importation of goods produced by forced labor, CBP aims to safeguard American workers, businesses, and consumers. Currently overseeing and enforcing numerous WROs and Findings, CBP emphasizes its commitment to eliminating forced labor from U.S. supply chains and encourages reporting of suspected violations.
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