2006 texas brokers forwarders conference

1. 2006 Texas Brokers & Forwarders Conference

2. Today’s Topics will include a discussion on … Today’s Topics will include a discussion on …

3. U.S. Principal Party in Interest (30.4) The U.S. Principal Party in Interest is the: U.S. Person or Entity Primary Benefactor (Monetary, or Otherwise) Foreign Entity (if in the U.S. at time goods are purchased or obtained for export) Generally that Person can be the: U.S. Seller: (Wholesaler or Distributor) U.S. Manufacturer U.S. Order Party Foreign Entity (If in U.S. at time goods purchased or obtained) A U.S. Principal Party in Interest is the person in the United States that receives the primary benefit monetary or otherwise of the export transaction. You could be benefiting by receiving a service. And as my boss, Jerry Greenwell, always says if you accept the check sign the dec. Generally that Person Can Be The: U.S. Seller: (Wholesaler or Distributor) U.S. Manufacturer: If they sell the merchandise directly For domestic shipments the last person who received the goods in the US would be listed as the USPPI. U.S. Order Party: Party who directly negotiated between the U.S. Seller and the foreign buyer and received the order for the export of merchandise Foreign Entity: If in the U.S. when items are purchased or obtained for export. The foreign entity would use the hotel address of where he stayed for the USPPI address and for the EIN he would report the passport # or border crossing number For example: if a Mexican party comes to the U.S. to purchase 100 t.v.’s from Wal-Mart and Wal-Mart ships the microwaves to Mexico. The USPPI in this scenario is the foreign entity because he was here at the time the goods were purchased. ----------- The freight forward is rarely shown as the USPPI. The instances where they would be list is…1.)order party 2.)carnet 3.) acts as a broker and imports the goods for the foreign party. A U.S. Principal Party in Interest is the person in the United States that receives the primary benefit monetary or otherwise of the export transaction. You could be benefiting by receiving a service. And as my boss, Jerry Greenwell, always says if you accept the check sign the dec. Generally that Person Can Be The: U.S. Seller: (Wholesaler or Distributor) U.S. Manufacturer: If they sell the merchandise directly For domestic shipments the last person who received the goods in the US would be listed as the USPPI. U.S. Order Party: Party who directly negotiated between the U.S. Seller and the foreign buyer and received the order for the export of merchandise Foreign Entity: If in the U.S. when items are purchased or obtained for export. The foreign entity would use the hotel address of where he stayed for the USPPI address and for the EIN he would report the passport # or border crossing number For example: if a Mexican party comes to the U.S. to purchase 100 t.v.’s from Wal-Mart and Wal-Mart ships the microwaves to Mexico. The USPPI in this scenario is the foreign entity because he was here at the time the goods were purchased. ----------- The freight forward is rarely shown as the USPPI. The instances where they would be list is…1.)order party 2.)carnet 3.) acts as a broker and imports the goods for the foreign party.

4. Two Types of Transactions(FTSR 30.4) Export Transaction (Standard): USPPI files the AES record or appoints an authorized U.S. agent to facilitate the export of items out of the United States. Routed Export Transaction: Foreign Principal Party in Interest (FPPI) appoints an authorized U.S. agent to facilitate the export of items out of the United States. A Standard Export Transaction is where the USPPI files the SED or AES record or authorizes a U.S. forwarding or other agent to facilitate the movement of the exports out of the United States. A Routed Export Transaction is where the foreign principal party in interest authorizes a U.S. forwarding or other agent to facilitates the movement of the exports out of the United States. When making a distinction between the two types of transactions you need to look at who is directing the movement of the goods. And then that person is responsible for providing the POA A Standard Export Transaction is where the USPPI files the SED or AES record or authorizes a U.S. forwarding or other agent to facilitate the movement of the exports out of the United States. A Routed Export Transaction is where the foreign principal party in interest authorizes a U.S. forwarding or other agent to facilitates the movement of the exports out of the United States. When making a distinction between the two types of transactions you need to look at who is directing the movement of the goods. And then that person is responsible for providing the POA

5. Export Transaction USPPI Responsibilities: Appoints Authorized U.S. Agent to facilitate the movement of cargo Provide POA to the Authorized U.S. Agent Responsible for License Determination Authorized Agent Responsibilities: Provide Transportation Data USPPI Will authorize a forwarding agent or other agent to move the cargo. They then must submit the export information with a power of attorney to the forwarder In addition to providing the forwarder with export information they also responsible for the license determination. But it is also very important that the USPPI maintains documentation on this transaction. Forwarder Will provide the transportation data Report accurate and complete export information Obtain the authorization from the USPPI Provide the USPPI with a copy of the export information that was filed if requested. Maintain documentation to support the export information reported.USPPI Will authorize a forwarding agent or other agent to move the cargo. They then must submit the export information with a power of attorney to the forwarder In addition to providing the forwarder with export information they also responsible for the license determination. But it is also very important that the USPPI maintains documentation on this transaction. Forwarder Will provide the transportation data Report accurate and complete export information Obtain the authorization from the USPPI Provide the USPPI with a copy of the export information that was filed if requested. Maintain documentation to support the export information reported.

6. Routed Export Transaction USPPI: Must Provide Authorized U.S. Agent with Statistical Data & Licensing Information Upon request be provided with their copy of EEI upon completion by authorized U.S. agent Authorized U.S. Agent: Obtains a Power of Attorney or Written Authorization from the FPPI to Move Cargo Complete / File the EEI USPPI Provide the forwarder with the statistical data and licensing information. This includes their EIN. We receive in our office many calls from forwarders who say the USPPI will not give them their EIN. However, according to our regs they are required to provide this information. So if someone is giving you a problem and it is a routed transaction you can refer them to our office. In a routed transaction the USPPI can request a copy of their SED or AES record upon completion by the forwarder. So another thing you as a forwarder can do is to assure the USPPI that their information will be proper filed and to assure this you can provide them with a copy of the completed transaction As the USPPI you also want to maintain documentation as to what you sent the forwarder and the completed transaction. This is important because we receive calls from USPPIs saying that the forwarder will not give them a copy of the transaction. Freight Forwarder Obtaining a POA or written authorization from the FPPI Preparing and filing the SED or AES record Maintaining documentation USPPI Provide the forwarder with the statistical data and licensing information. This includes their EIN. We receive in our office many calls from forwarders who say the USPPI will not give them their EIN. However, according to our regs they are required to provide this information. So if someone is giving you a problem and it is a routed transaction you can refer them to our office. In a routed transaction the USPPI can request a copy of their SED or AES record upon completion by the forwarder. So another thing you as a forwarder can do is to assure the USPPI that their information will be proper filed and to assure this you can provide them with a copy of the completed transaction As the USPPI you also want to maintain documentation as to what you sent the forwarder and the completed transaction. This is important because we receive calls from USPPIs saying that the forwarder will not give them a copy of the transaction. Freight Forwarder Obtaining a POA or written authorization from the FPPI Preparing and filing the SED or AES record Maintaining documentation

7. Shipments Exempt from Filingthe EEI (FTR 30.35-30.40) $2,500 or less per Schedule B Number (30.55(h)) Intangible exports of software & technology (30.55(o)) Tools of Trade: hand carried, personal or company use, not for sale, returned within 1 year (30.56(b)) Country of ultimate destination is Canada (30.58) Current exemption provisions are given in Section 30.50-30.58 of the FTSR $2,500 or less per Schedule B Number (30.55(h)) Intangible exports of software & technology (30.55(n)) Tools of Trade: hand carried, personal or company use, not for sale, returned within 1 year (30.56(b)) Country of ultimate destination is Canada (30.58) $2,500 or less iff a license is not required. Intangible exports– 30.55 (n) talks about mass market Tools of the trade---Give Example Country of ultimate destination is Canada unless the goods are licensed or items that exported to Canada enroute to a third country Current exemption provisions are given in Section 30.50-30.58 of the FTSR $2,500 or less per Schedule B Number (30.55(h)) Intangible exports of software & technology (30.55(n)) Tools of Trade: hand carried, personal or company use, not for sale, returned within 1 year (30.56(b)) Country of ultimate destination is Canada (30.58) $2,500 or less iff a license is not required. Intangible exports– 30.55 (n) talks about mass market Tools of the trade---Give Example Country of ultimate destination is Canada unless the goods are licensed or items that exported to Canada enroute to a third country

8. AES Filing Citations Predeparture Filing AES Proof of Filing Citation AES ITN AES X20060621123456 Postdeparture Filing USPPI AESPOST USPPI EIN mm/dd/yyyy AESPOST 12345678900 01/01/2006 Authorized Agent AESPOST USPPI EIN – Filer ID mm/dd/yyyy AESPOST 12345678900 – 879456125 06/21/2006 Some of you that are not familiar with AES, may wonder what will I show my forwarder, or carrier, or Customs, if I am not reporting the 7525-V form? You will use these proof of filing citations, currently known as AES exemption statements If you are interested in other acceptable formats you can refer to our FTSR letter 168 amendment 2. This is an example of an AES proof of filing citation ITN when it is accepted by the system. And this is what you will get back. AES an X 2005 02 08 096045 This statement would be placed on the front page of the bill of lading, airway bill or other commercial documentation. The master copy is preferred over the house bills. Deliver the cargo and the exemption legend to the carrier. The examples listed here as “NO SED REQUIRED” followed by the filer’s ID number and shipment reference number. For example, here we have the company’s ID number, 123456789, followed by their shipment number, MIA001. You may also use the confirmation number back from the AES, as a part of the proof of filing citation, as shown here. Be sure the exemption is clear and easy to see by the inspector. If the inspector keys in the exemption number in AES he expects to see the transaction. If the shipment cannot be found by entering in your XTN or ITN, the shipment may be delayed or detained.  The shipment reference number must be unique for 5 years. Currently, you are allowed to use an XTN- which is the filer’s EIN followed by a dash and an unique shipment reference number. Most companies are moving away from using the XTN b/c they know that ITN is going to be mandatory with full mandatory AES filing. Letter 168 Amendment 2 for acceptable formatsSome of you that are not familiar with AES, may wonder what will I show my forwarder, or carrier, or Customs, if I am not reporting the 7525-V form? You will use these proof of filing citations, currently known as AES exemption statements If you are interested in other acceptable formats you can refer to our FTSR letter 168 amendment 2. This is an example of an AES proof of filing citation ITN when it is accepted by the system. And this is what you will get back. AES an X 2005 02 08 096045 This statement would be placed on the front page of the bill of lading, airway bill or other commercial documentation. The master copy is preferred over the house bills. Deliver the cargo and the exemption legend to the carrier. The examples listed here as “NO SED REQUIRED” followed by the filer’s ID number and shipment reference number. For example, here we have the company’s ID number, 123456789, followed by their shipment number, MIA001. You may also use the confirmation number back from the AES, as a part of the proof of filing citation, as shown here. Be sure the exemption is clear and easy to see by the inspector. If the inspector keys in the exemption number in AES he expects to see the transaction. If the shipment cannot be found by entering in your XTN or ITN, the shipment may be delayed or detained.  The shipment reference number must be unique for 5 years. Currently, you are allowed to use an XTN- which is the filer’s EIN followed by a dash and an unique shipment reference number. Most companies are moving away from using the XTN b/c they know that ITN is going to be mandatory with full mandatory AES filing. Letter 168 Amendment 2 for acceptable formats

9. AES Filing Citations Cont. EEI Exemptions (FTR 30.35-30.40) NOEEI FTR 30.36 NOEEI 30.36 Required on bill of lading, air waybill, or other commercial loading documents Shipments exempt from SED filing requirements must be noted on the Air Waybill, Bill of Lading or other loading document for the carrier. 30.36- canada exemption 30.37(a) low value shipmentShipments exempt from SED filing requirements must be noted on the Air Waybill, Bill of Lading or other loading document for the carrier. 30.36- canada exemption 30.37(a) low value shipment

10. AES Filing Citations Cont. With the post departure filing citation you don’t have an ITN prior to the export leaving the country so you can’t give Customs the ITN. So there has to be a separate unique post departure filing citation. That citation as noted above is NDR (no dec required) AES4 (option 4) the EIN of the approved USPPI not the filers ID dash the forwarders EIN Here are examples of Option 4 proof of filing citations… If the forwarder will file on behalf of the USPPI, then the following statement should be used. The NDR followed by the USPPI’s ID number then followed by the filer (forwarder’s) ID number. If the USPPI files Option 4 on their own, they will only list their own ID number as a part of the Option 4 statement; excluding the last half of the first statement Monitoring The AES branch monitors as best as they can the 1.4 million transactions they get into AES each month and they use automated tools to help them. They monitor both pre departure and post departure. They look at how many warning errors, verify messages you received. As well as they look to see if those corrections were made. AES also sends out monthly progress reports. They record the number of shipments reported reported by the filer each month and calculates a monthly error rate.With the post departure filing citation you don’t have an ITN prior to the export leaving the country so you can’t give Customs the ITN. So there has to be a separate unique post departure filing citation. That citation as noted above is NDR (no dec required) AES4 (option 4) the EIN of the approved USPPI not the filers ID dash the forwarders EIN Here are examples of Option 4 proof of filing citations… If the forwarder will file on behalf of the USPPI, then the following statement should be used. The NDR followed by the USPPI’s ID number then followed by the filer (forwarder’s) ID number. If the USPPI files Option 4 on their own, they will only list their own ID number as a part of the Option 4 statement; excluding the last half of the first statement Monitoring The AES branch monitors as best as they can the 1.4 million transactions they get into AES each month and they use automated tools to help them. They monitor both pre departure and post departure. They look at how many warning errors, verify messages you received. As well as they look to see if those corrections were made. AES also sends out monthly progress reports. They record the number of shipments reported reported by the filer each month and calculates a monthly error rate.

11. Exemptions Do Not Apply Commerce (BIS) Licenses State Department Licenses License Shipments from Other Government Agencies OFAC Prohibited Countries SEDs or AES transactions must be filed under all of the above conditions because exemptions DO NOT apply when shipments are subject to licenses sanctioned countries and trade restrictions.SEDs or AES transactions must be filed under all of the above conditions because exemptions DO NOT apply when shipments are subject to licenses sanctioned countries and trade restrictions.

12. Timeline for Mandatory Electronic Reporting Three Phases: Phase I: Mandatory Filing of Conflict Diamonds (April 25, 2003) Phase II: Mandatory Filing of USML and CCL Shipments (July 17, 2003) Phase III: Full Mandatory Filing The timeline of mandatory electronic filing for the Census purposes was broken into 3 phases. Phase I – required that all “raw and rough” diamonds that are exported under the Kimberly Process be reported through AES. Therefore any item that was exported or reexported under 7102.10, 7102.21, and 7102.31 be filed electronically. Phase II - required that those items on the United States Munitions list and the Commerce Control List that currently require a SED must be filed electronically in AES. These two phase occurred in October 2003 when final rules were published In June 2004 the commodity redesign came about to make the system work faster, and add additional edits to prepare for full mandatory AES filing. Now we are currently moving into Phase III which will require that all exports be filed electronically. When this takes place there will no longer be a paper option. We hope to have a final rule published by Fall 2005 about September. With an implementation date of the mandatory filing of the AES effective 90 days after the publishing date of the final rule in the Federal Register. On February 17, 2005, a Notice of Proposed Rule Making pertaining to the mandatory filing of export information appeared in the Federal Register. All comments were due by April 18. We received about 46 comments and they have been responded to. We are now in the process making the relevant changes, and then there will be a concurrence period with the other govt. agencies. The timeline of mandatory electronic filing for the Census purposes was broken into 3 phases. Phase I – required that all “raw and rough” diamonds that are exported under the Kimberly Process be reported through AES. Therefore any item that was exported or reexported under 7102.10, 7102.21, and 7102.31 be filed electronically. Phase II - required that those items on the United States Munitions list and the Commerce Control List that currently require a SED must be filed electronically in AES. These two phase occurred in October 2003 when final rules were published In June 2004 the commodity redesign came about to make the system work faster, and add additional edits to prepare for full mandatory AES filing. Now we are currently moving into Phase III which will require that all exports be filed electronically. When this takes place there will no longer be a paper option. We hope to have a final rule published by Fall 2005 about September. With an implementation date of the mandatory filing of the AES effective 90 days after the publishing date of the final rule in the Federal Register. On February 17, 2005, a Notice of Proposed Rule Making pertaining to the mandatory filing of export information appeared in the Federal Register. All comments were due by April 18. We received about 46 comments and they have been responded to. We are now in the process making the relevant changes, and then there will be a concurrence period with the other govt. agencies.

13. Full Mandatory Electronic Reporting Timelines Authority based in Trade Act 2002 New filing requirements Vessel - 24 hours prior to loading Air - no later than 2 hrs prior to departure Truck - no later than 1 hour prior to departure Rail - no later than 2 hrs prior to departure Other/Mail - no later than 2 hrs prior to departure ITN – Must be reported as the proof of filing citation Make sure you note the specific details of the time frame…For example. 24 hours prior to departure of the ship leaving the port By filing the information as far in advance as practicable reduces the need for CBP to delay export cargo of any screenings or examinations that may be necessary. This will enable CPB to perform their job more effectively. Currently, if you are filing an AES transaction that has items on the USML. The state department requires that you file air and truck 8 hours in advance, and rail and vessel 24 hours in advance. When the new regulations take affect CBP will start to enforce the above timeframes. If you are filing a state department shipment you will have to adhere to there regulations which require shipments that are going by air/truck to be filed 8 hours and vessel/rail to be filed 24 hours in advance.Make sure you note the specific details of the time frame…For example. 24 hours prior to departure of the ship leaving the port By filing the information as far in advance as practicable reduces the need for CBP to delay export cargo of any screenings or examinations that may be necessary. This will enable CPB to perform their job more effectively. Currently, if you are filing an AES transaction that has items on the USML. The state department requires that you file air and truck 8 hours in advance, and rail and vessel 24 hours in advance. When the new regulations take affect CBP will start to enforce the above timeframes. If you are filing a state department shipment you will have to adhere to there regulations which require shipments that are going by air/truck to be filed 8 hours and vessel/rail to be filed 24 hours in advance.

14. Reporting Timelines Trade Act 2002 Vessel 24 hrs Truck 1 hour Air 2 hours Rail 2 hours Mail 2 hours State Department Vessel 24 hrs Truck 8 hour Air 8 hours Rail 24 hours Mail 8 hours

15. Benefits of AES Improves compliance Improves trade statistics Reduces duplicate reporting Eliminates paper Saves time and money Maintains Compliance AES ensures compliance by returning a confirmation number for all accepted electronic export information. The unique Internal Transaction Number is your notification that your export shipment information has passed Census and CBP edits. Fatal response messages are returned for all rejected shipments and AES allows filers to correct these errors prior to exportation. Improves Trade Statistics Of the SEDs collected, 50 percent contain an error or omission. Census uses SED data for the monthly export trade figures. We do not want to publish data where the form we obtain the figures from is in error. AES because of its front-end edits has an error rate of less than one percent, thereby greatly improving the quality of export trade data. Reduces Duplicate Reporting AES reduces the redundant reporting of export information. Many authorized agents have reoccurring clients that export the same commodity over and over again. In a paper environment, a whole new SED must be created for each of those redundant shipments. In AES, you have the option to retrieve a template of that client or that commodity and change minimal shipment details prior to submission. Eliminates Paper Simply put, the AES system will eliminate the paper SED and the Vessel Carrier Outbound Manifest. Each USPPI or authorized agent must retain all SEDs for a minimum of 5 years. These are often kept in warehouses and file cabinets. By reporting the same information in AES, you can store the information electronically thus eliminating paper and saving space. Saves Time and Money It has been estimated that the entire process of filling out the original SED and passing it from the USPPI all the way to the Census costs between $18 and $75 per SED. Passing information electronically will save time and money. If a paper SED were to be filled out at any port in the US and sent to New York's JFK Airport in its original form, it would take at least one-day (express mail). To file the same information in AES electronically meeting the same requirements would take just minutes. Maintains Compliance AES ensures compliance by returning a confirmation number for all accepted electronic export information. The unique Internal Transaction Number is your notification that your export shipment information has passed Census and CBP edits. Fatal response messages are returned for all rejected shipments and AES allows filers to correct these errors prior to exportation. Improves Trade Statistics Of the SEDs collected, 50 percent contain an error or omission. Census uses SED data for the monthly export trade figures. We do not want to publish data where the form we obtain the figures from is in error. AES because of its front-end edits has an error rate of less than one percent, thereby greatly improving the quality of export trade data. Reduces Duplicate Reporting AES reduces the redundant reporting of export information. Many authorized agents have reoccurring clients that export the same commodity over and over again. In a paper environment, a whole new SED must be created for each of those redundant shipments. In AES, you have the option to retrieve a template of that client or that commodity and change minimal shipment details prior to submission. Eliminates Paper Simply put, the AES system will eliminate the paper SED and the Vessel Carrier Outbound Manifest. Each USPPI or authorized agent must retain all SEDs for a minimum of 5 years. These are often kept in warehouses and file cabinets. By reporting the same information in AES, you can store the information electronically thus eliminating paper and saving space. Saves Time and Money It has been estimated that the entire process of filling out the original SED and passing it from the USPPI all the way to the Census costs between $18 and $75 per SED. Passing information electronically will save time and money. If a paper SED were to be filled out at any port in the US and sent to New York's JFK Airport in its original form, it would take at least one-day (express mail). To file the same information in AES electronically meeting the same requirements would take just minutes.

16. AES Statistics July 2006 Number of AES Filers: 23,000 Number of Shipments: 1,106,000 Air: 600,000 Overland: 200,000 Vessel: 300,000 Other: 6,000 AES % of Export Trade: 97.2% July 2005 – 95.7% July 2002- 84%July 2005 – 95.7% July 2002- 84%

17. Fatal Errors Filers are required to correct all fatal errors Must be corrected prior to exportation to receive AES ITN Census will send follow-up e-mail messages twice a month Filers are required to correct all fatal errors - FTSR 30.64 (b) 3,700 Fatal Errors remain unresolved- These are errors that can be corrected but the company has failed to correct them. A systems generated message is sent to the filer immediately and a email report card is sent to the filer during weeks 1 and 3 of processing. Filers are required to correct all fatal errors - FTSR 30.64 (b) 3,700 Fatal Errors remain unresolved- These are errors that can be corrected but the company has failed to correct them. A systems generated message is sent to the filer immediately and a email report card is sent to the filer during weeks 1 and 3 of processing.

18. Fatal Errors Continued Top Fatal Errors by Filers Ultimate Consignee Contact Last Name Ineligible Carrier Unknown Invalid USPPI Phone Number Format: Format must be NNNNNNNNNN (Where N=Number) USPPI Postal Code Not Valid For State

19. Fatal Errors Continued What happens when fatal errors are not corrected Verbal (Phone) Communication 1st Letter 2nd letter – deactivation notice 3rd and final letter Deactivation

20. How to get reactivated Filer must submit a letter to request reinstatement. If deactivated company uses: AESDirect company will be reactivated in 60 days from date of deactivation. Vendor or self programming company must retest software to reinstate filing privileges.

21. Reducing Paper and Fatal Errors High paper SED concentrations Laredo, TX JFK Intl. Airport, NY Miami Intl. Airport, FL L.A. Intl. Airport, CA Otay Mesa Station

22. AES Marketing Efforts Paper Filer Project Target top 50 companies filing paper SEDs (monthly) Educate USPPI/Forwarder on filing AES through Compliance Seminars and AES workshops As of June 2006, documents received is 37,000 (averaging 41,000 for the year)As of June 2006, documents received is 37,000 (averaging 41,000 for the year)

23. Proposed Initiative Company Audit Project Monthly team visits to companies meeting the following proposed criteria: Non compliant option 4 filers Companies reporting late Companies with large amount of unresolved fatal errors, etc. Audits scheduled to begin January 2007.

24. Delegation of Authority / Enforcement Department of Commerce Bureau of Industry and Security (BIS) Department of Homeland Security Immigration and Customs Enforcement (ICE) Customs and Border Protection (CBP) Department of Commerce BIS / OEE will pursue referrals from Census Department of Homeland Security ICE and CBP will identify violations at the ports All enforcement agencies have administrative procedures in place to process violations Department of Commerce BIS / OEE will pursue referrals from Census Department of Homeland Security ICE and CBP will identify violations at the ports All enforcement agencies have administrative procedures in place to process violations

25. Penalty Provisions Criminal Penalties Voluntary Self-Disclosure

26. Criminal Penalties $10,000 or imprisonment up to 5 years or both Knowingly Failure to file, submission of false or misleading information Furtherance of illegal actions Forfeiture penalties On the Failure to file – its when they knowingly file false/misleading information Forfeiture any person convicted could forfeit goods or interest in, or security of claim against export of goods that was subject of the violation On the Failure to file – its when they knowingly file false/misleading information Forfeiture any person convicted could forfeit goods or interest in, or security of claim against export of goods that was subject of the violation

27. Voluntary Self Disclosure Type of violation Description of misreported data When and how the violation occurred Identify involved parties Mitigating circumstances Each partnering agency has a disclosure process FTR disclosures for consideration should be forwarded to the Chief of the Foreign Trade Division Disclosure may be referred to enforcement agencies Each partnering agency has a disclosure process FTR disclosures for consideration should be forwarded to the Chief of the Foreign Trade Division Disclosure may be referred to enforcement agencies

28. Lessons Learned Know your Regulations Communicate with all involved parties Do not assume Ask Questions

29. Outreach and Education AES Compliance Conference $199 Seminar $60 Workshop ROEB, CAB, AES, CBP Upcoming Seminars in 2006: Seattle, WA Oct. 17, 2006 San Diego Oct. 19, 2006 Miami, FL Nov. 8, 2006

30. Tentative 2007 Cities San Francisco, CA Wilmington, NC El Paso, TX Brownsville/Galveston, TX Biloxi, MS Norfolk, VA Cleveland, OH Tucson, AZ Syracuse, NY Minneapolis, MN

31. Contact Information Joe A. Cortez jcortez@census.gov Joey Morales joey.morales@census.gov Phone : 301-763-2238