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AES COMPLIANCE UPDATE

AES COMPLIANCE UPDATE. Presented by : Paul Divecchio –DiVecchio & Associate Phone: (617) 513-3230, Fax: (508) 393-3645 Email: pauldivec@earthlink.net. AES TODAY – COMPLIANCE AMBIGUITY of Interpretation ROUTED – FPPI HAS TOO MUCH AUTHORITY

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AES COMPLIANCE UPDATE

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  1. AES COMPLIANCE UPDATE Presented by : Paul Divecchio –DiVecchio & Associate Phone: (617) 513-3230, Fax: (508) 393-3645 Email: pauldivec@earthlink.net

  2. AES TODAY – COMPLIANCE • AMBIGUITY of Interpretation • ROUTED – FPPI HAS TOO MUCH AUTHORITY • Enforcement Oversight - INCONSISTENT

  3. AES REGS. – PROPOSED A GOOD START!!!: • Some CLARITY- Needs More • Comprehensive Data Elements • ROUTED not adequately addressed • Governing Agencies not Adequately Engaged • Exporters Better Take it SERIOUSLY • Forwarding Industry in for a “Wake Up Call”

  4. NEW AES:KEY ISSUES • END USER – “KNOWN” • ULTIMATE CONSIGNEE - TYPE • POST DEPARTURE? • FINAL REG. –PUBLISHED/IMPLEMENTED??????

  5. Export Compliance Decisions IT OUT, NOT: WHEN IN WHEN IN IT OUT 1. USE COMMON SENSE!! Everybody Has it?? 2. Document Decisions Demonstrate your D2 “Due Diligence” 3. Abide by the Exporters Cardinal Rule

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