October 11, 2011
Compliance with AES
A Practical approach
About Teradyne
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Founded:
Global headquarters:
President and CEO:
Employees:
Stock ticker:
2010 Sales:
About:
1960
600 Riverpark Drive, North Reading, MA
Michael A. Bradley
3,000 worldwide
NYSE:TER
$1,566M
Teradyne is the leading supplier of Automatic
Test Equipment used to test complex
electronics used in the consumer electronics,
automotive, computing, telecommunications,
and aerospace and defense industries.
Our products
Summary
Management of Export filings is more important today than in the
past.
1. Information is electronic and violations can be easily (auto)
identified by enforcement.
2. US Customs is enforcing EEI compliance
3. Penalties are being issued for minor clerical errors.
Exporters must review their export compliance procedures to ensure
a high level of compliance. Current controls may not be adequate.
1.
2.
3.
4.
Manage forwarders closely
Maintain proper procedural checks and controls
Recordkeeping
Audits
Checking exports for accuracy
Teradyne shippers
must complete a
pre and post
shipment
checklist for every
shipment
Checking exports
Was the “Port of export” filed correctly?
Was the correct “Date of export” filed correctly?
Port codes can be confusing.
“if the export information is wrong, then penalties
are possible. Given the number of shipments that
FedEx does for exporters, the number of penalties
could mount very rapidly.”
Robert C. Rawls
Outbound Branch Chief
U.S. Customs and Border Protection
Example: Would you be concerned if a forwarder
provided you with a port code of 2704 for shipment
from LAX?
2704-LOS ANGELES, CA
2709-LONG BEACH, CA
2720-LOS ANGELES INT ARPT, CA
2770-DHL, LOS ANGELES, CA
2775-TNT EXPRESS, LAX, CA
2791-DHL-HUB LOS ANGELES, CA
Audit your
exports
Do you request a copy
of your ETRAC export
information via FOIA for
audit purposes?
Once per year is free!
You may be surprised
when you review the
data.
Forwarder management
• Do you manager your Power of Attorney?
• Does shipping provide the forwarder a signed SLI?
• Do you have a SOP in place with your forwarder?
• Has the forwarder agreed to indemnify you if they cause a violation and
you are penalized?
• Do you provide a signed SLI for routed shipments? The forwarder may be
listing you as the exporter.
• Do you require communication between exporter and forwarder to be in
writing?
Do you permit Routed shipments?
Teradyne does not recommend the use of routed shipments.
- Standard Incoterms are FCA or DAP
- Teradyne has full control over EEI submission, can access and edit via AES
- Customer friendly policy, Teradyne is providing a service to our customer
- Reduces export delays, customer / forwarder are not experts at exporting Teradyne
products, we are.
BIS Best Practice #4 – “Companies should avoid routed export transactions when
exporting and facilitating the movement of dual-use items”