International Trade Finance

🔔 𝗥𝗕𝗜 𝗲𝗮𝘀𝗲𝘀 𝗰𝗼𝗺𝗽𝗹𝗶𝗮𝗻𝗰𝗲 𝗳𝗼𝗿 𝘀𝗺𝗮𝗹𝗹 𝗲𝘅𝗽𝗼𝗿𝘁𝗲𝗿𝘀 & 𝗶𝗺𝗽𝗼𝗿𝘁𝗲𝗿𝘀 On 1st October 2025, RBI issued a circular that will change the way banks and businesses handle closure of entries in EDPMS (Exports) and IDPMS (Imports). 🔹 What was the current regime? - For every export shipping bill or import bill of entry, AD Category-I banks had to close entries in EDPMS/IDPMS only after verifying supporting documents and payment/realisation proofs. - Even low-value transactions (₹10 lakh or less per entry) required the same level of scrutiny as high-value ones. - Reductions in invoice/shipping bill value were allowed, but only with documentation and approvals. - Consolidated declarations (clubbed entries) were not typically permitted. - Penalty/charges could be levied for delays in reporting or reconciliation. 🔹 What has RBI now changed? - Threshold introduced: For entries of ₹10 lakh or below per bill, closure can now be done based on self-declaration from exporters/importers. - Value reduction allowed: Any decrease in invoice/shipping bill value will be accepted solely on declaration, without further checks. - Quarterly consolidation permitted: Exporters/importers can now submit one combined declaration every quarter covering multiple bills. - Charges to be reviewed: AD banks must re-align their fee structure for such small-value transactions and cannot levy penalties for regulatory delays. - Immediate effect: These relaxations are live from the date of the circular, and Master Directions will be updated. 🔹 Why does this matter? - For SMEs & startups: Less paperwork, faster closure, fewer compliance costs. - For banks: Reduced operational burden, more focus on larger and complex transactions. - For India Inc.: Promotes ease of doing business in trade, especially for small players struggling with thin margins. 💡 My take: This move is a big win for the long-tail of India’s exporters/importers. By trusting declarations for small-value entries, RBI is signalling a shift from micro-compliance policing to ease-of-business facilitation. #RBI #FEMA #TradeFinance #Export #Import #EDPMS #IDPMS #EaseOfDoingBusiness

If you think compliance is simply a cost center, look no further than what’s happening with Temu and Shein. A Congressional oversight committee report called out the Chinese behemoth marketplaces in 2023 for failing “to maintain even the facade of a meaningful compliance program.” The result? Scrutiny, legal risk, and reputational damage. But let’s be clear—this isn’t just about two companies. For importers, customs brokers, and marketplaces alike, compliance isn’t optional. Compliance is not only the backbone of any company with an international supply chain, but it actually can be the difference between going big and going home. Why do compliance programs matter? 👉 For Importers: - Forced labor bans, de minimis restrictions, and tariff changes are evolving - Compliance programs allow you to implement agility quickly, and be ready to pivot alongside fast-changing changing regulations - Without a compliance program, you could be shipping goods that violate U.S. or other laws—leading to seizures, fines, and loss of supplier relationships Temu’s risk? It could be yours. If your supply chain isn’t fully traceable, how do you know your goods are compliant? The answer: prioritizing master data and proactive screening 👉 For Customs Brokers: - If your clients get hit with compliance violations, you do too (it's your license on the line after all) - You’re expected to be the expert in regulatory shifts like Uyghur Forced Labor Prevention Act (UFLPA), tariff exclusions, and de minimis eligibility changes - A strong compliance program ensures you’re not just processing entries—you’re protecting your clients and your business 👉 For Marketplaces: - Your entire platform is at risk if you don’t enforce compliance on sellers - Temu’s “we’re not the importer of record” argument is falling apart—lawmakers are making it clear that marketplaces facilitating noncompliant imports will face consequences - If you aren’t vetting suppliers and enforcing compliance rules, your marketplace could be next in the crosshairs The bottom line? Compliance can't be an afterthought. Temu and Shein have been getting their act together since this report. Their situation is a warning: If you don’t build a strong compliance program proactively, it will be forced upon you reactively. I help companies secure their transactions at origin, validate supplier compliance, and ensure smooth customs clearance—companies have launched my program as quickly as 60 days. #customscompliance #tariffs #ecommerce

🤝 Starting an export–import business in India? Bookmark this. It can save you weeks of confusion. Here’s a simplified roadmap of the **most important government platforms** you actually need: 🔹 **Core (Start Here)** • DGFT – IEC, policies, licenses • GST Portal – registration, LUT, refunds • ICEGATE – customs clearance & filings 🔹 **Product-Based Authorities** (depends on your goods) • APEDA – agri & processed foods • FSSAI – food compliance • Spices Board, MPEDA, Tea Board, Coffee Board 🔹 **Trade Support** • FIEO – networking, export promotion • Indian Trade Portal – market insights & rules 🔹 **Logistics & Documentation** • DG Shipping – shipping regulations • PCS 1x – port documentation & operations 🔹 **Banking & Risk** • RBI – forex & remittance guidelines • ECGC – export credit insurance 🔹 **MSME Support** • Udyam Registration – MSME benefits & schemes 📌 **Simple flow to start:** IEC → GST → Bank AD Code → ICEGATE → Product Registration → Export 💡 Reality check: You don’t need to register everywhere. Start with the basics, then expand based on your product and market. Exports aren’t complicated—*they’re just structured.* #ExportBusiness #ImportExport #DGFT #ICEGATE #MakeInIndia #Logistics #MSME #StartupIndia #GlobalTrade

The End of “We didn’t export to Russia” as a sanctions defence The UK authorities have concluded the largest compound settlement to date for a breach of Russia sanctions—another clear signal of how rapidly and aggressively sanctions enforcement is evolving. HM Revenue & Customs (HMRC) imposed a £1,160,725.67 penalty on a UK exporter for making goods available to Russia in breach of the Russia (Sanctions) (EU Exit) Regulations 2019. What makes this case particularly instructive from a compliance perspective is that it did not necessarily involve a direct export to Russia. Under UK sanctions law, the concept of “making goods available” is deliberately broad. It can capture scenarios where goods are supplied via intermediaries, including companies based in third countries but ultimately connected to Russia. For businesses operating within complex international supply chains, this case is a timely reminder that sanctions compliance is no longer limited to screening the immediate customer. Authorities increasingly expect companies to demonstrate an understanding of: - the ultimate end-user, - the ownership and control structure of counterparties, and - the risk of diversion through third countries. With enforcement intensifying across the UK, EU, and US, companies engaged in cross‑border trade should reassess whether their sanctions due diligence, end‑use verification, and supply‑chain monitoring are robust enough to identify indirect exposure. In practice, many recent sanctions breaches stem not from intentional misconduct, but from insufficient visibility into complex distribution and reseller networks. This case is a useful reminder that effective sanctions risk management increasingly requires a holistic, supply‑chain‑wide view—not just a transactional compliance check at the point of sale. https://lnkd.in/epJUjtU6 #SanctionsCompliance #ExportControls #TradeCompliance #UKSanctions #HMRC #InternationalTrade #SupplyChainRisk #ThirdCountryRisk #DueDiligence #KYC #EconomicSanctions #ComplianceLeadership #RiskManagement #GlobalTrade #EthicsAndCompliance #screening #duedilligence

🚨 As if the last few weeks have not been challenging enough for importers and exporters, the Canadian government has fast tracked the coming-into-force of new sanctions evasion, anti-money laundering and anti-terrorist financing obligations. These new measures are intended to address trade-based financial crime risks posed by imported and exported goods, including sanctions evasion. Originally slated to take effect on October 1, 2025, these new declaration and record-keeping obligations under Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act will now apply to importers and exporters as of April 1, 2025. Key points are: ➡️ importers and exporters must make a declaration to the Canada Border Services Agency (CBSA) as to whether the goods they are importing or exporting are proceeds of crime or are goods related to money laundering, to the financing of terrorist activities or to sanctions evasion, and that the goods are actually being imported or exported ➡️ importers, exporters and other involved parties are subject to record-keeping requirements to support the declaration ➡️ CBSA officers have been granted search and seizure powers related to sanctions evasion, money-laundering and terrorist financing ➡️  there is an administrative monetary penalty (“AMP”) scheme for failure to abide these requirements - these penalties are assessed on a strict liability basis, unlike the existing criminal penalties for violating Canada’s economic sanctions and anti-terrorism legislation ➡️ CBSA has not yet released guidance on the declaration and related requirements All the details here in our latest blog post from Gajan Sathananthan, Cindy Zhang and me. #AML #sanctions #evasion #CBSA #TradeCompliance #PCMLTFA McCarthy Tétrault https://lnkd.in/gibZBgB5

🚨 $1M fine for #Teledyne #FLIR — a wake-up call for every company handling 🇺🇸#US.-#origin technology abroad. (YES, even when is "Made In Sweden" 🇸🇪)⤵️ Bureau of Industry and Security-U.S. Department of Commerce just fines the #thermal #imaging maker 🎦 for 19 #export #control violations involving #China 🇨🇳 and #Hong #Kong🇭🇰. But here's what makes this case especially relevant for EU-based operations: 👉several violations originated from #Sweden🇸🇪, where a subsidiary #reexported controlled cameras to China #without the required #license. 🚩If your #European #entity incorporates U.S.-#origin #components, you are not outside the reach of U.S. export controls. 🔑Three key #lessons every compliance #professional should take away 👇 1️⃣ #De #minimis is not a shortcut. More than half of the violations came from #incorrect #calculations of U.S.-#controlled #content. Structuring fees to push #content #below 25% is exactly the kind of conduct regulators will scrutinize.⛔️ 2️⃣ #Entity #List #screening must be continuous. One violation involved an export to a #Hong #Kong 🇭🇰 #address added to the Entity List in 2024. ⚠️Screening at the time of #onboarding is #not #enough. 👤 3️⃣ #License #conditions are #obligations, not suggestions. A European subsidiary used a BIS license to ship a camera worth roughly $1,000 to #Shanghai but failed to meet the #recordkeeping conditions attached to that license. BIS expects full #traceability and #documentation — no matter the value of the item.📥 🔆This case is a reminder for #EU-#based companies working with U.S. technology, compliance with the #EAR is not optional — it's the #cost of doing business.💰 ✅️To Do List to Protect Your Business 🔎 Know your #content. 🛂 Screen your #parties. 🔰 #Document everything relevant. We are here for support CROSS-BORDER | Global Trade Solutions 🌐 www.cbglobal.it

Ever seen a $365 million typo? That’s what the wrong HS code looks like on a customs bill As someone who’s defended Fortune boards in closed‑door customs investigations, I’ve learned the biggest risks hide in plain sight. Know the truth. Here’s what you need to understand: 1. Using the wrong HS code is not harmless.  ↳ Customs will not always re-classify it.   ↳ Misclassifying can lead to huge fines. For example, a company paid US $365 million in March 2024 for misclassifying Transit Connect vans. 2. FTA preference does not apply automatically.  ↳ Just because a product ‘originates’ does not mean you are safe.   ↳ Importers must have a valid Certificate of Origin. Missing this can trigger duty reversals and penalties that cost millions. 3. Relying on your customs broker is a mistake.  ↳ The Importer of Record (IOR) holds strict liability for entry data.   ↳ Even if a broker files the entry, you are still responsible. The DOJ is increasing enforcement against IORs who rely on “rubber-stamp” brokers. This can lead to lost time, trust issues, and costly audits. The math is simple: every 1 % duty error on a $100 M import program equals $1 M of silent margin leakage By addressing these myths, executives can turn compliance into a strategic advantage. This can help avoid eight-figure surprises and improve duty management. Want the Rapid Checklist? DM me. CTA: If you found this helpful, follow for more trade compliance insights.

Alright LinkedIn fam, say it with me now: Export controls are not optional. A former U.S. Air Force pilot has been arrested and charged for providing unauthorized defense services to China. - When it comes to defense technology and services, the rules of engagement aren’t just for industry, they apply to individuals too. - Training and advisory support that touches defense capabilities must be properly licensed and aligned with U.S. national security policy. No exceptions. - Transfers of expertise whether technical, tactical, or advisory fall squarely within the scope of the Arms Export Control Act and ITAR when they involve defense services to foreign militaries. This is about understanding that what we know matters as much as how we apply it within the regulatory framework. Export controls exist to protect U.S. interests, our allies, and the integrity of international security cooperation. For companies and professionals operating in global markets, compliance isn’t a bureaucratic checkbox. It’s foundational to responsible engagement, sustained trust, and mission success. If you work across FMS, DCS, or international cooperation, now is a good moment to double down on clarity and make sure your export compliance practices are as robust as your technical expertise. Read more here: https://lnkd.in/eWCwEB-u #ExportControls #ITAR #AECA #DefenseTrade #NationalSecurity #Compliance

Importers: Are You Unknowingly Violating CBP Regulations? Many importers aren’t aware that a Power of Attorney (POA) for customs clearance must be executed directly with the licensed customs broker — not through a freight forwarder (unless they are a broker) or any third party. This is a strict requirement under 19 CFR § 111.36(c)(3). IF YOU ARE BUYING LDP, DO NOT PROVIDE A POWER OF ATTORNEY TO THE SELLER'S THIRD PARTY OR HAVE SHIPMENTS CLEARED IN YOUR NAME SINCE YOU WILL BE RESPONSIBLE FOR ALL DECLARATIONS TO CBP AS IMPORTER OF RECORD. Let’s break this down: 📌 What the Regulation Says: Customs brokers are prohibited from accepting a POA that was obtained by a third party, such as a non-customs broker licensed freight forwarder. The customs broker must have a direct POA with the importer of record. 📌 Why This Matters: If a freight forwarder (that is not a licensed broker) — let’s say “Rain Forest Forwarder” — presents you with a POA for their in-house broker, such as “SOSO Brokers,” and you sign it, you are not in compliance with CBP regulations. The POA must be directly between you and the broker. Often, importers assume the forwarder is the customs broker, leading to confusion and lack of reasonable care in CBP’s eyes. If CBP pulls your entry and asks who your broker is — and you reply “Rain Forest” — but SOSO Brokers filed the entry, that could demonstrate a compliance failure on your part. ⚠️ The Risk to You: Violating 19 CFR § 111.36(c)(3) Failure to exercise “reasonable care” as required under 19 U.S.C. § 1484 Potential audits, penalties, or delays in cargo clearance Being misled into authorizing a broker relationship you never intended 💡 Best Practice: Always execute a POA directly with your licensed customs broker. Ask them to confirm their license and maintain open communication. No third party should interfere with or act as a conduit for that relationship. At the end of the day, compliance is your responsibility as the importer. Make sure you’re protected — and adequately aligned with CBP regulations. #LDP #importer #Duty #customs #CBP #powerofattorney #customscompliance #importcompliance #reasonablecare.

Every tariff change is a test for pharma supply chains. Are you ready for the next bottleneck? Tariffs don’t just raise costs-they create ripple effects that can disrupt the entire supply chain. For the pharmaceutical industry, where timely delivery of critical products is non-negotiable, these disruptions can be costly in more ways than one. Here’s what I’ve seen happen when tariff changes catch companies off guard: 🔹 Delays at borders that hold up production schedules and customer deliveries. 🔹 Increased scrutiny of import declarations, leading to fines or penalties for non-compliance. 🔹 Misclassified goods that miss out on exemptions or lower duty rates. But these challenges are avoidable with the right preparation. Here’s how you can mitigate the impact: ✔️ Review your HTS classifications regularly. Many pharmaceutical products qualify for exemptions, but only if classified correctly. ✔️ Leverage Free Trade Agreements (FTAs) where applicable to reduce or eliminate duties. ✔️ Ensure supplier documentation is accurate and consistent. Don’t rely on others to get it right-take control of the process. ✔️ Stay informed about policy changes. Tariffs can shift quickly, and being proactive is your best defense. Trade compliance isn’t just about avoiding fines-it’s a strategic investment in your supply chain’s resilience. By addressing tariff risks head-on, you can minimize bottlenecks and keep your operations running smoothly. If you’re unsure where to start, now is the time to evaluate your processes. Don’t wait until the next tariff hike to take action. I am Elizabeth Lomax, import/export compliance expert helping pharma and biotech companies create more efficient international supply chains. DM me or visit my LinkedIn profile to learn more. To stay updated, click the notification bell on my profile. 🔔