Regular readers of our newsletter, and those familiar with U.S.
import and export regulations, know that U.S. Customs and Border
Protection ("CBP" or "Customs") generally
enforces the U.S. import regulations, while multiple executive
government agencies administer regulations related to the export of
goods. Such agencies include, but are not limited to, the
Department of Commerce Bureau of Industry and Security
("BIS"), the Department of State Directorate of Defense
Trade Controls ("DDTC"), the Department of the Treasury
Office of Foreign Assets Control, the Drug Enforcement Agency, and
the Census Bureau.
However, CBP also enforces export regulations at the
country's ports, which can lead to a situation that every
exporter hopes to avoid: the seizure by CBP of export merchandise.
These seizures can be prompted by violations of regulations
administered by multiple agencies and can range from egregious
violations of U.S. sanctions laws to forgetting to cite a
