Amendments to Cuba Sanctions and New Voluntary Disclosure License Code Types

In January 2015 the Automated Export System deployed changes to allow new License Codes that can be used in export filings. Global Trade Management Cloud is updated to accommodate the use of these new License Codes. The format and query templates have been modified to fulfill the new reporting requirements and will appear in the X107 field of the EDI filing document. The new License Codes, their use and the configuration necessary is described below.

C62 – SUPPORT FOR THE CUBAN PEOPLE

This is a standard license exception code that would normally be found in either a Compliance Rule Exception Code field or the Authorization field. The user-friendly code that should be entered is SCP. The templates will map this to the EDI License Code C62.

• VDC – COMMERCE DEPARTMENT VOLUNTARY SELF DISCLOSURE
• VDS – STATE DEPARTMENT VOLUNTARY DISCLOSURE
• VDO – OTHER PARTNER GOVERNMENT AGENCY VOLUNTARY DISCLOSURE

These three are neither License Codes or License Exception Codes, but other information. However, it is expected to find these either in a Compliance Rule Exception Code or the Authorization field. There is no user-friendly code, so the actual values, VDC/VDS/VDO are expected to be found in the Compliance Rule Exception Code or Authorization field.

Users are expected to capture the need for voluntary disclosure by either entering the values directly into the Authorization field or by modeling a Compliance Rule on a Transaction Remark. The Remark Text should be one of the three values listed above and this same value would be used in the Exception Control Code.