A recent change has raised the risk that importers/exporters of wildlife products may inadvertently allow their import/export licenses to expire.
With certain limited exceptions, importers/exporters are required to obtain a U.S. Fish and Wildlife Service (FWS) Import/Export License to import/export products that incorporate wildlife (i.e., any living or dead animal, including mammals, birds, reptiles, amphibians, fish, insects, crustaceans, arthropods, mollusks, and coelenterates). This license must be renewed annually. If the license has expired, the import/export of wildlife products is prohibited and is subject to seizure and forfeiture. The importer/exporter is also exposed to the possible issuance of civil and criminal penalties.
Historically, FWS issued a courtesy letter to license holders notifying them of their pending license expiration date. However, effective August 1, 2014, FWS has ceased this practice. As a result, it is imperative that FWS Import/Export license renewal dates are assiduously monitored to ensure the timely filing of license renewal applications and the uninterrupted continuation of permissible wildlife product importations.
Brought to you by EACCNY member Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP, which is available to provide assistance in monitoring the expiration and renewal of FWS Import/Export Licenses. Should you have any questions, or require assistance, please contact John A. Schoenig.