Before 10 November: screen the customer, not just the product

Part 3/3 · 9 min 51. The video is in French.

What the video covers

• 00:00 Three questions, to be asked in this order
• 01:30 Two cases, two outcomes: $252.5M versus $36.2M
• 03:30 When controls target the customer rather than the product
• 05:30 The limits of name-based screening: the 50% rule
• 06:30 Four steps to take before 10 November

Presentation by Matthew A. Bock, attorney (Bock Trade Law, Massachusetts), at the 16 September 2026 webinar of the Occitanie committee of the French Foreign Trade Advisors, where I spoke alongside him. The presentation is in French. It addresses US law and is general information, not legal advice. Published with the speaker's consent.

Other parts

• Part 1 — Bosch: $36M for "ordinary" sensors and the Foreign Direct Product Rule · 9 min 45
• Part 2 — Applied Materials: $252.5M over a question of origin — de minimis and dual origin · 9 min 45

The four webinar chapters (Jan Holtzhäusser) →