Does a party performing consular documentation services for ocean shipments require an OTI license?

The determination regarding whether a party performing consular documentation services for ocean shipments requires an Ocean Transportation Intermediary (OTI) license is based on the activities they engage in. Consular documentation services generally involve preparing and processing the necessary paperwork for customs and regulatory requirements in the destination country. This function does not fall under the activities that necessitate an OTI license.

An OTI license is required for entities that are engaged in arranging the transportation of cargo, such as freight forwarders and non-vessel operating common carriers (NVOCCs). Since consular documentation is purely administrative and does not involve the actual handling of cargo or the arranging of its transportation, the need for an OTI license is not applicable in this context.

This understanding clarifies why the other options are not suitable. For instance, the requirement for an OTI license when handling multiple shipments is not relevant in this case, as the activity in question does not constitute handling shipments in the manner that an OTI would. Similarly, the type of cargo does not influence the need for an OTI license because the nature of the service being provided (consular documentation) remains unchanged regardless of cargo type.