@Jack, In a routed transaction, both must occur. The FPPI must facilitate the export and then authorize the USPPI or a U.S. agent to file the EEI. If the FPPI has not authorized a filer, however, that does not mean it is not a routed transaction.
Additional Named Insured. Additional Named Insureds are considered to be owners of the policy. Therefore an Additional Named Insured has full access to the coverage provided by the policy with very few (if any) restrictions. However, the rights afforded to Additional Named Insureds come with risks.
If the client still insists that it be named an additional insured on you policy, you might work with your. attorney, insurance agent and insurance underwriter to develop alternate contractual language that. would better achieve the clients objectives and be acceptable to the insurer.