17-0424 Monday “The Daily Bugle”

17-0424 Monday “Daily Bugle”

Monday, 24 April 2017

The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, Customs, NISPOM, EAR, FACR/OFAC, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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[No items of interest noted today.] 

  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. DHS/CBP Sends Out Reminder Concerning Required Security Change for All ACE Portal Accounts 
  4. DoD/DSCA Posts SAMM and Policy Memoranda, Week 23-29 Apr 
  5. DoD/DSS Posts DISS Deployment Update for Industry 
  6. DoD/DSS Posts Notice on Knowledge Center Being Closed on 28 Apr 
  7. Justice: “Chinese National Pleads Guilty to Attempting to Illegally Export High-Grade Carbon Fiber to China” 
  8. State/DDTC: (No new postings.) 
  9. Treasury/OFAC Sanctions 271 Syrian Scientific Studies and Research Center Staff in Response to Sarin Attack on Khan Sheikhoun 
  1. ST&R Trade Report: “Assembly Process Not Enough to Substantially Transform Imported Parts, CBP Says” 
  1. D. Santorum: “EU Dual-Use Reform to Impact Surveillance Camera Exports” 
  2. M.H. Borrego & J.A. Joiner: “NAFTA – Uncertainty and Anticipation”  
  1. Annual ICP European Conference in Dublin Ireland, 11-13 Jun  
  1. Monday List of Ex/Im Job Openings: 105 Jobs Posted 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (27 Jan 2017), DOD/NISPOM (18 May 2016), EAR (18 Apr 2017), FACR/OFAC (10 Feb 2017), FTR (19 Apr 2017), HTSUS (7 Mar 2017), ITAR (11 Jan 2017) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



[No items of interest noted today.]

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OGS_a11. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register

* Commerce; Industry and Security Bureau; NOTICES; Meetings [Publication Date: 25 April 2017.]:
  – Materials Processing Equipment Technical Advisory Committee
  – Transportation and Related Equipment Technical Advisory Committee

* Commerce; Industry and Security Bureau; NOTICES; Initiation of National Security Investigation of Imports of Steel; Request for Comments and Public Hearing [Publication Date: 26 April 2017.]

* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 25 April 2017.]
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CSMS# 17-000231, 22 April 2017.)
ACE Outreach Events
Federal Regulations require that sensitive data be protected when being disseminated over the Internet. Transport Layer Security (TLS) is the government approved security mechanism to protect sensitive data during internet transmission. Currently, ACE supports versions 1.0, 1.1, and 1.2 of the TLS protocol.
On May 1, 2017, U.S. Customs and Border Protection (CBP) will discontinue supporting versions 1.0 and 1.1 of TLS. To comply with government regulations, all ACE Secure Data Portal users are being notified that CBP will be phasing out versions 1.0 and 1.1 of TLS and will only support version 1.2
Please note: The ACE Portal will not be accessible to users who operate computers that run operating systems older than Windows 7.
For more information about portal system requirements, please visit the “Using the ACE Secure Data Portal” page on CBP.gov/ACE, and scroll down to the bottom of this page.
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. DoD/DSS Posts DISS Deployment Update for Industry

(Source: DoD/DSS)
The Defense Information System for Security (DISS), once fully deployed, will replace the Joint Personnel Adjudication System (JPAS) to serve as the system of record to perform comprehensive personnel security, suitability and credential eligibility management for all military, civilian, and DOD contractor personnel. DISS provides secure communications between adjudicators, security officers and component adjudicators in support of eligibility and access management.
DISS will deploy in a phased approach, with Phase 1 (DISS 1.0) being rolled out to users incrementally. The deployment date for Industry has shifted from 3rd Quarter FY17 to a date yet to be determined. In the meantime, DSS continues to work with Industry to review DISS capabilities and identify requirements. The DISS website is available and has the most up-to-date information.

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. DoD/DSS Posts Notice on Knowledge Center Being Closed on 28 Apr

(Source: DoD/DSS)
Personnel Security (PCL) inquiries (option #2) to include e-QIP authentication resets of the DSS Knowledge Center will be closed on Friday, April 28, 2017, for the purpose of conducting internal training to deliver the highest quality customer service to Industry and Government callers. Normal operations for PCL and e-QIP inquiries will resume on Monday, May 1, 2017. Reminder, the PCL portion of the DSS Knowledge Center typically closes on the last Friday each month.

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. Justice: “Chinese National Pleads Guilty to Attempting to Illegally Export High-Grade Carbon Fiber to China”

(Source: Justice) [Excerpts.]
Joon H. Kim, the Acting United States Attorney for the Southern District of New York, and Mary B. McCord, the Acting Assistant Attorney General for the National Security Division of the Department of Justice (“NSD”), announced that FUYI SUN, a/k/a “Frank,” a citizen of the People’s Republic of China (“China”), pled guilty today before U.S. District Judge Alvin K. Hellerstein to violating the International Emergency Economic Powers Act (“IEEPA”) in connection with a scheme to illegally export to China, without a license, high-grade carbon fiber, which is used primarily in aerospace and military applications.
Acting Manhattan U.S. Attorney Joon H. Kim said: “As Fuyi Sun admitted today in court, he tried to skirt U.S. export laws by hiding his purchase of high-grade carbon fiber for the Chinese military. Sun used fraudulent documents and codewords in his efforts to obtain this highly protected material, which is used in aerospace and defense programs, and to avoid detection. Together with our law enforcement partners, we will continue to enforce the laws that protect our national security.”
NSD Acting Assistant Attorney General Mary McCord said: “Today, Fuyi Sun admitted to attempting to procure high-grade carbon fiber – which has sophisticated aerospace and defense applications – for the Chinese military. The defendant was willing to pay a premium to evade U.S. export laws and illegally transfer this highly protected material. The National Security Division will continue to identify those who violate IEEPA and other laws that protect our national assets from reaching the hands of potential adversaries.”
According to the allegations contained in the Complaint and the Indictment filed against SUN and statements made in court filings and proceedings, including today’s guilty plea:
Since approximately 2011, SUN has attempted to acquire extremely high-grade carbon fiber, including Toray type M60JB-3000-50B carbon fiber (“M60 Carbon Fiber”). M60 Carbon Fiber has applications in aerospace technologies, unmanned aerial vehicles (commonly known as “drones”) and other government defense applications. Accordingly, M60 Carbon Fiber is strictly controlled – and requires a license for export to China – for nuclear non-proliferation and anti-terrorism reasons.
In furtherance of his attempts to illegally export M60 Carbon Fiber from the United States to China without a license, SUN contacted what he believed was a distributor of carbon fiber – but was, in fact, an undercover entity created by HSI and “staffed” by HSI undercover special agents (the “UC Company”). SUN inquired about purchasing the M60 Carbon Fiber without the required license. In the course of his years’ long communications with the undercover agents and UC Company, SUN repeatedly suggested various security measures that he believed would protect them from “U.S. intelligence.” Among other such measures, at one point, SUN instructed the undercover agents to use the term “banana” instead of “carbon fiber” in their communications. Consequently, soon thereafter he inquired about purchasing 450 kilograms of “banana” for more than $62,000. In order to avoid detection, SUN also suggested removing the identifying barcodes for the M60 Carbon Fiber, prior to transshipment, and further suggested that they identify the M60 Carbon Fiber as “acrylic fiber” in customs documents.
On April 11, 2016, SUN traveled from China to New York for the purpose of purchasing M60 Carbon Fiber from the UC Company. During meetings with the undercover agents, on or about April 11 and 12, among other things, SUN repeatedly suggested that the Chinese military was the ultimate end-user for the M60 Carbon Fiber he sought to acquire from the UC Company, and claimed to have personally worked in the Chinese missile program. SUN further asserted that he maintained a close relationship with the Chinese military, had a sophisticated understanding of the Chinese military’s need for carbon fiber, and suggested that he would be supplying the M60 Carbon Fiber to the Chinese military or to institutions closely associated with it.
On April 12, 2016, SUN agreed to purchase two cases of M60 Carbon Fiber from the UC Company. On that date, SUN paid the undercover agents purporting to represent the UC Company $23,000 in cash for the carbon fiber, as well as an additional $2,000 as compensation for the risk he believed the UC Company was taking to illegally export the carbon fiber to China without a license. SUN was arrested the next day, April 13, 2016. …
SUN, 53, pled guilty today to attempting to violate IEEPA, which carries a maximum sentence of 20 years in prison. The maximum potential sentence in this case is prescribed by Congress and is provided here for informational purposes only, as any sentencing of the defendant will be determined by the judge. SUN is scheduled to be sentenced by Judge Hellerstein on July 26, 2017 at 11:00 a.m. …

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. State/DDTC: (No new postings.)

(Source: State/DDTC)

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. Treasury/OFAC Sanctions 271 Syrian Scientific Studies and Research Center Staff in Response to Sarin Attack on Khan Sheikhoun

(Source: Treasury/OFAC) [Excerpts.]
Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is taking action in response to the April 4, 2017 sarin attack on innocent civilians in Khan Sheikhoun, Syria, by the regime of Syrian dictator Bashar al-Assad. In one of the largest sanctions actions in its history, OFAC is designating 271 employees of Syria’s Scientific Studies and Research Center (SSRC), the Syrian government agency responsible for developing and producing non-conventional weapons and the means to deliver them. These 271 SSRC employees have expertise in chemistry and related disciplines and/or have worked in support of SSRC’s chemical weapons program since at least 2012.

  “These sweeping sanctions target the scientific support center for Syrian dictator Bashar al-Assad’s horrific chemical weapons attack on innocent civilian men, women, and children. The United States is sending a strong message with this action that we will hold the entire Assad regime accountable for these blatant human rights violations in order to deter the spread of these types of barbaric chemical weapons,” said Treasury Secretary Steven T. Mnuchin. “We take Syria’s disregard for innocent human life very seriously, and will relentlessly pursue and shut down the financial networks of all individuals involved with the production of chemical weapons used to commit these atrocities.” …
For identifying information on the individuals designated today, click here.

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. ST&R Trade Report: “Assembly Process Not Enough to Substantially Transform Imported Parts, CBP Says”

U.S. Customs and Border Protection has issued a final determination concerning the country of origin of network tap products that may be offered to the U.S. government under an undesignated government procurement contract. Any party-at-interest may seek judicial review of this determination by May 24. CBP issues country of origin advisory rulings and final determinations as to whether an article is or would be a product of a designated country or instrumentality for the purposes of granting waivers of certain “Buy American” restrictions in U.S. law or practice for products offered for sale to the U.S. government.
A network tap is a fiber optic device that provides a physical connection or access to a network. Network taps enable users to physically connect a computer or other monitoring device to a network for the purpose of evaluating, monitoring, or checking network issues.
The network tap at issue consists of three adapters from Taiwan, two splitters from China, and a chassis, tamper-proof labels, and other items from the U.S. These parts are assembled into the finished product in the U.S. by specially trained technicians and then tested, processes that combined take about 15 minutes.
CBP finds that the foreign adapters and splitters are not substantially transformed as a result of the post-importation processing because they do not lose their individual names, remain physically recognizable as adapters and splitters, and do not change in material composition or use. In addition, the assembly process is not sufficiently complex or meaningful to render a substantial transformation.
CBP concludes that the country of origin of this network tap for purposes of U.S. government procurement is China. CBP explains that this product allows data from a single source to be used on multiple analyzing tools and that it is the splitter from China that enables this functionality and therefore constitutes the essence of the product.

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. D. Santorum: “EU Dual-Use Reform to Impact Surveillance Camera Exports”

* Author: David Santorum, Project Manager, Spectaris, santorum@spectaris.de, +49 30 41 40 21-58.
On 28 September 2016, the European Commission presented a proposal for a new EU dual-use regulation, which is meant to replace the regulation from 2009 on the community regime for the control of exports, transfer, brokering and transit of dual-use items. This provision is the most significant legislative text on European export control and absolutely all European companies need to pay attention to it that manage goods or technologies that may be used for civilian as well as military purposes, i.e. dual-use items.
The most outstanding novelty of this legal proposal is probably the new ‘human security approach’. According to the explanatory memorandum, the European Commission is committed to pursuing a value-based trade policy. To do justice to this goal, the Commission introduced the concept of ‘human security approach’ to the regulation’s proposal. This new value approach is noticeable at various points. For example, the definition of dual-use items has been redefined, new catch-all controls added, and the due diligence obligations of the economic operators and the test criteria of the competent national authorities have been expanded.
The definition of dual-use items is expanded to include cyber-surveillance technology, which can be used for the commission of serious violations of human rights or international humanitarian law. The reason for this expansion lies in the events that took place during the Arab Spring. When the unrest occurred the authoritarian regimes used cyber-surveillance technology to locate and eliminate their opponents. Later it became known that this technology also had European origin. With this new legislative proposal the Commission wants to prevent such abuse in the future.
The question must be raised as to whether the pursued goal can actually be reached by expanding this definition. In practice, situations often arise in which one cannot determine beforehand whether the technology will be used for civilian purposes or misused to violate human rights. A clear example of this is surveillance cameras. The footage taken by these devices are per se legitimate. However, these surveillance cameras may be seized by authoritarian regimes and used to track down and arrest government critics or opposition members.
Special attention must be given to the new catch-all controls. In the current EC dual-use regulation, the catch-all clause only applies if non-listed goods could be used in terms of ABC weaponry, missile/carrier technology or other defence technologies, and a weapons embargo has been imposed on the final destination country. The new regulation proposal distances itself from this approach and introduces two new catch-all rules: a human rights catch-all rule and a terrorism catch-all rule.
The human rights catch-all rule describes ‘serious violations of human rights or the international humanitarian law’. While the term ‘international humanitarian law’ – for example, based on the Geneva Convention – can be delimited, the general reference to human rights is quite imprecise and will lead to ambiguities in practice, as a clear and uniform-codified legal source is missing. It is unclear whether the regulation proposal refers to the Declaration of Human Rights of the United Nations, the European Convention on Human Rights, the EU Charter of Fundamental Rights or the single state’s fundamental and human rights. But even if the term ‘human rights’ is specified, the inclusion of this catch-all clause would remain highly problematic. The question remains how and on what basis of which information a company is meant to judge what behaviour poses a serious violation of human rights. This assessment can only be made by a responsible state institution.
The matter of the terrorism catch-all clause is similar. Although the regulation’s proposal refers to a definition of ‘terrorist act’, it does not make it easier for a company to determine whether a product could possibly be misused for terrorist purposes. Here too, an indication or reference by a state authority is indispensable.
The increased compliance obligation that is imposed on the exporter is especially alarming. The legal proposal stipulates that the exporter, ‘under his obligation to exercise due diligence’, must notify the competent authority if his goods are fully or partially intended for offences such as human rights violations or terrorist activities.
This stipulation deviates from the current requirement of positive knowledge and introduces a new notion of diligence. It is unclear how companies are to implement this due diligence notion, which business processes need to be newly implemented accordingly and, above all, the extent of the companies’ obligation to acquire information is not specified either. This has the effect that the compliance effort within the company will increase significantly. At the same time, one can assume that the work volume of the responsible national authorities will have to expand in parallel, as numerous companies will apply for negative certificates to hedge their bets.
The ‘human security approach’ makes it clear that the Commission is moving away from traditional goals in export control. Hitherto, the export control pursued two main goals: preventing the proliferation of weapons of mass destruction (non-proliferation) and the unchecked distribution of conventional arms. This proposal shows that the intent is for companies to also take on additional responsibility in the area of protection of human rights and counter-terrorism. This socio-politically important and commendable goal puts additional strain on companies and it will not be possible for them to adequately implement these. Both the protection of human rights and counter-terrorism measures are classic tasks in the core area of political action. This shall not be transferred to the area of responsibilities of commercial companies without automatically endangering the competitiveness through additional administration and lacking predictability and reliability for international partners. Instead, companies rather depend on receiving clear indications by the responsible state bodies on sensitive products, as well as critical target countries, persons and institutions.
The proposal for a new EU dual-use regulation clearly shows many deficiencies. Over the next months the European Parliament and the Council will have to remove these shortcomings in order to adopt a new dual-use regulation, which in practice can also be implemented by the companies in a realistic manner.

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* Authors: Mary H. Borrego, Esq., mborrego@joinertradelaw.com, 713-623-1488; and Jamie A. Joiner, Esq., jjoiner@joinertradelaw.com, 713-395-2200. Both of Joiner Law Firm PLLC.
The uncertainty of North American trade has loomed since Trump railed against NAFTA-calling it the “worst trade deal.” Since then discussions have focused on how trade relations among the U.S., Mexico, and Canada may change under the Trump administration. Now, with the assembly of Trump’s trade team – Wilbur Ross as Secretary of Commerce, Peter Navarro as director of the National Trade Council, and Robert Lighthizer’s expected confirmation as U.S. Trade Representative – anticipated changes to NAFTA are beginning to take shape.
On March 30th, a draft proposal circulated to Congress was made public. The proposal took the form of a letter (Letter) that indicated negotiations related to NAFTA are likely to begin in the coming months and be conducted in accordance with the Trade Priorities Act of 2015 (TPA). Under the TPA, Congress may only cast an up-or-down vote on trade agreements negotiated by the administration – without option for amendments. But in exchange, the administration must comply with congressional transparency and consultation obligations. The purpose of the TPA is to promote both presidential negotiating authority and expedited congressional procedures for implementing legislation needed for new trade agreements to apply domestically. In theory, this means that the TPA will lead to more inclusive deliberations between the Executive branch and Congress, and not only avoid the negotiated trade agreement being significantly changed when implemented by Congress, but also avoid Congress’ complete rejection of the President’s trade deal. The Letter highlights several objectives that all parties to NAFTA agree are needed, while also not completely forgoing certain areas of concern that may prove troublesome during negotiations.
NAFTA was negotiated over 25 years ago and was not drafted to account for changes in e-commerce, digital trade, cross-border data flows, and intellectual property rights, and rules for state-owned enterprises, among other areas that have greatly evolved over the last quarter century. Other areas, including rules of origin in customs procedures, labor, environment, and trade protections for small and medium-sized businesses, were not adequately addressed within the NAFTA agreement, itself instead leaving those to be implemented or addressed through alternative arrangements. All three parties generally agree that NAFTA is in need of modernization and, if done correctly, could lead to the creation of a North American powerhouse.
It is encouraging to see the Trump administration dial back, at least somewhat, its protectionist position signaling the intent to make “the United States, and North America, stronger, [and] a more attractive place to do business.” To achieve this, the Letter identifies several objectives including the elimination of non-tariff barriers, such as permits and licensing, maintaining full reciprocal access to NAFTA markets, and improving transparency and regulatory coherence. Likewise, changes to the NAFTA rules of origin, including the percentage of content or components that must originate in the NAFTA territory, and a reduction to the de minimis value threshold are anticipated.
The rules of origin designate how much of a product must originate within the NAFTA region to qualify for duty-free treatment. For instance, in 2002 the rules of origin for certain vehicles required a regional value content (RVC) of 62.5 percent. This meant that, in order to receive preferential duty treatment under NAFTA, the vehicles must be made with at least 62.5 percent of materials (component parts) originating in the NAFTA territory (made in the U.S., Mexico, or Canada.) Secretary Ross has indicated that negotiating increases to the originating content rules will incentivize Mexican and other North American manufacturers of finished goods to source more component parts from U.S. suppliers. If the U.S. focuses on modifying the rules to specifically require more U.S. content, as opposed to more U.S., Mexican, or Canadian content, this could disrupt established supply chains and lead to higher prices for finished goods and, ultimately, open the door to Asia-Pacific suppliers to be more globally competitive than North American suppliers of finished goods. However, all NAFTA countries could benefit from increased regional value content (RVC) requirements for components. Such a combined effort would ideally help strengthen North America’s position in global trade.
When it comes to the de minimis value threshold, the same precautions exist. Currently, the de minimis value rule provides that products otherwise subject to the RVC requirement will not have to satisfy the requirement if the value of all non-originating materials, such as component parts and materials from China, is not more than seven percent of the transaction value of the finished good. If the de minimis value threshold is decreased, then products with a very small amount of foreign (non-U.S., Mexican, or Canadian) materials incorporated into finish products would be denied beneficial tariff treatment. In theory, this would also incentivize the use of U.S. or NAFTA region materials in lieu of cheaper foreign materials such as component parts made in China, India, or anywhere other than the U.S., Mexico, or China. But, as with the potential consequences of changes to the rules of origin, uniform efforts may prove more beneficial than protectionist efforts focused solely on U.S. goods.

Overall, Trump’s “buy American, hire American” policies and rhetoric on reducing trade deficits linger as the countries prepare for negotiations. According to the Letter, the Trump Administration seeks to level the playing field by addressing the tax treatment of trade in goods. In fact, on several occasions Trump has spoken of Mexico’s “unfair taxes” on U.S. goods at the border. However, this issue is more a result of Mexico’s value-added tax (VAT) that causes all foreign goods, not just U.S. goods, sold in Mexico to be taxed at the same rate. Trump views this as an unfair trade practice and so the goal of leveling the playing field could mean the U.S. either requests that VAT stop on U.S. goods going into Mexico, or imposes a border adjustment tax through anticipated U.S. tax reforms. However, it is likely that Mexico would find either option unacceptable resulting in problematic negotiations.
Despite all this, the reality is that the U.S. relies on cross border supply chains. NAFTA, although outdated, expanded North American trade relationships, especially between the U.S. and Mexico, where manufacturing collaboration is crucial. As such, the U.S. would benefit from strengthening the agreement to incentivize the use of more North American local content, and not just U.S. local content. A focus solely on increasing U.S. content could cause more harm to U.S. economic ties and boost non-NAFTA foreign competitors such as China. As these anticipated changes begin to take shape, there is potential for American, Mexican, and Canadian businesses, workers, and consumers to benefit from NAFTA reforms if all three nations remain focused on benefits to the region, as opposed to taking protectionist positions seen to benefit only one of the parties. 
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. Annual ICP European Conference in Dublin Ireland, 11-13 Jun

* What: The conference has been segmented into two tracks following both import and export.
View the
* When: 11-13 June 2017
* Where: Radisson Blu St. Helens, Stillorgan Road, Blackrock, Booterstown, Dublin, Ierland
* Sponsor: International Compliance Professional Association (ICPA)
* Register Here.

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MS_a114. Monday List of Ex/Im Job Openings: 105 Jobs Posted

(Source: Editor)  
Published every Monday or first business day of the week.  Send openings in the following format to
#” New listing this week:

* Aerojet Rocketdyne; Huntsville AL; 
Specialist, International Trade & Compliance
; Requisition ID: 11972

* Amazon; Luxembourg, Luxembourg;
Trade Compliance Project Integration Manager (M/F)
; Requisition ID: 479077

* Amazon; Mexico City, Mexico;
Mexico Trade Compliance Program Manager
; Requisition ID: 481541

# Amazon; Mexico City, Mexico;
Mexico Trade Compliance Program Manager
; Requisition ID: 520481
# Amazon; Mexico City, Mexico;
Senior Manager, Mexico Trade Compliance
; Requisition ID: 520460

* Amazon; Seattle WA;
NA Compliance Analyst
; Requisition ID: 256357

* Amazon; Seattle WA;
U.S. Export Compliance PM
; Requisition ID: 475927

* Amazon; Tokyo, Japan;
Trade Compliance Specialist
; Requisition ID: 481891

* Advanced Micro Devices (AMD); Austin TX;
Import/Export Compliance Manager; Requisition ID: 24061

# Ansell; Iselin NJ;
Senior Specialist NA Trade Compliance
; Requisition ID: IRC6513
# ASML; Veldhoven, the Netherlands;
Senior Manager Trade & Customs
; Requisition ID: RC05619

* BAE Systems Plc; Farnborough, United Kingdom; 
Deputy Head of Licensing & Policy
; Requisition ID: 

* Barnes Group Inc.,; Bristol CT and Windsor CT;
Counsel & Director of Trade Compliance, Government Contracts Program; Requisition ID: 2200-271

* Bemis Company; Neenah WI;
Director – Global Trade Compliance
; Requisition ID: REQ_13735
* Berry Plastics Corporation; Evansville IN;
International Trade Compliance Administrator
; Requisition ID: 4054

* Biogen; Cambridge MA;
Trade Compliance Specialist
; Requisition ID: 30956BR

* Brunswick Corporation; Lake Forest IL;
Trade Compliance Auditor
; Becky Longrie, 847-735-4755,
; Requisition ID: 22999

* Crane Aerospace and Electronics; Chandler AZ;
Sr. Export Compliance Analyst
; Requisition ID: 4725

* CSL Behring; King of Prussia PN;
Global Trade Compliance Senior Analyst
; Requisition ID: R-038869

* CSRA Inc.; Falls Church VA;
Global Trade & Compliance Principal
; Alan Strober 571-375-4890; Requisition ID: 17002RN

* Danaher; Wash DC (Other locations possible);
Global Trade Compliance Manager; Requisition ID: DAN000510

* DB Schenker (2 positions); Atlanta GA, and Long Beach CA;
Area Customs Director
; Requisition ID: 17P009

# DHL; Netherlands;
Manager Customs Compliance
; Requisition ID: req39070

* Elbit Systems of America; Forth Worth TX or Merrimack NH;
Import Compliance Manager
; Requisition ID: 2017-4965

* Erickson Inc.; Portland OR;
Trade Compliance Manager
Joanna Rafiner-Jarboe
; Requisition 2017-2267

* Esterline Technologies Corporation; Bellevue WA;
Audit Manager – Compliance
; Requisition ID: 8215BR

* Esterline Technologies Corporation; Brea CA;
Sr. Trade Compliance Manager;
Requisition ID: 7333BR

* Esterline Technologies Corporation; Paso Robles CA;
Trade Compliance Manager
; Requisition ID: 6148BR

* Expeditors; Sunnyvale CA;
Customs Compliance Specialist
* Export Solutions Inc.; Melbourne FL; Trade Compliance Specialist;

* FD Associates, Tysons Corner VA;
Senior Export Compliance Associate

* FlightSafety International; Oklahoma; Trade Compliance Advisor; Requisition ID 16480

FLIR; Billerica MA; 
Sr. Defense Trade Licensing & Compliance Analyst
; Requisition ID: 8008

* General Dynamics Information Technology; Falls Church VA;
Principal Contracts Administrator – Export Compliance Coordinator
; Requisition ID: 2017-21288

* Givaudan; Bogor, Indonesia;
Compliance Manager
; Requisition ID: 68063

* The Hershey Company; Hershey PA;
Global Customs and Trade Analyst
* Infinera Corporation; Sunnyvale CA;
Director, Global Logistics and Trade Compliance
; Requisition ID: 2016840

Ingersoll Rand; San Diego, CA;
Latin America Trade Compliance Manager (Trilingual: English, Spanish, and Portuguese)
; Requisition ID: 1610632

* Intel; Santa Clara CA;
Global Export Compliance Specialist
; Requisition ID: JR0814909

# KPMG; Antwerp, Brussels;
Manager Global Trade & Customs – SAP GTS
; 122756BR

* Lam Research Corporation; Fremont CA;
Foreign Trade Intern 1

* Lam Research Corporation; Shanghai, China;
Foreign Trade Analyst 

* Lutron; Coopersburg PA;
Trade Manager-Export
; Requisition ID: 2926

* L-3 Technologies; Arlington VA;
Sr. Mgr. Corporate Customs Compliance
; Requisition ID: 087862

* L-3 Technologies, Platform Integration Division; Waco TX;
Export/Import Compliance Administrator 3
; Requisition ID 088725
# Maxim Integrated; Dallas TX;
Manager, Global Trade
; 3304BR

* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst
; 16000DYY

* Medtronic; Wash DC;
Global Trade Lawyer
; Requisition ID: 170002ON

* Meggitt PLC; Maidenhead, UK;
Trade Compliance Officer 

* Meggit-USA, Inc.; Simi Valley CA;
Trade Compliance Administrator
; Requisition ID: 25172

* Michael Page; Oestgeest, The Netherlands
Sr. Manager – Global Trade Management

# Northrop Grumman Corporation; Falls Church VA;
International Trade Compliance Analyst
; Requisition ID: 16016665

* Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 3
; Requisition ID: 17000826

* Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 3/4; Requisition ID: 17001180

# Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 1
; Requisition ID: 17003433

* Northrop Grumman Sperry Marine; New Malden, UK;
Trade Compliance Coordinator

* Pall Corporation; Portsmouth, UK;
Trade Compliance Specialist
; Requisition ID: SHA000201

* Panduit; Tinley Park IL;
Global Trade Compliance Agent
; Requisition ID: PAND-03297

* Parexel; Billerica MA;
Vice President, Chief Compliance Officer; Requisition ID: pare-00024091

* Plexus Corporation; Neenah Wi;
Manager – Export Compliance
; Requisition ID: 14645BR
* Plexus Corporation; Neenah Wi;
Manager – Import Compliance
; Requisition ID: 14593BR
# Premier Farnell Organisation; Leeds, UK;
Trade Compliance Specialist – Europe
; 4301

* Roanoke Insurance Group; Schaumburg IL;
Carnet Service Representative
; Requisition ID: 1019

* Raytheon; Andover MA and Woburn MA;
Manager of Export Import Control, Empowered Officials
; Requisition ID: 93622

* Raytheon; Arlington VA;
Export Licensing Manager I
; Requisition ID: 94113BR

* Raytheon Australia; Canberra, Australia;
Export/Import Operations Advisor; Requisition ID: 86438BR

* Raytheon; Fullerton CA;
Manager of Export-Import Control, Empowered Official (RCCS); Requisition ID: 93625BR

* Raytheon; McKinney TX;
Counsel Global Trade Compliance
; Requisition ID: 94826BR

* Raytheon; Portsmouth RI;
Manager of Export Import Control, Empowered Official
; Requisition ID: 93628

* Raytheon; Woburn MA;
Supply Chain Compliance Manager; Requisition ID: 93734BR

* Raytheon; Woburn MA;
Supply Chain Subcontract Manager; Requisition ID: 93615BR

* Raytheon Integrated Defense Systems; Andover MA;
Export Licensing & Compliance Advisor, Global Trade; Requisition ID: 93670BR

* Raytheon Intelligence, Information and Services; Annapolis Junction MD or Dulles VA;
Sr Exp License&Compliance Adv; Requisition ID: 91338BR

* Raytheon Intelligence, Information and Services; Orlando FL;
Sr Exp License&Compliance Adv; Requisition ID: 92852BR

* Raytheon Space & Airborne Systems; McKinney TX;
Sr Exp License & Compliance Adv;
; 310-334-7499; Requisition ID:

* Synopsys; Mountain View CA;
Senior Manager, Export Compliance
650-584-1676; Requisition ID: 13208BR
* Talbots; Hingham MA;
Sr Mgr Global Trade & Customs Compliance
; Requisition ID: 1077
* Talbots; Lakeville MA;
Dir., Global Logistics & Customs Com
; Requisition ID: 1085

# Teledyne Microwave Solutions; Mountain View CA;

Trade Compliance Administrator 2
; Requisition ID: 2017-4111

* Tesla Motors; Fremont CA;
Global Supply Manager – Logistics
; Requisition ID: 38153

* Thales Defense and Security, Inc.; Clarksburg MD; Senior Manager Trade Compliance
; William.Denning@thalesdsi.com; Requisition ID: 2592

# ThermoFisher Scientific; Breda, the Netherlands;
Import/Export Specialist – EMEA CMD Commercial Offices
; Requisition ID: 44930BR

* ThermoFisher Scientific; Matamoros, Mexico;
Import/Export Supervisor
; Requisition ID: 39750BR

* ThermoFisher Scientific; Shanghai, China;
Trade Compliance Specialist – CMC
; Requisition ID: 42143BR

# UCB; Braine L’alleud, Belgium;
Manager Global Customs and Trade Compliance

* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC

Intern, International Trade Compliance
; Requisition ID: 45442BR

* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
Specialist, ITC IT Systems
; Requisition ID:

* United Technologies Corporation, UTC Aerospace Systems; Chula Vista CA;

International Trade Compliance Intern
; Requisition ID:

# United Technologies Corporation, UTC Aerospace Systems; Chula Vista CT;
International Trade Compliance Analyst
; Requisition ID: 46876BR

* United Technologies Corporation, Otis; Farmington, CT;
International Trade Compliance (ITC) Program Manager
; Requisition ID: 44984BR

# United Technologies Corporation, UTC Aerospace Systems; Fort Worth TX;
Manager, Intl Trade Compl
; Requisition ID: 46311BR

* United Technologies Corporation, UTC Aerospace Systems; Santa Fe Springs CA;
Sr. Analyst, International Trade Compliance
; Requisition ID: 46184BR

* United Technologies Corporation, UTC Aerospace Systems; Troy OH;
Sr. Manager, Intl Trade Compliance
; Requisition ID: 44065BR 

* United Technologies Corporation, UTC Aerospace Systems; Vergennes, VT;

ITC Generalist
; Requisition ID:
* United Technologies Corporation, UTC Aerospace Systems; Westford MA;
Senior Analyst, International Trade Compliance
; Requisition ID: 31576BR

# United Technologies Corporation, UTC Aerospace Systems; Windsor Locks CT;
Customs and Import Specialist; Requisition ID: 42570BR

* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks, CT;
IT Export & Compliance Intern
; Requisition ID: 42148BR

# United Technologies Corporation, UTC Aerospace Systems; Windsor Lock CT;
International Trade Compliance Site Lead
; Requisition ID: 47259BR

* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks, CT; 
Spec, Intl Trade Compl
; Requisition ID: 44177BBR

* Vigilant; Unknown location in the U.S.;
BioTech/Pharmaceutical Global Trade Analyst

* Wurth Industry of North America; Indianapolis IN; Trade Compliance Officer;
International Trade Compliance Officer
; Requisition ID: 389-720

* XPO Logistics; Greenwich CT;
Global Trade Compliance Analyst

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Monday, 24 April 2017
Anthony Trollope (
24 Apr 1815 – 6 Dec 1882, was an English novelist of the Victorian era. Among his best-known works is a series of novels collectively known as the
Chronicles of Barsetshire, which revolves around the imaginary county of
 – “
I hold that gentleman to be the best-dressed whose dress no one observes.”
Monday is pun day:
Q. Why did the tomato blush?
A. Because she saw the salad dressing.
Q. What did one hat say to the other hat?
A. You stay here, I’ll go on ahead.
  – Jo Harper,
Ashland, OH 44805
* * * * * * * * * * * * * * * * * * * *

. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  Changes to applicable regulations are listed below.
: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War
  – Last Amendment: 15 Jan 2016: 81 FR 2657-2723: Machineguns, Destructive Devices and Certain Other Firearms; Background Checks for Responsible Persons of a Trust or Legal Entity With Respect To Making or Transferring a Firearm. 
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment: 27 Jan 2017: 82 FR 8589-8590: Delay of Effective Date for Importations of Certain Vehicles and Engines Subject to Federal Antipollution Emission Standards; and 82 FR 8590: Delay of Effective Date for Toxic Substance Control Act Chemical Substance Import Certification Process Revisions.

  – Last Amendment: 18 May 2016: Change 2: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and canceled Supp. 1 to the NISPOM  (Summary here.)

  – Last Amendment: 18 Apr 2017: 82 FR 18217-18220: Revision to an Entry on the Entity List)

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment:
10 Feb 2017: 82 FR 10434-10440: Inflation Adjustment of Civil Monetary Penalties. 
: 15 CFR Part 30
  – Last Amendment: 19 Apr 2017: 82 FR 18383-18393: Foreign Trade Regulations: Clarification on Filing Requirements 
  – HTS codes that are not valid for AES are available
  – The latest edition (19 Apr 2017) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR contains all FTR amendments, FTR Letters and Notices, a large Index, and footnotes containing case annotations, practice tips, and Census/AES guidance.  Subscribers receive revised copies every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance website.  BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR.
, 1 Jan 2017: 19 USC 1202 Annex. (“HTS” and “HTSA” are often seen as abbreviations for the Harmonized Tariff Schedule of the United States Annotated, shortened versions of “HTSUSA”.)
  – Last Amendment: 7 Mar 2017: Harmonized System Update 1702, containing 1,754 ABI records and 360 harmonized tariff records. 
  – HTS codes for AES are available
  – HTS codes that are not valid for AES are available
  – Latest Amendment: 11 Jan 2017: 82 FR 3168-3170: 2017 Civil Monetary Penalties Inflationary Adjustment
  – The only available fully updated copy (latest edition 8 Mar 2017) of the ITAR is Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III. The BITAR contains all ITAR amendments to date, plus a large Index, over 750 footnotes containing case annotations, practice tips, DDTC guidance, and explanations of errors in the official ITAR text.  Subscribers receive updated copies of the BITAR in Word by email, usually revised within 24 hours after every ITAR amendment.  The BITAR is available by annual subscription from the Full Circle Compliance website.  BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please contact us to receive your discount code.

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Review last week’s top Ex/Im stories in “Weekly Highlights of the Daily Bugle Top Stories” published

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* The Ex/Im Daily Update is a publication of FCC Advisory B.V., edited by James E. Bartlett III and Alexander Bosch, and emailed every business day to approximately 8,000 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOJ/ATF, DoD/DSS, DoD/DTSA, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

* RIGHTS & RESTRICTIONS: This email contains no proprietary, classified, or export-controlled information. All items are obtained from public sources or are published with permission of private contributors, and may be freely circulated without further permission. Any further use of contributors’ material, however, must comply with applicable copyright laws.

* CAVEAT: The contents of this newsletter cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.

* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website.

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