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16-1024 Monday “The Daily Bugle”

16-1024 Monday “Daily Bugle”

Monday, 24 October 2016

TOP
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 
here for free subscription.  Contact us
for advertising inquiries and rates.
 

  1. Justice/ATF Seeks Comments on ATF Form 2 (5320) Notice of Firearms Manufactured or Imported 
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. Commerce/Census: “Tips on How to Resolve AES Fatal Errors” 
  4. DoD/DSS Posts Notice on PSMO-I Knowledge Center Shutting Down Last Business Day of Each Month 
  5. State/DDTC No Longer Accepts CJ Submission through EFS 
  6. State/DDTC Posts Revision 4.4b of Guidelines for Preparing Agreements 
  7. State/DDTC IT Systems Unavailable on 28 Oct 
  8. EU Extends Restrictive Measure Concerning Situation in Ukraine Until 15 Mar 2017 
  1. Opensource.com: “Distributing Encryption Software May Break the Law” 
  2. ST&R Trade Report: “U.S. Services Exports and Imports Up in 2014” 
  3. Washington Post: “Ex-NSA Contractor Accused of Massive Theft Is a ‘Collector,’ Not a ‘Traitor,’ Lawyers Say” 
  1. Gary Stanley’s ECR Tip of the Day 
  1. Robert McMillan Named Executive Director of CBP’s Regulatory Audit 
  2. Monday List of Ex/Im Job Openings: 108 Jobs Posted 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (26 Aug 2016), DOD/NISPOM (18 May 2016), EAR (17 Oct 2016), FACR/OFAC (17 Oct 2016), FTR (15 May 2015), HTSUS (30 Aug 2016), ITAR (12 Oct 2016) 

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a11. Justice/ATF Seeks Comments on ATF Form 2 (5320) Notice of Firearms Manufactured or Imported

 
81 FR 73140: Agency Information Collection Activities; Proposed eCollection eComments Requested; Notice of Firearms Manufactured or Imported (ATF Form 2 (5320.2)
* AGENCY: Bureau of Alcohol, Tobacco, Firearms and Explosives, Department of Justice.
* ACTION: 60-Day notice. …
* DATES: Comments are encouraged and will be accepted for 60 days until December 23, 2016.
* FOR FURTHER INFORMATION CONTACT: Gary Schaible, Office of Enforcement Programs and Services, National Firearms Act Division, Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) either by mail at 99 New York Ave. NE., Washington, DC 20226, by email at nfaombcomments@atf.gov, or by telephone 202-648-7165.
* SUPPLEMENTARY INFORMATION: …
  – The Title of the Form/Collection: Notice of Firearms Manufactured
or Imported.
  – Form number (if applicable): ATF Form 2 (5320.2).
  – Component: Bureau of Alcohol, Tobacco, Firearms and Explosives, U.S. Department of Justice.
  – Abstract: The ATF Form 2 (5320.2) is required of (1) a person who is qualified to manufacture National Firearms Act (NFA) firearms, or (2) a person who is qualified to import NFA firearms to register manufactured or imported NFA firearm(s). …
 
   Dated: October 18, 2016.
Jerri Murray, Department Clearance Officer for PRA, U.S. Department of Justice.
* * * * * * * * * * * * * * * * * * * *

OGSOTHER GOVERNMENT SOURCES

OGS_a12. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

 
* President; ADMINISTRATIVE ORDERS; Congo, Democratic Republic of the; Continuation of National Emergency (Notice of October 21, 2016) [Publication Date: 25 October 2016.]

* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 25 October 2016.]  

* * * * * * * * * * * * * * * * * * * *

* * * * * * * * * * * * * * * * * * * *

 
When a shipment is filed to the AES, a system response message is generated and indicates whether the shipment has been accepted or rejected. If the shipment is accepted, the AES filer receives an Internal Transaction Number (ITN) as confirmation. However, if the shipment is rejected, a Fatal Error notification is received.
 
To help you resolve AES Fatal Errors, here are some tips on how to correct the most frequent errors that were generated in AES for this month.
 
Fatal Error Response Code: 110
 
  – Narrative: State of Origin Unknown
  – Reason: The U.S. State of Origin indicated is not valid in AES.
  – Resolution: The U.S. State of Origin Code must be a valid two-character U.S. state, territory, or possession code (i.e., any USPS code). Verify the State of Origin, correct the shipment and resubmit.
 
Fatal Error Response Code: 572
 
  – Narrative: DDTC Registrant Expired
  – Reason: The DDTC Registration Number reported is not valid in the AES at the time of export.
  – Resolution: When the License Code/License Exemption Code indicates a Department of State – Directorate of Defense Trade Controls (DDTC) license (SAG, SCA, S00, S05, S61, S73, S85 or S94), the DDTC Registration Number must be reported. The DDTC Registration Number must be valid in the AES and cannot be expired at the time of export. Verify the DDTC Registration Number and the Estimated Date of Export, correct the shipment and resubmit. For further assistance, contact the licensing agency. The Department of State – Directorate of Defense Trade Controls / DDTC Help Desk can be reached on 202-663-2838.
 
For a complete list of Fatal Error Response Codes, their reasons, and resolutions, see Appendix A – Commodity Filing Response Messages.
 
It is important that AES filers correct Fatal Errors as soon as they are received in order to comply with the Foreign Trade Regulations. These errors must be corrected prior to export for shipments filed predeparture and as soon as possible for shipments filed postdeparture, but not later than five calendar days after departure.
 
For further information or questions, contact the U.S. Census Bureau’s Data Collection Branch.
 
  – Telephone: (800) 549-0595, select option 1 for AES.
  – Email: askaes@census.gov
  – Online: www.census.gov/trade

* * * * * * * * * * * * * * * * * * * *

OGS_a45. DoD/DSS Posts Notice on PSMO-I Knowledge Center Shutting Down Last Business Day of Each Month
(Source: DoD/DSS)
 
As a reminder, the PSMO-I Knowledge Center will shut down the last business day of each month for the purpose of conducting internal training to deliver the highest quality customer service to Industry and Government callers. Personnel security inquiries to include e-QIP (option #2) of the DSS Knowledge Center will be unavailable on Monday, October 31, 2016, but will resume normal business hours on Tuesday, November 1, 2016.
* * * * * * * * * * * * * * * * * * * *

OGS_a56. State/DDTC No Longer Accepts CJ Submission through EFS
(Source: State/DDTC)
 
Effective Wednesday, November 16th at 5PM EST, The Department of State will no longer use the Electronic Form Submission (EFS) application to accept Commodity Jurisdiction (CJ) (DS-4076) applications. Beginning Monday, November 21st at 8AM EST users will submit CJ applications via the Defense Export Control and Compliance (DECCS) CJ application.
* * * * * * * * * * * * * * * * * * * *

OGS_a67. State/DDTC Posts Revision 4.4b of Guidelines for Preparing Agreements

(Source: State/DDTC)
 
Summary of Changes:
 
This revision reflects conforming changes to the latest ITAR updates from 81 FR 66804 and 81 FR 54732. It also adds administrative clarifications for some of the changes made in Revision 4.4. The changes from 81 FR 54732 will go into effect on 15 November 2016.
 
Conforming Changes Resulting from the latest ITAR Revisions:
 
  – Updates the DCS references to reflect the changes to § 123.9(b)(iv), § 124.9(a)(6) and §124.14(c)(7)
  – Adds a statement listing the sales territory to the § 124.7(a)(4) paragraph of MLAs
o Sec 5.2.c.4, Appendix A – Tabs 3 and 7
  – Updates references to § 126.1 countries
  – Updates references from § 124.7 to § 124.7(a) to reflect the new ITAR designations*
  – Updates references from § 124.8 to § 124.8(a) to reflect the new ITAR designations*#
 
* As there were over 100 instances of § 124.7 and § 124.8 in the Agreements Guidelines, and since the changes were purely administrative in nature, the updated references have not been highlighted in all instances.
 
# This change affects all the required Option 2 DN/TCN request statements in Section 3.5.
 
Clarifications:
 
  – Clarifies that conforming statement changes should be updated at the next amendment, whether major or minor
  – Clarifies that § 126.18(c) and § 126.18(d) are separate vetting options (Sec 3.5.b, Fig 3.1)
  – Clarifies how to update Space Insurance amendments when adding the conforming changes
  – Clarifies that Section 20.4.g applies to reexports and retransfers
  – Adds Appendix G – Summary of Changes from Revisions 4.4 and 4.4a
 
Applicants are not required to submit an amendment for the sole purpose of updating the revised statements in Revisions 4.4 and 4.4b, or to reflect other conforming changes. However, the conforming changes should be made at the next amendment, whether major or minor. All new agreement/amendment applications submitted after November 15, 2016, should conform to all the changes in Revision 4.4b. If the changes have not been made, provisos will be added instructing the applicant to make the changes prior to execution. Applicants may submit agreements that conform to the changes in Revision 4.4b prior to November 15.
 
Notes: The ITAR updates in 81 FR 54732 go into effect on November 15, 2016. Applicants are responsible for notifying their foreign signatories of these changes.
 
Existing NDAs remain valid. Sublicensees and DN/TCNs are not required to re-execute NDAs.

* * * * * * * * * * * * * * * * * * * *

OGS_a78. State/DDTC IT Systems Unavailable on 28 Oct

(Source: State/DDTC)
 
All DDTC systems, including DTrade and EFS, will be unavailable to industry from 5:30PM (EST) Friday, October 28, through 9:30PM (EST) due to scheduled system maintenance.

* * * * * * * * * * * * * * * * * * * *

OGS_a89. EU Extends Restrictive Measure Concerning Situation in Ukraine Until 15 Mar 2017
 
On 15 September 2016, the Council adopted Council Decision (CFSP) 2016/1671 [FN/1].
 
The Council Decision extends the existing measures until 15 March 2017 and amends the list of persons and entities subject to restrictive measures as set out in the Annex to Decision 2014/145/CFSP.
 
The Candidate Countries Montenegro and Albania, and the EFTA countries Liechtenstein and Norway, members of the European Economic Area, as well as Ukraine align themselves with this Council Decision.  
They will ensure that their national policies conform to this Council Decision.  
The European Union takes note of this commitment and welcomes it.
————–
  [FN/1] Published on 16.9.2016 in the Official Journal of the European Union no. L 249, p.39.
* * * * * * * * * * * * * * * * * * * *

NWSNEWS

NWS_a110. Opensource.com: “Distributing Encryption Software May Break the Law”
(Source: opensource.com)
 
Developers, distributors, and users of Free and Open Source Software (FOSS) often face a host of legal issues, which they need to keep in mind. Although areas of law such as copyright, trademark, and patents are frequently discussed, these are not the only legal concerns for FOSS. One area that often escapes notice is export controls. It may come as a surprise that sharing software that performs or uses cryptographic functions on a public website could be a violation of U.S. export control law.
 
Export controls
is a term for the various legal rules which together have the effect of placing restrictions, conditions, or even wholesale prohibitions on certain types of export as a means to promote national security interests and foreign policy objectives. Export control has a long history in the United States that goes back to the Revolutionary War with an embargo of trade with Great Britain by the First Continental Congress. The modern United States export control regime includes the Department of State’s regulations covering export of munitions, the Treasury Department’s enforcement of United States’ foreign embargoes and sanctions regimes, and the Department of Commerce’s regulations applying to exports of “dual-use” items, i.e. items which have civil applications as well as terrorism, military, or weapons of mass destruction-related applications.
 
In the aftermath of World War II, the strategic importance of cryptographic technology had been clearly established, and cryptographic items were recognized as important subjects in U.S export control policy. Initially, encryption software and technology items were viewed as entirely military in nature, and their export was accordingly severely limited. However, this conclusion was challenged in the 1960s by the global financial system’s increasing use of wired money transfer, which presented a compelling international civilian market demand for cryptography. In 1975 the U.S. released the IBM-developed and NSA-modified Data Encryption Standard (DES) for use by government and commercial parties. This release is commonly seen as a pivotal moment for the growth of civil cryptography internationally. However, even with DES, cryptographic software was still the exclusive domain of large corporations and academic researchers, and was far from a matter of public concern.
 
The personal computer boom and the spread of the Internet in the 1980s and 1990s contributed to a massive increase in the market for cryptographic software among the broader public for use in, among other things, e-commerce. The government, faced with the competing interests of the civilian demand for strong cryptography and the intelligence value of prohibiting access to cryptographic items by foreign powers, developed regulations that encouraged companies to create domestic and international variants of their products with different levels of cryptographic functionality, and further scrambled to assure its own domestic access to data through efforts such as the failed backdoor Clipper chip. This period of efforts by the government to restrict broader access to strong encryption despite popular demand is often referred to as the “crypto wars”. Export controls for encryption software were relaxed in a steady progression throughout the late 1990s, and by January 10, 2000 the rules were amended to the point that most saw the crypto wars as over and done with.
 
Although encryption software today is no longer classified primarily as a munition, the crypto wars did not end export controls on encryption software entirely. Moreover, in recent years the topic of encryption policy is in the realm of mainstream public debate once again. Export of encryption software is still regulated (chiefly by the Department of Commerce regime for dual-use goods) and violations of those regulations are enforced.
 
Export controls compliance
 
FOSS cryptography is a powerful tool for protecting the confidentiality, integrity, and authentication of information against even the most capable adversaries, but distributing these tools may carry some risk. While some distributors of FOSS encryption software may qualify for some of the low-or-no burden exemptions, exclusions, and exceptions from the Department of Commerce’s prohibitions on export, others may face significant compliance obligations.
 
When it comes to ensuring export controls compliance there is no substitute for consultation with a knowledgeable attorney. Determining applicable obligations under the export control regimes and the best way to satisfy those obligations can be a complex and challenging task which sometimes requires not only a mastery of the law, but also a competent grasp of the software in question.
* * * * * * * * * * * * * * * * * * * *

NWS_a211. ST&R Trade Report: “U.S. Services Exports and Imports Up in 2014”
 
The International Trade Commission’s annual report on trends in U.S. services trade finds that the U.S. is the world’s largest services market and was the world’s leading exporter and importer of services in 2014. This report presents a qualitative and quantitative overview of U.S. trade in services and highlights some of the service sectors and geographic markets that contribute substantially to recent services trade performance. This year’s report focuses on financial services and includes chapters on banking, insurance, and securities services. Each chapter analyzes global market conditions in the industry, examines recent trade performance, and summarizes the industry’s outlook.
 
Highlights of this year’s report include the following.
 
  – In 2014, the value of U.S. commercial services exports was $690.1 billion (up 4.2 percent from 2013 and representing 14 percent of the global total) while imports totaled $453.3 billion (up 5.1 percent and accounting for 9 percent of the global total). Preliminary data for 2015 indicate that U.S. commercial services exports were up 5.9 percent and that imports were up 3.0 percent.
 
  – From 2013 to 2014 U.S. cross-border services exports rose nearly 4 percent while imports grew 3 percent. Financial services accounted for 15 percent of exports and 15 percent of imports, resulting in a trade surplus of $35.1 billion in this subsector in 2014.
 
  – Within the services sector, sales by foreign affiliates of U.S. firms – the leading channel by which many U.S. services are delivered to foreign markets – rose 3 percent to just over $1.3 trillion in 2013. Financial services accounted for about 20 percent of total sales by U.S.-owned foreign affiliates.
 
  – Financial services are facing significant challenges from digital technologies and in navigating the post-recessionary financial landscape of increased regulation and low interest rates. U.S. financial services firms have adapted by incorporating new financial technologies into their operations but also face rising cybersecurity risks. In addition, the growth of the Chinese financial system has increased competition for U.S. banks while at the same time creating an attractive market for U.S. securities firms.
* * * * * * * * * * * * * * * * * * * *

NWS_a312. Washington Post: “Ex-NSA Contractor Accused of Massive Theft Is a ‘Collector,’ Not a ‘Traitor,’ Lawyers Say”

(Source: Washington Post) [Excerpts.]
 
A federal judge found Friday that a former National Security Agency contractor accused of carrying out what is thought to be the largest theft of classified secrets in U.S. history posed a flight risk and ordered that he continue to be held in jail.
 
U.S. Magistrate Judge A. David Copperthite ruled that Harold T. Martin III should not be released pending trial, despite the impassioned arguments of his defense attorney that the computer technology expert is a patriot who intended no harm to his country and suffered from a “compulsive disorder” that led him to steal classified material over a 20-year period.
 
Defense attorney James Wyda conceded that Martin took the material, but he stressed that “there’s no evidence that Hal shared this information with anyone” or that he intended to pass it to a foreign government. …
 
Martin was charged in a sealed complaint in August with felony theft of government property and the unauthorized removal of classified materials, a misdemeanor. The complaint was unsealed this month when word of his arrest leaked out.
 
In a memo filed this week, the government said Martin had taken at least 50 terabytes of digital data, roughly the equivalent of 500 million pages of documents. He also took six banker’s boxes worth of paper documents, prosecutors said, many of which were lying open in his home or in his car. And investigators found dozens of computers, thumb drives and other digital storage devices that belonged to the government, prosecutors said. …

* * * * * * * * * * * * * * * * * * * *

COMMCOMMENTARY

COMM_a113. Gary Stanley’s ECR Tip of the Day
(Source: Defense and Export-Import Update; available by subscription from
gstanley@glstrade.com
)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
 
According to 22 CFR 126.13, all licenses or other requests must include a letter signed by a responsible official empowered by the applicant. With the implementation of electronic licensing via the DSP-5, -6, -61, -62, -73, and -74 forms, this requirement is fulfilled via an actual empowered official in the Industry Signature Authority role completing the Applicant Statement portion of the application and within the 22 CFR 126.13 Certification section selecting option a, b, or c as appropriate. If you are a Super User or User assigned the role of Industry Signature Authority and ARE NOT an empowered official, then you MUST select option d, e, or f as appropriate and attach to the application a letter meeting the requirements of 22 CFR 126.13 signed by an empowered official.
* * * * * * * * * * * * * * * * * * * *

MSEX/IM MOVERS & SHAKERS

MS_a214. Robert McMillan Named Executive Director of CBP’s Regulatory Audit
 
U.S. Customs and Border Protection announced Oct. 20 the selection of Robert McMillan as executive director of regulatory audit within CBP’s Office of Trade. A CBP press release states that McMillan is joining CBP with more than 20 years’ leadership experience in audit, finance, and transformation within the health care, financial services, and consumer products industries.
Most recently, McMillan served as chief financial officer and audit and compliance officer for AmeriHealth Caritas/Chartered Health Plan. Prior to that he served as the chief executive director of audit, finance, privacy, and procurement for Blue Cross/Blue Shield, where he oversaw the global administration of the Federal Employee Health Benefit Plan. His tenure at BC/BS also included serving as director of Sarbanes-Oxley and compliance and manager of e-commerce. McMillan spent a portion of his earlier career serving in several leadership capacities with Motorola as an integral member of the business transformation office.
* * * * * * * * * * * * * * * * * * * *

MS_a115
. Monday List of Ex/Im Job Openings: 108 Jobs Posted

(Source: Editor)  


 
Published every Monday or first business day of the week.  Send openings in the following format to
apbosch@fullcirclecompliance.eu
.
 
COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFO; REQ ID

#” New listing this week:

 

* 3M; Maplewood MN;
Trade Compliance Project Leader
; Requisition ID: 112850

* Abbvie; Lake County IL;
Senior Analyst, Global Trade Compliance
; Requisition ID: 1605835

* The Aerospace Corporation; Crystal City VA; 
Export Compliance Staff V
; Requisition ID: 2761

* Agilent; Singapore;
Global Trade Compliance Manager – South Asia Region
; Requisition ID: 2068249

* Amazon; London, UK;
Senior Trade Compliance Program Manager (M/F)
; Requisition ID: 429019

* Amazon; Seattle WA;
Compliance Investigator
; Requisition ID: 432560
* Amazon; Seattle WA;
Compliance Investigator
; Requisition ID: 432561
* Amazon; Seattle WA;
Compliance Investigator
; Requisition ID: 432564
* Amazon; Seattle WA;
Sanctions Compliance Specialist
; Requisition ID: 431298

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

* Amazon; Seattle WA;
Prime Air Trade Compliance Program Manager; Requisition ID: 395658

* Amazon; Singapore;
Sr. Trade Compliance Manager
; Requisition ID: 441734

* Aramco Services Company; Houston TX;
Trade Compliance Specialist
; Requisition ID: 295802


* Bourns Inc.; Riverside CA;
Director Worldwide Contracts
;
ournsHR.Riv@bourns.com


* Bunn-O-Matic Corporation; Springfield IL;
Global Logistics Analyst
;
employment.openings@bunn.com
; GO1678
* Bunn-O-Matic Corporation; Springfield IL;
Global Trade Compliance Analyst
;
employment.openings@bunn.com
; GO1687

# Catalent; Swindon, Bathgate or Bolton, UK;
International Trade Compliance Analyst
; Requisition ID: 0020306

* Cirrus Logic; Austin TX;
Logistics & Trade Compliance Analyst
; Requisition ID: RB-3290

* CONMED Corporation; Utica NY;
Logistics & Trade Compliance Analyst
; Requisition ID: 3469

* Continental; Manila,
Philippines;
Head of Transportation and Foreign Trade Compliance
; Requisition ID: 42475BR

* Coriant; Naperville IL;
Sr Mgr of Global Trade Compliance
; Requisition ID: 11353

* Crane Currency; Nashua NH;
Import/Export & Logistics Manager
; Requisition ID: 2016-1459

* DeLaval; Kansas City MO;
Trade Compliance Manager

# Dow; Terneuzen, The Netherlands;
Customs & Trade Compliance Leader – Europe (M/F)
; Requisition ID: 16066552

* DRS Technologies; Germantown MD;
Senior Trade Compliance Manager
;
Requisition ID: 54749

* DRS Technologies; Melbourne FL;
Senior Trade Compliance Specialist
; Requisition ID: 59327

*
DynCorp International LLC; Fort Worth TX;
BD Trade Compliance Manager
; Requisition ID: 1601114

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

* Esterline Technologies Corporation; Bellevue WA;
Senior Manager Trade Compliance – Segment Jurisdiction and Classification
; Requisition ID: 7187BR

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

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

* Esterline Technologies Corporation; Tijuana, Mexico;
Trade Compliance Specialist IV
; Requisition ID: 8341BR

* Expeditors; Bangkok, Thailand; Regional Trade Compliance Manager – Indochina & Philippines
* Export Solutions Inc.; Melbourne FL; 

Trade Compliance Specialist II

info@exportsolutionsinc.com

* FLIR Systems; Arlington VA;
Director of Defense Trade Licensing & Compliance

# General Dynamics; South Wales, UK;
Senior Trade Compliance Officer
; Requisition ID: 6079

* Google; Amsterdam, the Netherlands;
Export Compliance Program Manager

* Graco; Rogers MN;
Trade Compliance Supervisor 

* Henderson Group Unlimited Inc.; Wash DC;
Commodities Jurisdiction Analyst
;
alannasmith@hendersongroupinc.net


* Henkel; Amsterdam, the Netherlands;
Global Trade Compliance Manager (m/f)
; Requisition ID:
160004JX


# Intel; Santa Clara CA;
Global Export Compliance Specialist
; Requisition ID: 814909

* Intuitive Surgical; Sunnyvale CA;
Senior Manager, Trade Compliance
; Requisition ID: 161341

* IPG Photonics; Oxford MA;
Trade Compliance Analyst

# Jacobs; Houston TX;
Trade Compliance Coordinator
; Requisition ID: REF00008A

* L-3 Communications; Greenville TX;
International Trade Compliance Admin 2
; Requisition ID: 083430

* L-3 Communications, Combat Propulsion Division; Muskegon MI;
Sr. Rep. – Global Trade Compliance
; Requisition ID: 084817

* Lam Research Corporation; Fremont CA:
Foreign Trade Analyst 6
; Requisition ID: 12079BR

# Linde; Stewartsville NJ;
Compliance Administrator; Requisition ID: 916130

* Lumber Liquidators; Toano VA;
Compliance Auditor
; Requisition ID: 913

* Lumber Liquidators; Toano VA;
Supply Chain Compliance Specialist
; Requisition ID: 1578
* Lutron; Coopersburg PA;
Global Trade Compliance Leader
; Requisition ID: 3050

* Lutron; Coopersburg PA; Trade Compliance Coordinator; Requisition ID: 2834

* MACOM; Lowell MA;
Trade Compliance Analyst 1
; Requisition ID: 1529

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

* Meggitt (Erlanger), LLC; Erlanger KY;
Trade Compliance Manager
; Requisition ID: 22005

* Meggitt Advanced Composites Limited; Shepshed, UK;
Trade Compliance Officer
; Requisition ID: 22122

* Meggitt PLC; Los Angeles CA;
Trade Compliance Administrator
; Requisition ID: 22591

* Mentor Graphics; Fremont CA;
Senior Global Trade Compliance Manager
; Requisition ID: 5129

* Microsoft; Redmond WA;
Trade Director, Regulatory Compliance & Standards
;
rybeli@microsoft.com
; Requisition ID: 973167

* Moog; East Aurora NY;
Export Compliance Manager
;
anihill@moog.com
; Requisition ID: 161913

* Northrop Grumman T
echnology Services Sector, Advanced Defense Services (ADS) Division
; International Posting (Saudi Arabia);
Manager International Trade Compliance 1
(Saudi Arabia)
; Requisition ID: 16003577

* Northrop Grumman Corporation; Sierra Vista AZ and Herndon VA;

International Trade Compliance Analyst 4
; Requisition ID: 16008077 

# Northrop Grumman Corporation; El Segundo CA;
International Trade Compliance Analyst 4
; Requisition ID: 16024349
# Northrop Grumman Corporation; Falls Church VA;
Corporate Counsel
; Requisition ID: 16025649

* Northrop Grumman Corporation; Falls Church VA;
International Trade Compliance Analyst 3/4
; Requisition ID: 16016665

* Northrop Grumman Corporation; Falls Church VA;
International Trade Compliance Manager 1
; Requisition ID: 16023413

* Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 3
; Requisition ID: 16013233

# Northrop Grumman Corporation; Melbourne FL;
Manager International Trade Compliance 2 – Military Aircraft Systems
; Requisition ID: 16025266

* Northrop Grumman Corporation; Rolling Meadows IL;
International Trade Compliance Analyst 3
; Requisition ID: 160123994

* Northrop Grumman Corporation; San Diego CA;
Manager International Trade Compliance 2
; Requisition ID: 16017984


# Paraxel; Berlin, Germany;
Trade Compliance Specialist
; Requisition ID:
pare-10055069

* PerkinElmer; Waltham MA;
International Trade Compliance Associate, Informatics 

* PerkinElmer; Waltham MA;
Manager Trade & Customs

* Raytheon; Arlington VA;
Export Licensing SME/Empowered Official
; Requisition ID: 85810BR


* Raytheon; El Segundo CA;
Manager I Export-Import Control
; Requisition ID: 85354BR

* Raytheon; Fullerton CA;
Global Trade Compliance Manager
; Requisition ID: 85521BR

* Raytheon; Indianapolis IN;
Director Export-Import Control
; Requisition ID: 86373BR
* Raytheon; Indianapolis IN;
Principal SC Compliance Specialist
; Requisition ID: 84932BR

* Raytheon; Rosslyn VA;
Director of Licensing; Requisition ID: 83836BR


* Raytheon; Waltham MA;
Sr Principal SC Compliance Specialist
; Requisition ID: 86169BR
* Sekisui; San Diego CA;
International Trade Compliance Associate
; Requisition ID: 1196

* SpaceX; Washington DC;
Counsel – Export Compliance Officer


* Tecomet; Lansing MI;
Export Control Coordinator – EAR/ITAR
; Requisition ID: 1539

* TE Connectivity; Middletown PA;
Senior Director Global Trade Services
; Requisition ID: 2016-73314

# Tenneco; Edenkoben, Germany;
Global Trade Compliance Manager (m/w)
; Requisition ID: 176871-846

* Textron Systems; Hunt Valley MD;
Principal Export Compliance Analyst
; Requisition ID: 242851

* Textron Systems; Wilmington MA;
Principal Export Compliance Analyst
; Requisition ID: 242857


* Thales; Piscataway NJ;
Manager, Trade Compliance
; Requisition ID: R0012077

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

* ThermoFisher Scientific; Shanghai, China;
Compliance Director, Greater China
; Requisition ID: 38520BR
* ThermoFisher Scientific; Shanghai, China;
Sr. Compliance Specialist
; Requisition ID: 37066BR

* Troy Corporation; Florham Park NJ;
Global Trade and Compliance Manager
; Requisition ID: 306


* United States Pharmacopeia; Rockville MD OR Frederick MD;
Trade Compliance Specialist
;
Meaghan Ireland –
mci@usp.org
;
Requisition ID: 709-679

* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
Self-Assessment Senior Specialist
; Requisition ID: 13727BR 

* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
Manager, ITC-Authorizations
; Requisition ID: 22846BR  

* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
Specialist, ITC IT Systems
; Requisition ID: 33792BR

* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;

* United Technologies Corporation, UTC Aerospace Systems; Danbury CT; 
Sr Analyst, International Trade Compliance
; Requisition ID: 28174BR


* United Technologies Corporation, UTC Aerospace Systems; Phoenix AZ; Sr Analyst, International Trade Compliance; Requisition ID: 30058BR 
* United Technologies Corporation, UTC Aerospace Systems; Pueblo CO; 
Sr Analyst, Intl Trade Compliance
; Requisition ID: 27643BR


* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks CT;
Specialist, Intl Trade Compliance Authorizations
;
Requisition ID: 33970BR


* XPO Logistics; Greenwich CT;
Global Trade Compliance Analyst


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ENEDITOR’S NOTES

* * * * * * * * * * * * * * * * * * * *

EN_a217
. 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.
 
*
ATF ARMS IMPORT REGULATIONS
: 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 
 
*
CUSTOMS REGULATIONS
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment: 26 Aug 2016: 81 FR 58831-58834: Administrative Exemption on Value Increased for Certain Articles 

* DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM): DoD 5220.22-M
  – 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.)

* EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774 
  – Last Amendment: 17 Oct 2016: 81 FR 71365-71367: Cuba: Revisions to License Exceptions  

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 17 Oct 2016: 81 FR 71372-71378: Cuban Assets Control Regulations 
 
*
FOREIGN TRADE REGULATIONS (FTR)
: 15 CFR Part 30
  – Last Amendment: 15 May 2015; 80 FR 27853-27854: Foreign Trade Regulations (FTR): Reinstatement of Exemptions Related to Temporary Exports, Carnets, and Shipments Under a Temporary Import Bond 
  – HTS codes that are not valid for AES are available
here.
  – The latest edition (9 Mar 2016) 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.
 
*
HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA)
, 1 Jul 2016: 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: 30 Aug 2016; Harmonized System Update (HSU) 1612, containing 4,692 ABI records and 935 harmonized tariff records.  
  – HTS codes for AES are available
here
.
  – HTS codes that are not valid for AES are available
here.
 
INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130 (Caution — The ITAR as posted on GPO’s eCFR website and linked on the DDTC often takes several weeks to update the latest amendments.)
  – Latest Amendment: 12 Oct 2016: 81 FR 70340-70357: Amendment to the International Traffic in Arms Regulations: Revision of U.S. Munitions List Category XII and associated sections.
  – The only available fully updated copy (latest edition 12 Oct 2016) of the ITAR with all amendments is contained in Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III.  The BITAR contains all ITAR amendments to date, footnotes to amendments that will take effect on 15 November and 31 December, plus a large Index and 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.

* * * * * * * * * * * * * * * * * * * *

EPEDITORIAL POLICY

* 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 7,500 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.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

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