;

17-0109 Monday “The Daily Bugle”

17-0109 Monday “Daily Bugle”

Monday, 9 January 2017

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 Form ATF F 7(5310.12)/7 CR (5310.16), Application for Federal Firearms License 
  2. DHS/CBP Modifies and Clarifies NCAP Tests Regarding Post-Summary Corrections and Periodic Monthly Statements 
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. State/DDTC Announces USML Category XV Final Rule, effective January 15, 2017 
  4. UK/BIS ECO Posts Guidance on Using SPIRE Online Export Licensing 
  1. Reuters: “U.N. Chief Concerned Iran May Have Violated Arms Embargo: Report” 
  2. ST&R Trade Report: “Jan 14 ACE Transition Will Not Include ISF, Automated Surety Interface” 
  3. ST&R Trade Report: “Post-Summary Correction Test Modified to Ease Burden on Importers” 
  4. Washington Post: “U.S. Used Cold War-Era Statute to Prosecute Taiwanese American Nuclear Engineer” 
  1. M. O’Kane: “Jack Lew Memo on U.S. Sanctions Policy” 
  2. Gary Stanley’s ECR Tip of the Day 
  1. Monday List of Ex/Im Job Openings: 106 Jobs Posted 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (20 Dec 2016), DOD/NISPOM (18 May 2016), EAR (4 Jan 2017), FACR/OFAC (23 Dec 2016), FTR (15 May 2015), HTSUS (1 Jan 2017), ITAR (3 Jan 2017) 

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. Justice/ATF Seeks Comments on Form ATF F 7(5310.12)/7 CR (5310.16), Application for Federal Firearms License

(Source: Federal Register) [Excerpts.]
 
82 FR 2394-2395: Agency Information Collection Activities; Proposed eCollection eComments Requested; Application for Federal Firearms License (ATF F 7(5310.12)/7 CR (5310.16))
* AGENCY: Bureau of Alcohol, Tobacco, Firearms and Explosives, Department of Justice.
* ACTION: 30-Day notice. …
* DATES: Comments are encouraged and will be accepted for an additional 30 days until February 8, 2017.
* FOR FURTHER INFORMATION CONTACT: Tracey Robertson, Chief, Federal Firearms Licensing Center, either by mail at 244 Needy Road, Martinsburg, WV 25405, or by email at tracey.robertson@atf.gov. Written comments and/or suggestions can also be directed to the Office of Management and Budget, Office of Information and Regulatory Affairs, Attention: Department of Justice Desk Officer, Washington, DC 20503 or sent to OIRA_submissions@omb.eop.gov.
* SUPPLEMENTARY INFORMATION: …
  – The Title of the Form/Collection: Application for Federal
Firearms License.
  – Form number: ATF F 7(5310.12)/7 CR (5310.16).
  – Component: Bureau of Alcohol, Tobacco, Firearms and Explosives, U.S. Department of Justice.
  – Abstract: The law of 18 U.S.C. Section 923(a)(1), requires a person wishing to transport, ship, or receive firearms in interstate or foreign commerce to pay a fee, to file an application and to obtain a license before engaging in business. ATF F 5310.12/7 CR 5310.16 will be for the purpose of ensuring this collection of information is necessary to ensure that the person who wishes to be licensed as required by Section 923 meets the requirements of the section for the license. Additionally, this form will be used by the public when applying for a Federal firearms license to collect curios and relics to facilitate a personal collection in interstate and foreign commerce. The information requested on the form establishes eligibility for all license types. …
 
  Dated: January 4, 2017.
Melody Braswell, Department Clearance Officer for PRA, U.S. Department of Justice.

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

EXIM_a2

2. DHS/CBP Modifies and Clarifies NCAP Tests Regarding Post-Summary Corrections and Periodic Monthly Statements

(Source: Federal Register) [Excerpts.]
 
82 FR 2385-2389: Modification and Clarification of the National Customs Automation Program Tests Regarding Post-Summary Corrections and Periodic Monthly Statements; Republication With Correction and Further Clarification
* AGENCY: U.S. Customs and Border Protection, Department of Homeland Security.
* ACTION: General notice; republication with correction and further clarification.
* SUMMARY: On December 12, 2016, U.S. Customs and Border Protection (CBP) published in the Federal Register a document announcing CBP’s plans to modify and clarify the National Customs Automation Program (NCAP) test regarding Post-Summary Correction (PSC) claims to entry summaries that are filed in the Automated Commercial Environment (ACE), as well as the Periodic Monthly Statement (PMS) test. The notice liberalized and eliminated some requirements needed for the filing of PSCs; however, it also placed burdens on the importer in the form of a restriction and a prohibition.
   Subsequently, CBP decided to remove the restriction imposed on all PSC filings to make payments within three business days of submitting the PSC, with the exception of entry type 03 filings, and to remove the prohibition of filing additional PSCs until additional duties, fees and taxes are deposited. This document republishes and supersedes the document published on December 12 with these corrections and clarifications. Except to the extent expressly announced or modified by this document, all aspects, rules, terms and conditions announced in notices previous to this notice and the December 12 publication regarding the tests remain in effect.
* DATES: The changes made by this notice are effective January 14, 2017.
* ADDRESSES: Comments concerning these test programs may be submitted via email to Monica Crockett at ESARinfoinbox@dhs.gov with a subject line identifier reading, “Post-Summary Corrections and Periodic Monthly Statements.”
* FOR FURTHER INFORMATION CONTACT: For policy-related questions, contact Randy Mitchell, Director, Commercial Operations, Trade Policy and Programs, Office of Trade, at Randy.Mitchell@cbp.dhs.gov. For technical questions related to ABI transmissions, contact your assigned client representative. Interested parties without an assigned client representative should direct their questions to the Client Representative Branch at (703) 650-3500.
* SUPPLEMENTARY INFORMATION: …
 
Expansion of Entry Types
   This document announces that CBP is expanding the type of entries that may be corrected by filing a PSC, in addition to the current entry types 01 (Consumption–Free and Dutiable) and 03 (Consumption–Antidumping/Countervailing Duty). The additional entry types are as follows: …
 
Merchandise Subject to Quota
   When filing a PSC for an entry of merchandise subject to quota, the date and time of submission will be considered the date and time of presentation of the merchandise to CBP. If a PSC is filed on an entry with merchandise subject to quota, and the quota is full or nearly full at threshold, the PSC filer must do two things. The filer must follow the Entry Summary Business Rules and Process Document on www.CBP.gov and also, within 24 hours of making the correction, contact Headquarters Quota Branch, either by phone: (202) 863-6560 (public phone number), or email: HQQuota@cbp.dhs.gov, regardless of whether the correction concerns merchandise subject to quota.
 
Deposit of Duties, Fees and Taxes With PSC Showing Increase in Liability
   This document announces that when a PSC is filed declaring an increase in the importer’s liability for antidumping or countervailing duties and associated fees and taxes, the importer must mail or deliver a check to the CBP port of entry with those additional antidumping or countervailing duties and associated fees and taxes within three business days of submitting the PSC. Furthermore, CBP will no longer reject a PSC declaring an increase in liability for antidumping or countervailing duties and associated fees and taxes when the additional duties, fees and taxes are not deposited at the time of submitting the PSC. This is a change in CBP policy. …
 
Change of Entry Type When Antidumping and/or Countervailing Duties Are Involved
   Previously, a filer under the PSC test could not change a type 03 entry to a type 01 entry. See 76 FR 37136. This document announces that a PSC may declare that a previously filed entry which stated that merchandise covered by that entry was subject to antidumping and/or countervailing duties is not, in fact, subject to such duties. For instance, a PSC may declare that a previously filed 03 entry type is corrected to indicate it is a 01 entry type.
 
No Filing of PSC To Make a Post-Importation Claim under 19 U.S.C. 1520(d)
   On June 24, 2011, CBP announced in the Federal Register (76 FR
37136) that one of the data elements that may not be modified via a PSC is the NAFTA indicator. This notice clarifies that such prohibition applies not only to a post-importation NAFTA claim under 19 U.S.C. 1520(d), but also to a claim made under other free trade agreements covered by 19 U.S.C. 1520(d).
 
PSC Submission Within the Time Limitations Authorized by This Test
   On November 19, 2013, CBP published a notice in the Federal Register (78 FR 69434) that stated that a PSC cannot be filed when any merchandise covered by the original entry has been conditionally released and its right to admission has not been determined. This restriction was overly broad and prevented importers from filing a PSC because all goods are conditionally released and their admissibility is not legally determined until liquidation. This notice announces that this restriction does not prevent the filing of a PSC within the time periods allowed as long as all other requirements and limitations are met. The time limits authorized by this test are set forth in notices published in the Federal Register on June 24, 2011 (76 FR 37136) and November 19, 2013 (78 FR 69434). This clarification is in line with current practice.
 
Modification to the PMS Test
   This notice announces that CBP will consider a PMS as paid, in the event the importer uses the Automated Clearing House (ACH) debit process, when CBP receives confirmation from the Treasury Department that funds are available and transferred to CBP from the financial institution designated by the importer for payment of the ACH debit authorization. Prior to this modification, CBP considered a PMS as paid when CBP transmitted the debit authorization to the designated financial institution. See 69 FR 5362 (February 4, 2004). This change will result in a delay of approximately two working days in the time that CBP uses to consider a PMS as paid. It is important to note that this modification applies only to importers who participate in the test program. For all other importers, the current regulation, 19 CFR 24.25(c)(4), still applies which means CBP will consider a statement as paid upon acceptance of the ACH debit authorization.
 
   Dated: January 4, 2017.
Brenda B. Smith, Executive Assistant Commissioner, Office of Trade.

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

OGSOTHER GOVERNMENT SOURCES

OGS_a13. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)


* Commerce; Industry and Security Bureau; RULES; Certain Persons and Modification of Certain Entries to the Entity List; Additions and Removals [Publication Date: 10 January 2017.]

* Commerce; Industry and Security Bureau; RULES; Export Administration Regulations: Control of Spacecraft Systems and Related Items the President Determines No Longer Warrant Control under the United States Munitions List [Publication Date: 10 January 2017.]

* State; RULES; International Traffic in Arms Regulations: Revision of U.S. Munitions List Category XV [Publication Date: 10 January 2017.]

* State; NOTICES; Designations as Global Terrorists [Publication Date: 10 January 2017.]
  – Hamza bin Laden
  – Ibrahim al-Banna, aka Shaykh Ibrahim Muhammad Salih al-Banna, aka Ibrahim Muhammad Salih al-Banna, aka Ibrahim Muhamad Salih al-Banna, aka Abu Ayman al-Masri 

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

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

 
The Directorate of Defense Trade Controls expects to publish a Final Rule in the Federal Register revising USML Category XV soon [Editor’s Note: The item will be published in tomorrow’s Federal Register.]. The rule is titled Amendment to the International Traffic in Arms Regulations: Revision of U.S. Munitions List Category XV, Public Notice 9688. Once published in the Federal Register, DDTC anticipates this Final Rule will be effective on January 15, 2017. An unofficial copy of the final rule is available here. Please consult the Federal Register for an official copy of the final rule, including its effective date.

Click here for a web notice regarding the Department of Commerce signed final rule that was also delivered to the Federal Register for publication, Revisions to the Export Administration Regulations (EAR): Control of Spacecraft Systems and Related Items the President Determines No Longer Warrant Control under the United States Munitions List (USML), RIN 0694-AG59.  

[Editor’s Note: The amendment of USML Category XV, to be published in tomorrow’s Federal Register, will contained in a revised version of the BITAR, to be sent to all BITAR subscribers by email.  To subscribe, see item #15, below.]

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

OGS_a46. UK/BIS ECO Posts Guidance on Using SPIRE Online Export Licensing

(Source: UK/BIS ECO)   
 
The UK Export Control Organization has posted guidance on using SPIRE, the Export Control Organization’s export licensing system.
 
The guidance includes details on the various types of license available, and the conditions for using them.
 
The SPIRE guidance is available at here.

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

NWSNEWS

NWS_a17
. Reuters: “U.N. Chief Concerned Iran May Have Violated Arms Embargo: Report”

 
The United Nations chief expressed concern to the Security Council that Iran may have violated an arms embargo by supplying weapons and missiles to Lebanese Shi’ite group Hezbollah, according to a confidential report, seen by Reuters on Sunday.
 
The second bi-annual report, due to be discussed by the 15-member council on Jan. 18, also cites an accusation by France that an arms shipment seized in the northern Indian Ocean in March was from Iran and likely bound for Somalia or Yemen.
 
Most U.N. sanctions were lifted a year ago under a deal Iran made with Britain, France, Germany, China, Russia, the United States and the European Union to curb its nuclear program. But Iran is still subject to an arms embargo and other restrictions, which are not technically part of the nuclear agreement.
 
The report was submitted to the Security Council on Dec. 30 by U.N. Secretary-General Ban Ki-moon before he was succeeded by Antonio Guterres on Jan. 1. It comes just weeks before U.S. President-elect Donald Trump, who has threatened to either scrap the nuclear agreement or seek a better deal, takes office.
 
  “In a televised speech broadcast by Al Manar TV on 24 June 2016, Hassan Nasrallah, the Secretary-General of Hezbollah, stated that the budget of Hezbollah, its salaries, expenses, weapons and missiles all came from the Islamic Republic of Iran,” Ban wrote in the report.
 
  “I am very concerned by this statement, which suggests that transfers of arms and related materiel from the Islamic Republic of Iran to Hezbollah may have been undertaken contrary (to a Security Council resolution),” Ban said.
 
When asked by the United Nations to clarify the issue, Iran’s mission to the United Nations said “measures undertaken by the Islamic Republic of Iran in combating terrorism and violent extremism in the region have been consistent with its national security interests and international commitments.”
 
Under a Security Council resolution enshrining the deal, which came into effect a year ago, the U.N. secretary-general is required to report every six months to the council on any violations of sanctions still in place.
 
  “Since 16 January 2016, I have not received any report on the supply, sale, transfer or export to the Islamic Republic of Iran of nuclear-related items undertaken contrary to the (resolution),” Ban wrote.
 
In Ban’s first report in July he said ballistic missile launches carried out by Iran in March were “not consistent with the constructive spirit” of a nuclear deal, but it is up to the council to decide if they violated the resolution.

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

NWS_a3
8. ST&R Trade Report: “Jan 14 ACE Transition Will Not Include ISF, Automated Surety Interface”

 
U.S. Customs and Border Protection announced Jan. 6 that importer security filings will not be transitioned to the Automated Commercial Environment, and the full Automated Surety Interface will not be deployed, on Jan. 14 as previously scheduled. CBP states that it will issue further notification on the ISF deployment date in the near future and that an interim solution developed with sureties will be in place until ASI is deployed in full at a later date.
 
CBP is still planning to deploy drawback, duty deferral, reconciliation, liquidation, collections, and statements in ACE as of Jan. 14. CBP states that it will begin the migration of legacy data to ACE at 5:00 p.m. EST on Jan. 13, at which point filers will no longer be able to add or replace reconciliation, drawback, or duty deferral transactions in the Automated Commercial System. If updates are required to reconciliation, drawback, or duty deferral transactions filed in ACS prior to this cutover, filers will need to work with the ports or Centers of Excellence and Expertise as appropriate.
 
CBP will have an extended ACE outage period for this deployment beginning at 10:00 p.m. EST on Jan. 14 and targeted to conclude at 8:00 a.m. EST on Jan. 15. This outage will affect all ACE applications, including manifest and cargo release.
 
CBP plans to disseminate an update on the cutover timeframe specific to statements during the week of Jan. 9.

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

NWS_a4
9. ST&R Trade Report: “Post-Summary Correction Test Modified to Ease Burden on Importers”

 
Post-Summary Correction Test Modified to Ease Burden on Importers
 
U.S. Customs and Border Protection is lifting a restriction and a prohibition on the use of post-summary corrections that CBP said “placed burdens on the importer.”
 
Under the PSC test, importers may use the Automated Broker Interface to file PSC claims to entry summaries filed in the Automated Commercial Environment. Importers and their brokers may also use ABI to file PSCs to those pre-liquidation ACE entry summaries that are accepted by CBP, fully paid, and under CBP control. In a Dec. 12, 2016, notice CBP expanded the type of entries that may be corrected by filing a PSC and made a number of other changes to the test as well. Among other things, CBP stated that if a PSC is filed that increases the importer’s liability for duties, fees, or taxes, the importer must deposit those amounts within three business days of submitting the PSC and no additional PSCs may be filed until this is done.
 
CBP is now limiting the three-day payment requirement to PSC filings declaring an increase of liability for antidumping or countervailing duties and associated fees and taxes, thus alleviating this requirement for all other PSC filings. CBP is also removing the prohibition on filing additional PSCs until the duties, fees, and taxes are deposited. Further, CBP is providing the correct point of contact for making a deposit, clarifying the method and location of payment, and clarifying how it will determine the time of payment.

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

NWS_a2
10. Washington Post: “U.S. Used Cold War-Era Statute to Prosecute Taiwanese American Nuclear Engineer”
(Source: Washington Post) [Excerpts.]
 
A Taiwanese American nuclear engineer pleaded guilty Friday to one count of conspiring to produce “special nuclear material,” in this case plutonium, outside the United States without a license from the secretary of energy.
 
The prosecution of Szuhsiung “Allen” Ho and a colleague marks the first time the Justice ­Department has brought cases under a 1946 Cold War-era proliferation statute.
 
As part of the plea agreement, prosecutors will drop charges that Ho, who owns a consulting business in the field of commercial nuclear energy, intended to illegally help China and that he acted as a foreign agent. That means Ho, 66 and a naturalized citizen born in Taiwan, no longer faces a potential life sentence but a maximum of 10 years in prison.
 
Nuclear energy experts say they are baffled that the government pursued the case at all. They say that the government is taking an old statute meant to discourage the spread of nuclear weapons and is applying it to an export licensing matter involving commercial reactor technology used around the world – activity that had nothing to do with bombmaking.
 
  “To make this a case about getting plutonium for bombs is a wild overstretch, and a pretty astonishing display of ­Department of Energy and State Department hypocrisy,” said ­Victor Gilinsky, a physicist and independent consultant who served two terms on the Nuclear Regulatory Commission. “We urge everybody to build reactors, and we sell reactors. All ­uranium-fueled reactors make plutonium – even commercial reactors. So if Ho is engaged in a conspiracy to produce ­bomb-usable plutonium in ­China, his co-conspirators are DOE and State – and the White House.”
 
But the government insists that Ho endangered national ­security.
 
  “It’s a very serious case no matter how insignificant the defense may allude to the technology involved here,” said Charles E. Atchley Jr., an assistant U.S. attorney in the Eastern District of Tennessee, in a June hearing. “The defendant in this case is charged with procuring and helping to obtain on behalf of the Chinese government technology that it is not allowed to have.”
 
Ho’s case follows several prosecutions of Chinese American scientists who were accused of sharing U.S. technology secrets with China, but whose cases collapsed. Two of those cases, involving a Temple University professor and a National ­Weather Service hydrologist, were handled by defense ­attorney Peter Zeidenberg, who is also ­representing Ho.
 
Ho was accused of violating a provision of the Atomic Energy Act by helping the state-owned China General Nuclear Power Group, formerly known as the China Guangdong Nuclear Power Company (CGNPC), more quickly design and make components for nuclear reactors. Prosecutors in Knoxville say he paid a colleague, Ching Ning Guey, who worked at the Tennessee Valley Authority, to travel to China in 2013 at the power company’s request to provide nuclear consulting. They allege that Ho encouraged Guey to share reports on nuclear power generation that he got through his work at TVA.
 
Ho’s assistance to the ­company focused on advanced fuel assembly research and the validation of nuclear ­reactor-related computer codes, among other things – all of which he did without a license, the government says.
 
Attorney General Loretta E. Lynch signed off on Ho’s ­prosecution, as required by the statute.
 
Guey in 2015 pleaded guilty to one count of producing special nuclear material overseas ­without a license – the same charge Ho pleaded guilty to. The government agreed not to bring other charges against Guey in return for his cooperation against Ho. Guey, who unlike Ho was not jailed pending trial, has not yet been sentenced.
 
The Energy Department has certified that the technology that Ho shared is illegal to export to China without special ­authorization, according to the plea agreement.
 
  “I think that fundamentally this is more about theft of trade secrets than national security,” said Edwin Lyman, a nuclear proliferation expert at the Union of Concerned Scientists. “It does appear that there was some transfer of proprietary ­information,” he said after ­reading the indictment. But, ­Lyman said, “my sense is that the U.S. government is trying to make an example out of Ho by escalating the seriousness of the alleged offenses.”
 
Jonathan Poling, a former ­federal prosecutor who handled export control cases, said it is difficult to say whether Ho’s case is entirely commercial in nature or whether there were national security issues linked to entities or acts not discussed in the indictment. He said that “could be precisely why the government charged the case,” to protect the Energy Department’s and ­national security agencies’ “ability to make this assessment from the outset.”
 
China, which tested its first nuclear bomb in 1964, has about 260 warheads and the material to make more. Its main priority has been expanding its commercial nuclear power, with about two dozen reactors under construction. The Obama administration, with the passive approval of Congress, renewed a nuclear cooperation agreement that does not prohibit China from buying reprocessing technology that would help it produce weapons-grade plutonium from spent nuclear power plant fuel of U.S. origin.
 
Ho, who used to work for Westinghouse Electric Co., argued that he went to China not to produce plutonium to make a bomb but rather to help commercial nuclear power plants operate safely.
 
He has said that he sought guidance on whether he needed a license from the Energy Department and received equivocal responses. He said he was told that a license was not needed for his information technology work, but that he might need one for consulting on safety-related issues. He applied for a license for the latter, but months went by without a response. During that time he continued to consult, under the apparent belief that he was permitted to do so, according to the court record.  …
* * * * * * * * * * * * * * * * * * * *

COMMCOMMENTARY

COMM_a1
11. M. O’Kane: “Jack Lew Memo on U.S. Sanctions Policy”

 
* Author: Michael O’Kane, Esq., Peters & Peters Solicitors LLP, mokane@petersandpeters.com, +44 (0) 20 7822 7777.
 
U.S. Treasury Secretary Jack Lew has published a departure memorandum (link here) commenting on the work of the U.S. Treasury over the previous 8 years. He notes the success of sanctions on Iran, in cutting off terrorist groups from financing, and imposing pressure on Iran & North Korea. “All the while, we have worked to craft a cohesive vision for the use of sanctions, in which sanctions are informed by financial intelligence, strategically designed, and implemented with our public and private partners to focus pressure on bad actors and create clear incentives to end malign behaviour, while limiting collateral impact.” The memo says the US should continue to use sanctions “judiciously” and adapt to changed relationships (eg with Cuba).
 
He repeats the caution he gave in March last year (see previous blog) that the U.S. should be careful not to overuse sanctions, “particularly our most unilateral tools like secondary sanctions that extend to non-U.S. persons. If we overuse these powerful tools, we risk lessening their impact when they are most needed and ultimately threaten our central role in the global financial system.”

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

COMM_a2
12. 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
NLR (“no license required”) is a symbol entered on the Electronic Export Information filing on the Automated Export System certifying that no license is required. Just because no license is required for the export of an item to a particular end-user for a particular end-use does not mean that it is not subject to U.S. export and re-export controls.

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

MSEX/IM MOVERS & SHAKERS

MS_a113. Monday List of Ex/Im Job Openings: 106 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:
 
* Aerospace Industries Association; Arlington VA;
International Affairs Director
;
Remy.Nathan@aia-aerospace.org
* Amazon; London, UK;
Senior Trade Compliance Program Manager (M/F)
; Requisition ID: 429019

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

* Amazon; Seattle WA;
Compliance Investigator
; Requisition ID: 432564

* Amazon; Seattle WA;
Sanctions Compliance Specialist
; Requisition ID: 467576
* Amazon; Seattle WA;
NA Compliance Analyst
; Requisition ID: 256357
* Amazon; Seattle WA;
Prime Air Trade Compliance Program Manager
; Requisition ID: 395658
* Amazon; Seattle WA;
Senior Compliance Audit Specialist
; Requisition ID: 473466
* Amazon; Seattle WA;
Sr. Trade Compliance PM, Fashion
; Requisition ID: 475927
* Amazon; Singapore;
Sr. Trade Compliance Manager
; Requisition ID: 441734
* Amazon; Tokyo, Japan;
JP Export Compliance Manager
; Requisition ID: 464733
* Apple; Singapore;
APAC Trade Compliance Analyst / Manager
; Requisition ID: 52327703
* AstraZeneca; Wilmington DE;
Sr. Import Analyst
; Requisition ID: R-001528
* Avigilon; Plano, TX;
Global Trade Compliance Manager
; Requisition ID: 2016-2551

# Bank of America; London, UK;
Trade Control Analyst
; Requisition ID: 16046883

* Bayer; Leverkusen, Germany;
Head of Customs & International Trade Classification (m/f)
; Requisition ID: 0000180456

# Boeing; Cape Canaveral FL;
Trade Control Specialist
; Requisition ID: 1700000067

* Boeing; Englewood CO;
Intern – International Trade Regulations
; Requisition ID: 794168

* Boeing; Gdansk, Poland;
Compliance Specialist
; Requisition ID: 795762
* Boeing; Mesa AZ;
Trade Control Specialist
; Requisition ID: 1600021767

# Choice Logistics; New York NY;
Manager, Global Trade Operations

* Ciena; Hanover MD;
Global Logistics Cost Leader
; Requisition ID: R005158

*
Cobham Advanced Electronic Solutions; Exeter NH, Plainview, NY; Eatontown, NJ; and Lansdale, PA;
Export Compliance Manager
; Craig Beronja,
craig.beronja@cobham.com
; Requisition ID: 00LR5
* Colony Brands, Inc.; Monroe WI;
Assistant Trade Compliance Manager
; Requisition ID: 16-0954
* Crane Aerospace and Electronics; Chandler AZ;
Sr. Export Compliance Analyst
; Requisition ID: 4725
* Crane Currency; Nashua NH;
Import/Export & Logistics Manager
; Requisition ID: 2016-1459
* Crane Aerospace and Electronics, West Caldwell NJ;
Export Compliance Manager
; Requisition ID: 5411
* Cummins Inc.; Daventry, United Kingdom;
Lead Export Controls Analyst
* Diageo; Norwalk CT;
Trade Compliance Excellence Manager
; Requisition ID: 54069BR
* DRS Technologies; Germantown MD;
Senior Trade Compliance Manager
; Requisition ID: 54749

# Eaton; Titchfield, UK;
Global Trade Manager (Trade Compliance)
; Requisition ID: 020681

* ED & F Man; London, UK;
Trade Support Specialist

* Edgewell Personal Care; Milford CT; 
Export Compliance And Security Lead
; Requisition ID: NAM00808
* Emerson; Cluj, Romania;
International Trade Compliance Assistant
; Requisition ID: 16006899
* Esterline Technologies Corporation; Bellevue WA;
Audit Manager – Compliance
; Requisition ID: 8215BR
* Esterline Technologies Corporation; Bellevue WA;
Sr. Trade Compliance Manager – Sensors & Systems (Engineering)
; Requisition ID: 8791BR
* Esterline Technologies Corporation; Brea, CA;
Logistics Coordinator
; Requisition ID:
8887BR
* Esterline Technologies Corporation; Brea CA;
Sr. Trade Compliance Manager;
Requisition ID: 7333BR
* Esterline Technologies Corporation; Buena Park, CA;
Manager, Shipping and Inventory Control
; Requisition ID:
9046BR

# Esterline Technologies Corporation; Frankenmuth MI;
Trade Compliance & Contracts Administrator
; Requisition ID: 9307BR

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

# Expeditors; Manila, The Philippines;
Regional Trade Compliance Manager – Indochina & Philippines

* Export Solutions Inc.; Melbourne FL; 
Trade Compliance Specialist II

info@exportsolutionsinc.com

* Facebook; Menlo Park CA;
Head of Global Trade Compliance Operations

* Facebook; Singapore;
Export Compliance Manager, APAC 

* FLIR; Arlington VA;
Sr. Defense Trade Licensing & Compliance Analyst
; Requisition ID: 7924
*
FLIR; Billerica MA; 
Sr. Defense Trade Licensing & Compliance Analyst
;
Requisition ID: 8008
* General Dynamics; South Wales, UK;
Senior Trade Compliance Officer
; Requisition ID: 6079
* Givaudan; Bogor, Indonesia;
Compliance Manager
; Requisition ID: 68063
* Google; San Francisco CA;
Associate Counsel, Customs Compliance
* Honeywell; Moscow, Russia;
Integrity & Compliance Manager
; Requisition ID: 00330983

# Illumina; San Diego CA;
Senior Analyst, Trade Compliance
; Requisition ID: 6294BR

*
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
* Intel; Santa Clara, CA;
Export Compliance Specialist
; Requisition ID: JR0005160
* Lam Research Corporation; Fremont CA:
Foreign Trade Analyst 6
; Requisition ID: 12079BR
* Linde; Stewartsville NJ;
Compliance Administrator
; Requisition ID: 916130

# Lumber Liquidators; Toano VA;
Intern, Compliance
; Requisition ID: 2227

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

* Lutron; Coopersburg PA;
Trade Compliance Coordinator
; Requisition ID: 2834
* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst
; 16000DYY
* Meggitt Control Systems; North Hollywood CA;
Trade Compliance Officer
;
jenn.avritt@meggitt.com
; Requisition ID: 23720

# Meggitt PLC; Coventry, UK;
Trade Compliance Administrator
; Requisition ID: 24392
# Meggitt PLC; Erdington-Birmingham, UK;
Trade Compliance Officer & HR Administrator
; Requisition ID: 24656

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

* Meggit PLC; Los Angeles CA;
Trade Compliance Officer
* Merck KGaA; South West England, UK;
Trade Compliance Specialist
; Requisition ID: 153405
* Moog; East Aurora NY;
Export Compliance Manager
;
anihill@moog.com
; Requisition ID: 161913
* Northrop Grumman Corporation; Annapolis Junction MD;
International Trade Compliance Analyst 4
; Requisition ID: 16028623
* Northrop Grumman Corporation; Falls Church VA;
International Trade Compliance Analyst 3/4
; Requisition ID: 16026961
* Northrop Grumman Corporation; Falls Church VA;
International Trade Compliance Analyst 3/4
; Requisition ID: 16027133
* Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 1
; Requisition ID: 16028160
* Northrop Grumman Corporation; Redondo Beach CA;
International Trade Compliance Analyst 4
; Requisition ID: 16024309
* Northrop Grumman Sperry Marine; New Malden, UK;
Trade Compliance Coordinator
; Apply via
careers.uk@sperry.ngc.com
* NXP Semiconductors; Nijmegen, The Netherlands;
Export Control Officer, Requirements Manager
; R-10001504
* Pall Corporation; Portsmouth, UK;
Trade Compliance Specialist
; Requisition ID: SHA000201
* Parexel; Buenos Aires, Argentina;
Trade Compliance Specialist
; Requisition ID: pare-10055899
* Questrade; Toronto ON, Canada;
Compliance Analyst, Trade Conduct Compliance
; Requisition ID: 724
* Raytheon; Arlington VA;
Export Licensing Manager I
; Requisition ID: 87321BR
* Raytheon; Cambridge MA;
Export Compliance Agreement Owner
; Requisition ID: 87607BR
* Raytheon; El Segundo CA or McKinney TX;
Sr. Manager, Global Trade
; Requisition ID: 90829BR
* Raytheon; Fullerton CA;
Global Trade Compliance Manager
; Requisition ID: 85521BR
* Raytheon; Indianapolis IN;
Principal SC Compliance Specialist
; Requisition ID: 84932BR
* Smith and Wesson; Springfield MA;
International Sales Administrator
; Requisition ID: SCB-1223
* State Department; Wash DC;
Supervisory Compliance Specialist
; Requisition ID: HRSC/T/PM-2017-0003
* Tenneco; Edenkoben, Germany;
Global Trade Compliance Manager (m/w)
; Requisition ID: 176871-846
* Tesla Motors; Fremont CA;
International Tax Lead/Senior International Tax Counsel
; Requisition ID: 35593
* Tesla Motors; Fremont CA;
Global Trade Compliance Manager
; Requisition ID: 40738
* Tesla Motors; Fremont CA;
Global Supply Manager – Logistics
; Requisition ID: 38153
* Tesla Motors; Fremont CA;
Group Manager – Logistics Sourcing
; Requisition ID: 38574
* Textron Systems; Wilmington MA;
Principal Export Compliance Analyst
; Requisition ID: 242857
* ThermoFisher Scientific; Madison WI;
Import/Export Compliance Coordinator
; Requisition ID: 41440BR
* 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;
Trade Compliance Specialist
; Requisition ID: 42144BR

# ThermoFisher Scientific; Shanghai, China;
Trade Compliance Specialist
; Requisition ID: 42875BR

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

* Tractor Supply Company; Brentwood TN;
Customs Process Manager
;
nknott@tractorsupply.com
; Requisition ID: 16-986
* Troy Corporation; Florham Park NJ;
Global Trade and Compliance Manager
; Requisition ID: 306
* XPO Logistics; Greenwich CT;
Global Trade Compliance Analyst
* * * * * * * * * * * * * * * * * * * *

ENEDITOR’S NOTES

(Source: Editor) 

 
*
Lady Randolph Churchill (Jeanette, Lady Randolph Churchill, née Jerome, 9 Jan 1854 – 29 Jun 1921, was an American-born British socialite, the wife of Lord Randolph Churchill and the mother of British Prime Minister Sir Winston Churchill.)

  – “Treat your friends as you do your best pictures, and place them in their best light.”

  – “We owe something to extravagance, for thrift and adventure seldom go hand in hand.”

 

*
Baltasar Gracian (Baltasar Gracián y Morales, SJ, 8 Jan 1601 – 6 Dec 1658, was a Spanish Jesuit and baroque prose writer and philosopher. His writings were lauded by Schopenhauer and Nietzsche.)

  – “Never open the door to a lesser evil, for other and greater ones invariably slink in after it.”

 

Monday is Pun Day.

Q. What do they call the annual butcher’s union dinner-dance?

A. The Meatball! 

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

EN_a315
. 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: 20 Dec 2016: 81 FR 92978-93027: Regulatory Implementation of the Centers of Excellence and Expertise 

* 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: 4 Jan 2017: 82 FR 722-725: Addition of Certain Entities to the Entity List 

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 23 Dec 2016: 81 FR 94254-94259: Iranian Transactions and Sanctions 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 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: 1 Jan 2017: 2017 Basic HTS 
  – 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.
  – Latest Amendment: 3 Jan 2017 (effective 31 Dec 2016): 82 FR 15-19: International Traffic in Arms Regulations: International Trade Data System, Reporting
  – The only available fully updated copy (latest edition 3 Jan 2017) 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, 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.  (Tomorrow’s ITAR amendment will be contained in a revised edition of the BITAR.)  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 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.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

Scroll to Top