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17-0213 Monday “The Daily Bugle”

17-0213 Monday “Daily Bugle”

Monday, 13 February 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. DHS/CBP Seeks Comments on Commercial Invoice 
  2. DHS/CBP Seeks Comments on Forms 7512 & 7512A, Transportation Entry and Manifest of Goods Subject to CBP Inspection and Permit 
  3. State: Defense Trade Advisory Group to Meet on 30 Mar in Wash DC 
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS Posts Updated Export Compliance Guidelines 
  3. Commerce/Census: “Harmonized Tariff Schedule Updated in the Automated Export System” 
  4. DoD/DSCA Posts SAMM and Policy Memoranda, Week 12-18 Feb 
  5. DoD/DSS Clarifies Submission of Top Secret Periodic Reinvestigations 
  6. DoD/DSS Announces Personnel Security Inquiries to Be Closed on 17 Feb and 20 Feb 
  7. State/DDTC Posts Reminder Concerning DECCS Batch Licensing Application Submission Release v2.0 
  1. Expeditors News: “CBP Releases Harmonized System Update 1701” 
  1. D.M. Edelman: “Another Reason To Always Run Compliance Screenings Even If You Are A Non-U.S. Party – OFAC Is Targeting Foreign Companies” 
  2. Gary Stanley’s ECR Tip of the Day 
  1. “16th Annual ‘Partnering for Compliance™’ East ECR/Export/Import Control Program” on 7-10 Mar in Orlando FL 
  2. ECS Presents ITAR/EAR Critical Compliance on 28-29 Mar in Scottsdale AZ 
  1. Monday List of Ex/Im Job Openings: 119 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 (1 Feb 2017), FACR/OFAC (10 Feb 2017), FTR (15 May 2015), HTSUS (10 Feb 2017), ITAR (11 Jan 2017) 

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. DHS/CBP Seeks Comments on Commercial Invoice


(Source: Federal Register) [Excerpts.]
 
82 FR 10495-10496: Agency Information Collection Activities: Commercial Invoice
* AGENCY: U.S. Customs and Border Protection, Department of Homeland Security.
* ACTION: 60-Day notice and request for comments; extension of an existing collection of information. …
* DATES: Written comments should be received on or before April 14, 2017 to be assured of consideration.
* ADDRESSES: All submissions received must include the OMB Control Number 1651-0090 in the subject line and the agency name. To avoid duplicate submissions, please use only one of the following methods to submit comments:
  (1) Email. Submit comments to: (CBP_PRA@cbp.dhs.gov). The email should include the OMB Control number in the subject line.
  (2) Mail. Submit written comments to CBP PRA Officer, U.S. Customs and Border Protection, Office of Trade, Regulations and Rulings, Economic Impact Analysis Branch, 10th Floor, 90 K St NE., Washington, DC 20229-1177.
* FOR FURTHER INFORMATION CONTACT: Requests for additional PRA information should be directed to Paperwork Reduction Act Officer, U.S. Customs and Border Protection, Regulations and Rulings, Office of Trade, 90 K Street NE., 10th Floor, Washington, DC 20229-1177, or via email (CBP_PRA@cbp.dhs.gov). Please note that the contact information provided here is solely for questions regarding this notice. Individuals seeking information about other CBP programs should contact the CBP National Customer Service Center at 877-227-5511, (TTY) 1-800-877-8339, or CBP Web site. For additional help.
* SUPPLEMENTARY INFORMATION: …
  – Title: Commercial Invoice.
  – OMB Number: 1651-0090.
  – Form Number: None.
  – Abstract: The collection of the commercial invoice is necessary for conducting adequate examination of merchandise and determination of the duties due on imported merchandise as required by 19 CFR 141.81, 141.82, 141.83, 141.84, 141.85, 141.86, 141.87, 141.88, 141.89, 141.90, 141.91, 141.92 and by 19 U.S.C. 1481 and 1484. The commercial invoice is provided to CBP by the importer. The information is used to ascertain the proper tariff classification and valuation of imported merchandise, as required by the Tariff Act of 1930. To facilitate trade, CBP did not develop a specific form for this information collection. Importers are allowed to use their existing invoices to comply with these regulations.
  – Current Actions: This submission is being made to extend the
expiration date with no change to the burden hours. …
 
   Dated: February 8, 2017.
Seth Renkema, Branch Chief, Economic Impact Analysis Branch, U.S. Customs and Border Protection.

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

EXIM_a2

2. DHS/CBP Seeks Comments on Forms 7512 & 7512A, Transportation Entry and Manifest of Goods Subject to CBP Inspection and Permit


(Source: Federal Register) [Excerpts.]
 
82 FR 10496-10497: Agency Information Collection Activities: Transportation Entry and Manifest of Goods Subject to CBP Inspection and Permit
* AGENCY: U.S. Customs and Border Protection, Department of Homeland Security.
* ACTION: 60-Day notice and request for comments; extension of an existing collection of information. …
* DATES: Written comments should be received on or before April 14, 2017 to be assured of consideration.
* ADDRESSES: All submissions received must include the OMB Control Number 1651-0003 in the subject line and the agency name. To avoid duplicate submissions, please use only one of the following methods to submit comments:
  (1) Email. Submit comments to: (CBP_PRA@cbp.dhs.gov). The email should include the OMB Control number in the subject line.
  (2) Mail. Submit written comments to CBP PRA Officer, U.S. Customs and Border Protection, Office of Trade, Regulations and Rulings, Economic Impact Analysis Branch, 10th Floor, 90 K St NE., Washington, DC 20229-1177.
* FOR FURTHER INFORMATION CONTACT: Requests for additional PRA information should be directed to Paperwork Reduction Act Officer, U.S. Customs and Border Protection, Regulations and Rulings, Office of Trade, 90 K Street NE., 10th Floor, Washington, DC 20229-1177, or via email (CBP_PRA@cbp.dhs.gov). Please note that the contact information provided here is solely for questions regarding this notice. Individuals seeking information about other CBP programs should contact the CBP National Customer Service Center at 877-227-5511, (TTY) 1-800-877-8339, or CBP Web site. For additional help.
* SUPPLEMENTARY INFORMATION: …
  – Title: Transportation Entry and Manifest of Goods Subject to CBP Inspection and Permit
  – OMB Number: 1651-0003
  – Form Numbers: CBP Forms 7512 and 7512A
  – Abstract: CBP Forms 7512 and 7512A are used by carriers and brokers to serve as the manifest and transportation entry for cargo moving under bond within the United States. The data on the form is used by CBP to identify the carrier who initiated the bonded movement and to document merchandise moving in-bond. These forms provide documentation that CBP uses for enforcement, targeting, and protection of revenue. Forms 7512 and 7512A collect information such as the names of the importer and consignee; a description of the merchandise moving in-bond; and the ports of lading and unlading. Various provisions in 19 CFR require the use of these forms including 19 CFR 10.60, 19 CFR 10.61 and 19 CFR part 18. The forms be found here.
  – Type of Review: Extension (without change).
  – Current Actions: This submission is being made to extend the expiration date with no change to the burden hours or to the information collected. …
 
   Dated: February 8, 2017.
Seth Renkema, Branch Chief, Economic Impact Analysis Branch U.S. Customs and Border Protection.

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

EXIM_a3

3. State: Defense Trade Advisory Group to Meet on 30 Mar in Wash DC
(Source: Federal Register) [Excerpts.]
 
82 FR 10535: Defense Trade Advisory Group; Notice of Open Meeting
   The Defense Trade Advisory Group (DTAG) will meet in open session from 1:00 p.m. until 5:00 p.m. on Thursday, March 30, 2017 at 1777 F Street NW., Washington, DC 20006. Entry and registration will begin at 12:30 p.m. The membership of this advisory committee consists of private sector defense trade representatives, appointed by the Assistant Secretary of State for Political-Military Affairs, who advise the Department on policies, regulations, and technical issues affecting defense trade. The purpose of the meeting will be to discuss current defense trade issues and topics for further study. …
   Members of the public may attend this open session and will be permitted to participate in the discussion in accordance with the Chair’s instructions. Members of the public may, if they wish, submit a brief statement to the committee in writing. …
   For additional information, contact Ms. Glennis Gross-Peyton, PM/DDTC, SA-1, 12th Floor, Directorate of Defense Trade Controls, Bureau of Political-Military Affairs, U.S. Department of State, Washington, DC 20522-0112; telephone (202) 663-2862; FAX (202) 261-8199; or email DTAG@state.gov.
 
Anthony Dearth, Alternate Designated Federal Officer, Defense Trade Advisory Group, Department of State.

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

OGSOTHER GOVERNMENT SOURCES

OGS_a14. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)


* Commerce; International Trade Administration; NOTICES; Meetings: Advisory Committee on Supply Chain Competitiveness [Publication Date: 14 Feb 2017.]  

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

 
The Office of Exporter Services’ Export Management and Compliance Division of the Bureau of Industry and Security combined and revised the content of the Export Compliance Guidelines and Audit Module into one easy-to-use booklet. BIS hopes that this revised resource will provide useful guidance and provide assistance in creating or enhancing your Export Compliance Program.
 
For more information, please visit the Export Management and Compliance Division’s website.

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

 
Effective immediately, all recent additions to the Harmonized Tariff Schedule (HTS) are now available for use in AES.
 
*Note: There have been no additions to the Schedule B.

The ACE AESDirect program has been updated with these new HTS codes.
The full 2017 Schedule B and HTS tables are available for downloading here.
The current list of HTS codes that are not valid for AES are available here.
For further information or questions, contact the U.S. Census Bureau’s International Trade Indicator Micro Analysis Branch.

  – Telephone: (800) 549-0595, select option 2 for International Trade Indicator Micro Analysis Branch
  – Email: eid.scheduleb@census.gov
  – Online: www.census.gov/trade

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

 

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

 

Effective February 10, 2017, DSS will implement the following change(s) to the January 6, 2017 guidance posted on www.dss.mil, concerning Tier 5 Periodic Reinvestigations (T5 PR) caveat programs. The following National Security e-QIPs will be submitted to the National Background Investigations Bureau (NBIB) for scheduling by the Personnel Security Management Office for Industry (PSMO-I):

  (1) New T5 PR e-QIPs for Special Access Programs (SAP) where the SAP policy, as of February 10, 2017, explicitly states a T5 PR is due every 5 years. (this will be considered a caveat program) Note: SCI is NOT considered an exception and should not be submitted to PSMO-I.
  (2) Existing T5 PR e-QIPs (those in current DSS inventory).
  (3) New and existing initial investigations T3 and T5 e-QIPs.
  (4) New and existing T3 PR e-QIPs.

Please no longer submit RRUs for caveat T5 PRs. DSS will be processing the T5 PR inventory by oldest to newest prior to investigation package expiration. Also, the expiration date for e-QIPs in JPAS was increased from 90 days to 120 days. Therefore, e-QIPs will not expire until they reach negative 30 day (-30). DSS will be monitoring expiration dates on all e-QIPs.

For new T5 PR Caveat requests, please include the following in the “Special Handling Instructions”:

  (1) Statement indicating the e-QIP is in support of a caveat program (as identified in this new criteria)
  (2) GCA contact information

As a reminder, the Office of the Undersecretary of Defense for Intelligence signed a memorandum on December 7, 2016, reminding DoD components that personnel security clearances do not expire. Individuals with current eligibility in the System of Record should not be denied access based on a re-investigations passed its periodicity. When the System of Record shows current adverse information, but eligibility is still current, access may continue. The memorandum is provided here for ease or reference. 

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

OGS_a69. DoD/DSS Announces Personnel Security Inquiries to Be Closed on 17 Feb and 20 Feb
(Source: DoD/DSS)
 

Personnel Security (PCL) inquiries (option #2) to include e-QIP authentication resets of the DSS Knowledge Center will be closing at 3 p.m. ET on Friday, February 17, 2017, and will also be closed on Monday, February 20, 2017, in observance of a federal holiday. Normal Knowledge Center operations for PCL and e-QIP inquiries will resume on Tuesday, February 21, 2017. Reminder, the PCL portion of the DSS Knowledge Center typically closes on the last Friday each month.

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

OGS_a710. State/DDTC Posts Reminder Concerning DECCS Batch Licensing Application Submission Release v2.0
(Source: State/DDTC)
 
Industry users that use the batch submission process in DTrade are invited to schedule an individual meeting with DDTC’s technical project team to discuss how the batch process will work with upcoming DDTC changes to its systems and forms in calendar year 2017. Conference calls will be 1 hour each, with time slots available daily from 11am-1pm EST., starting January 17, 2017 – February 17, 2017. To reserve a time slot with DDTC’s technical project team, contact the DDTC Helpdesk at 202-663-2838. DDTC requests that questions be submitted to the technical project team 48 hours prior to the meeting. Specification Document for batch Submission.

Web Notices can be located at http://www.pmddtc.state.gov/. Updates and communications regarding the IT Modernization effort can be found under Outreach and then the IT Modernization Outreach page.
* * * * * * * * * * * * * * * * * * * *

NWSNEWS

 
On February 10, 2017, U.S. Customs and Border Protection (CBP) issued Cargo Systems Messaging Service (CSMS) #17-000072 announcing the release of Harmonized System Update (HSU) 1701, containing 1,295 ABI records and 293 harmonized tariff records.
 
The CSMS specifies that, “Modifications include agency requested PGA indicator changes made to support the PGA message set functionality.”
The update also includes all required modifications for the verification of the 2017 Harmonized Tariff Schedule.
 
The CSMS can be accessed online here.
* * * * * * * * * * * * * * * * * * * *

COMMCOMMENTARY

 
* Author: Doreen M. Edelman, Esq., Baker Donelson LLP, 202-508-3460, dedelman@bakerdonelson.com
 
If you are a foreign company that wants access to the U.S. financial markets, make sure you  understand the U.S. Iran Transactions and Sanctions Regulations (ITSR). Administered by the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC), the ITSR, unlike other sanctions programs, contain secondary sanctions that apply to non-U.S. persons for wholly non-U.S. conduct that may occur entirely outside U.S. jurisdiction. Even if you are not doing business with Iran, several companies and individuals, many of whom are not Iranian, have been listed under the sanctions program, including 25 more added earlier this month.
 
What makes the ITSR unique is its broad reach and recent actions by OFAC indicate that that its reach is only expanding. For instance, just last week OFAC issued a violation (but no fine) against a Taiwanese shipping group over which it asserted jurisdiction because some of the property involved in the transaction was subject to a bankruptcy proceeding in a U.S. court. The transaction involved an Iranian ship transferring oil to a Liberian-flagged ship that was owned by the Taiwanese company. The transfer took place in international waters. Because the Taiwanese shipping group had filed a bankruptcy petition in U.S. court, thereby placing its assets under control of the court, OFAC determined that a violation of the ITSR had occurred.
 
While OFAC’s jurisdictional claim in the above case is particularly novel and the facts particularly unique, foreign companies should take note of it since it signals that OFAC is enforcing the ITSR with particular zeal. Further, the recent listing of more companies and individuals to the Specially Designated Nationals and Blocked Persons (SDN) List, many of whom are not Iranian, should put companies on notice that they should always screen parties with whom they are transacting business so as to not run afoul of ITSR’s secondary sanctions. Although OFAC may not be able to bring criminal sanctions or enforce a civil penalty against a foreign person transacting business with Iran, secondary sanctions allow it to add companies and individuals whom it finds have transacted such business to the SDN List, essentially shutting them out of the U.S. financial system. For more on secondary sanctions programs, see my blog post from last summer here.
 
As all sanctions regulations, but particularly the ITSR, can prove complicated, companies are advised to consult with their compliance officers and lawyers before conducting any business that many involve Iran or a company or person who is on the SDN List. Screening is essential to discover if a company or person is on the SDN List, and understanding what can and cannot be done is critical. Given the recent administration’s expressed intent to get tough with Iran and OFAC’s increasingly assertive jurisdictional posture, compliance should be more a priority than ever before.
* * * * * * * * * * * * * * * * * * * *

COMM_a2
13
. Gary Stanley’s ECR Tip of the Day

 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
 

For ITAR § 126.18(c)(2), the foreign licensee or sublicensee is responsible for maintaining all records regarding the screening to include the NDA. The U.S. applicant is only required to maintain NDAs for dual or third country nationals requested pursuant to ITAR § 124.8(5).

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

TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a1
14. “16th Annual ‘Partnering for Compliance™’ East ECR/Export/Import Control Program” on 7-10 Mar in Orlando FL

(Source: Ailish NicPhaidin, Ailish@PartneringForCompliance.org)

* What: The 16th Annual “Partnering for Compliance™” East will focus intensely on a broad spectrum of export/import regulatory and compliance matters of current relevance to companies and individuals involved in global trading. Senior-level government officials and trade experts will provide first-class training. Our objective is to greatly expand your knowledge and awareness of the requirements needed to adhere to US export/import control regulations, thus helping to ensure your success as a global trader.
* Where: Orlando/Holiday Inn Orlando International Airport Hotel, Orlando, FL
* When:
  – Tue – Thurs, 07-09 Mar: “16th Annual ‘Partnering for Compliance™’ East ECR/Export Control Program
  – Fri, 10 Mar: 1-Day Program “Customs/Import Boot Camp”
* Speakers: DoS/DDTL: Terry Davis & Catherine Hamilton; DoS/DDTC: Daniel Buzby; DoC/BIS: Adam Krepp & OEE Jonathan Barnes; DoD/DTSA: Ken Oukrop; Census Bureau: Kiesha Downs; DHS/CBP: Russell Morgan & Joseph Mitchell; ICE: Jacquelyn Metzger; AND, Braumiller Law Group PLLC: Bruce Leeds & Brad Menard (Imports); Global Legal Services, PC: Gary Stanley; General Dynamics Mission Systems-Canada: Kristen Stewart; and Enterprise Florida: Michael A. Schiffhauer. Cyber Security will be covered as appropriate as will ECR updates.
*Opening Address: Jim Bartlett, Law Office of James E. Bartlett III, PLLC, & Partner, Full Circle Compliance, BV. 
* Bruce Leeds will cover OFAC policies and processes.
* Cost: Customs/Import 1-day program: $200. Export 3-day program: $600. Both programs: $800.
* Remarks: As time permits, all Government and trade speakers will informally hold short “one-to-one” meetings with participants on a “first-come, first-served” basis.
* Certificates of Completion granting: 4.5 IIEI CEUs and 20 CES NCBFAA Credits for 3-day Exports program, and 6.5 CCS NCBFAA Credits for 1-day Customs/Import Boot Camp will be awarded for each program.
* More information: Here.

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

TE_a2
15. ECS Presents
ITAR/EAR Critical Compliance on 28-29 Mar in Scottsdale AZ
(Source: Suzanne Palmer, spalmer@exportcompliancesolutions.com)
 
* What: ITAR/EAR Critical Compliance, Scottsdale AZ
* When: March 28-29, 2017
* Sponsor: Export Compliance Solutions (ECS)
* ECS Speaker Panel:  Suzanne Palmer, Lisa Bencivenga
* Register Here or by calling 866-238-4018 or e-mail spalmer@exportcompliancesolutions.com
* * * * * * * * * * * * * * * * * * * *

MSEX/IM MOVERS & SHAKERS

MS_a116. Monday List of Ex/Im Job Openings: 119 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; Mexico City, Mexico;
Mexico Trade Compliance Program Manager
; Requisition ID: 481541
* Amazon; Mexico City, Mexico;
Mexico Trade Compliance Program Manager
; Requisition ID: 481542
* 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;
Senior Compliance Manager, Global Trade Compliance
; Requisition ID: 489370

* Amazon; Seattle WA;
Sr. Trade Compliance PM, Fashion
; Requisition ID: 475927

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

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

* Amazon; Tokyo, Japan;
JP Export Compliance Manager
; Requisition ID: 464733
* Amazon; Tokyo, Japan;
Trade Compliance Specialist
; Requisition ID: 481891
* American Science & Engineering; Billerica MA;
Sr. Trade Compliance Analyst
;
Requisition ID: 10799
* Apple; Singapore;
APAC Trade Compliance Analyst / Manager
; Requisition ID: 52327703
* Bayer; Leverkusen, Germany;
Head of Customs & International Trade Classification (m/f)
; Requisition ID: 0000180456

* Choice Logistics; New York NY;
VP, Global Trade Solutions

* 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

# Crocs; Amsterdam, The Netherlands;
Manager, Trade Compliance EU

* Cummins Inc.; Daventry, United Kingdom;
Lead Export Controls Analyst
* DRS Technologies; Germantown MD;
Senior Trade Compliance Manager
; Requisition ID: 54749

# Dutch Ophthalmic Research Center; Rotterdam, The Netherlands;
Trade Compliance Specialist

* Edgewell Personal Care; Milford CT; 
Export Compliance And Security Lead
; Requisition ID: NAM00808

* 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;
Sr. Trade Compliance Manager;
Requisition ID: 7333BR
* Esterline Technologies Corporation; Brea CA;
Trade Compliance Specialist
; Requisition ID:
8887BR

# Esterline Technologies Corporation; Coeur d’Alene ID;
Compliance Engineer
; Requisition ID:
9296BR

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

* Expeditors; Manila, The Philippines;
Regional Trade Compliance Manager – Indochina & Philippines
* Expeditors; Roma, Italy;
Ocean Export Manager
* Expeditors; San Francisco CA;
Export Compliance Specialist
* Expeditors; Sunnyvale CA;
Customs Compliance Specialist
* Export Solutions Inc.; Melbourne FL; Trade Compliance Specialist;
info@exportsolutionsinc.com

# Facebook; Dublin, Ireland;
Sanctions Specialist

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

# Facebook; Menlo Park CA;
Compliance Audit Analyst

* Facebook; Singapore;
Export Compliance Manager, APAC

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

* FLIR; Arlington VA;
Manager of Defense Trade Licensing
;
Jamie.Sweeney@flir.com
; Requisition ID: 8121

*
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
* Honeywell; Moscow, Russia;
Integrity & Compliance Manager
; Requisition ID: 00330983

# Huntington Ingalls Industries, Inc.; Newport News VA;
Import/Export Administrator
; Requisition ID: 16103BR
# IBM; Madrid, Spain;
Trade and Compliance Manager

* Illumina; San Diego CA;
SAP Business Solution Analyst, Trade Compliance & Logistics
; Requisition ID: 6890BR

*
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

# Johnson Controls; Wash DC;
Manager Customs & Census; Requisition ID: 144495

*
L3 Technologies, Platform Integration Division; Waco TX;
Export/Import Administrator 3
; Requisition ID 086435

* Lam Research Corporation; Fremont CA:
Foreign Trade Analyst 6
; Requisition ID: 12079BR
* LORD Fly-by-Wire; Saint-Vallier, France; Trade Compliance and Customs Manager  
* 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 PLC; Los Angeles CA;
Export Control/Trade Compliance Administrator
; Requisition ID: 22591
* Merck & Co, Inc.; West Point PA;
Assoc. Director Global Trade Compliance – Export Control, Exports and US Foreign Trade Zones
; Requisition ID: 8728162

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

* Northrop Grumman Corporation; Annapolis Junction MD;
International Trade Compliance Analyst 4
; Requisition ID: 16028623

* Northrop Grumman Corporation; Baltimore MD;
International Trade Compliance Analyst 2
; Requisition ID: 17001145

# Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 2
; Requisition ID: 17000564

* Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 2
; Requisition ID: 17000653

* 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 3
; Requisition ID: 17001930

* Northrop Grumman Corporation; Redondo Beach CA;
International Trade Compliance Analyst 4
; Requisition ID: 16024309

* Northrop Grumman Sperry Marine; New Malden, UK;
Trade Compliance Coordinator
;
careers.uk@sperry.ngc.com
* NXP Semiconductors; Nijmegen, The Netherlands;
Export Control Officer, Requirements Manager
; R-10001504
*
Orbital ATK; Mesa AZ;
International Trade Compliance Specialist
; Requisition ID: MGK20162212-37731
* Pall Corporation; Portsmouth, UK;
Trade Compliance Specialist
; Requisition ID: SHA000201
* Parexel; Kiev, Ukraine;
Global Trade Compliance Specialist
; Requisition ID: pare-10056329
* Roanoke Insurance Group; Schaumburg IL;
Carnet Service Representative
; Requisition ID: 1019
* Raytheon; Arlington VA;
Export Licensing Manager I
; Requisition ID: 87321BR
* Raytheon; Indianapolis IN;
Principal SC Compliance Specialist
; Requisition ID: 84932BR
* Raytheon Space & Airborne Systems; Cambridge MA;
Sr. Exp. License & Compliance Adv
;
Jennifer.a.martindale@raytheon.com
; 310-334-7499; Requisition ID: 91503BR

# Shell; The Hague, The Netherlands;
Legal Counsel – Trade Controls

* Sierra Nevada Corporation; Denver CO;
International Trade Compliance Analyst II
; Requisition ID: R0002483

# Sierra Nevada Corporation; Denver CO;
International Trade Compliance Analyst III
; Requisition ID: R0002484
# Terumo Medical Corporation; Somerset NJ;
Director, Global Trade Compliance

* 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

* Thales; South East Crawley, UK;
Trade Compliance Support Officer
; Requisition ID: R0013706
# ThermoFisher Scientific; Hennigsdorf, Germany;
Global Trade Compliance Specialist (m/f)
; 43954BR

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

* ThermoFisher Scientific; Shanghai, China;
Trade Compliance Specialist
; Requisition ID: 42875BR
* ThermoFisher Scientific; Shanghai, China;
Trade Compliance Specialist – CMC
; Requisition ID: 42143BR

* United Technologies Corporation, UTC Aerospace Systems; Chula Vista CA;
International Trade Compliance Intern
; Requisition ID:
39406BR
* United Technologies Corporation, UTC Aerospace Systems; Chula Vista CA;
International Trade Compliance Intern
; Requisition ID:
39406BR
* United Technologies Corporation, UTC Aerospace Systems; Phoenix AZ;
Manager, International Trade Compliance
; Requisition ID:
28043BR
* United Technologies Corporation, UTC Aerospace Systems; Pueblo CO;
* United Technologies Corporation, UTC Aerospace Systems; Vergennes, VT;
International Trade Compliance Lead
; Requisition ID:
39752BR
* United Technologies Corporation, UTC Aerospace Systems; Westford MA;
* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks CT;
* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks CT;

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

* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
Program Manager, Customs
; Requisition ID:
31331BR
* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
Sr Mgr, Intl Trade Compl
; Requisition ID: 30525BR
* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks CT;

* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks CT;
Specialist, International Trade Compliance
; Requisition ID:
41668BR
* United Technologies Corporation, UTC Aerospace Systems; York NE;
Trade Compliance Analyst
; Requisition ID:
30820BR

* Wurth Industry of North America; Brooklyn Park MN; Trade Compliance Officer;
International Trade Compliance Officer
; Requisition ID: 388-720

* 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

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

ENEDITOR’S NOTES

(Source: Editor) 

 
* Abraham Lincoln (12 Feb 1809 – 15 Apr 1865, was an American politician and lawyer who served as the 16th President of the United States from March 1861 until his assassination.
  – “In the end, it’s not the years in your life that count. It’s the life in your years.”
  – “Don’t interfere with anything in the Constitution. That must be maintained, for it is the only safeguard of our liberties.”
 
* Charles Darwin (Charles Robert Darwin, 12 Feb 1809 – 19 Apr 1882, was an English naturalist and geologist, best known for his contributions to the science of evolution, chiefly in in his 1859 book, On the Origin of Species.  Darwin has been described as one of the most influential figures in human history, and he was honored by burial in Westminster Abbey.)
  – “Ignorance more frequently begets confidence than does knowledge: it is those who know little, and not those who know much, who so positively assert that this or that problem will never be solved by science.”
  – ” I have tried lately to read Shakespeare, and found it so intolerably dull that it nauseated me.”
 
Monday is Pun Day.

Q. What’s your opinion of those two carpenters we hired?
A. The older guy really nails it, but the young guy screws up everything.

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

EN_a318
. 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: 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.

* 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: Last Amendment: 1 Feb 2017: 82 FR 8893-8894: Commerce Control List: Removal of Certain Nuclear Nonproliferation (NP) Column 2 Controls. 

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment:
10 Feb 2017: 82 FR 10434-10440: Inflation Adjustment of Civil Monetary Penalties. 
 
*
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: 10 Feb 2017: Harmonized System Update 1701, containing 1,295 ABI records and 293 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.
  – Latest Amendment: 11 Jan 2017: 82 FR 3168-3170: 2017 Civil Monetary Penalties Inflationary Adjustment
  – The only available fully updated copy (latest edition 24 Jan 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.  

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

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.

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