;

17-0227 Monday “The Daily Bugle”

17-0227 Monday “Daily Bugle”

Monday, 27 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.

[No items of interest noted today.]  

  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.) 
  3. State/DDTC: (No new postings.) 
  4. EU Amends Restrictive Measures Concerning the ISIL (Da’esh) and Al-Qaida Organizations 
  1. Patch.com: “Miami Export Company Accused of Sending Spare Parts to Syria” 
  2. Reuters: “North Korea Evades Sanctions With Network of Overseas Companies: U.N. Report” 
  1. A. Tanchyk & E.W. Sitarchuk: “DOJ Issues New Guidance on Corporate Compliance Programs” 
  2. O. Torres & M. Fogarty: “Outlook for Export Controls and Economic Sanctions Under the Trump Administration” 
  1. ECTI Presents How to Improve Export Compliance with Effective Audits Webinar, 18 Apr 
  1. Kimberly Fordham Joins Northrop Grumman Aerospace Systems 
  2. Monday List of Ex/Im Job Openings: 105 Jobs Posted 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (27 Jan 2017), DOD/NISPOM (18 May 2016), EAR (24 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


[
No items of interest noted today.
]

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

OGSOTHER GOVERNMENT SOURCES

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

* Defense; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: National Industrial Security Program Cost Collection Survey [Publication Date: 28 February 2017.]

* State; NOTICES; Notifications to the Congress of Proposed Commercial Export Licenses [Publication Date: 28 February 2017.]  

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

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

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

OGS_a44.
EU Amends Restrictive Measures Concerning the ISIL (Da’esh) and Al-Qaida Organizations

 
Regulations:
  –
Commission Implementing Regulation (EU) 2017/326 of 24 February 2017 amending for the 261st time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organisations

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

NWSNEWS

NWS_a15.

Patch.com: “Miami Export Company Accused of Sending Spare Parts to Syria”

(Source:
Miami Patch) [Excerpts.]
 
A Miami export company is accused of violating an export ban to war-torn Syria and falsifying export documents.
 
U.S. officials charged 40-year-old Ali Caby, 43-year-old Arash Caby and 34-year-0ld Marjan Caby for their alleged participation in a conspiracy to export so-called “dual-use goods” to Syrian Arab Airlines in violation of the International Emergency Economic Powers Act, the Export Administration Regulations and Global Terrorism Sanctions Regulations.
 
Federal officials define dual use good as articles that have both civilian and military applications. Syrian Arab Airlines is Syria’s official government airline.
 
The airline has been singled out by the U.S. Department of the Treasury’s Office of Foreign Assets Control for transporting weapons and ammunition to Syria along with Hizballah, a terrorist organization, and the Iranian Revolutionary Guard Corps. … 

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

NWS_a036.

Reuters: “North Korea Evades Sanctions With Network of Overseas Companies: U.N. Report”

(Source:
Reuters) [Excerpts.]
 
North Korea is evading international sanctions with a sophisticated network of overseas companies, enabled partly by its continued access to the international banking system, says a forthcoming United Nations report seen by Reuters.
 
North Korea is under heavy U.N. sanctions and a strict arms embargo designed to impede the development of its banned nuclear and missile programs. The U.N. panel of experts, which produced the 100-page draft report, was created to investigate reported infringements of those sanctions.
 
  “Designated entities and banks have continued to operate in the sanctioned environment by using agents who are highly experienced and well trained in moving money, people and goods, including arms and related materiel, across borders,” the report says.
 
U.N. member states should “exercise heightened vigilance” over North Korean diplomats engaged in commercial activities, it says, because some may be providing financial support to illegal networks.
 
North Korea “is flouting sanctions through trade in prohibited goods, with evasion techniques that are increasing in scale, scope and sophistication,” the report says.  
It details a previously unknown interdiction of North Korean-made military communications equipment destined for Eritrea in July last year.
 
The interdiction was the second time North Korean military equipment bound for Eritrea had been intercepted, indicating an ongoing arms trade between the two countries, the report said.
 
The seized equipment, part of an air shipment, included 45 boxes of battlefield radios and accessories, the report says.  
The radios were manufactured by a Malaysia-based front company called “Glocom”, which is controlled by the Reconnaissance General Bureau, the sanctioned North Korean intelligence agency tasked with overseas operations and weapons procurement, the report says.
 
Intelligence Agency
 
The report identifies two North Korean trading companies which, according to an unidentified U.N. member state, are linked to sanctioned entities, including the Reconnaissance General Bureau.
 
The report also outlines North Korea’s use of the financial system to pay for its sanctioned operations.  
“Behind these illicit activities is the continued access of the Democratic People’s Republic of Korea to the international banking system,” the report says, using North Korea’s official title.  
“Despite strengthened financial sanctions in 2016, the country’s networks are adapting by using greater ingenuity in accessing formal banking channels,” the report said.
 
In cases where financial access is more restricted, North Korean agents use bulk cash and gold to circumvent the financial system entirely, and at times use foreign citizens as middlemen and facilitators.  
The report says North Korea continues to export banned minerals despite last year’s sanctions putting a cap on coal exports, a key source of hard currency for the state’s nuclear and missile programs.
 
China has said it would ban coal imports from North Korea until the end of the year. On Thursday, North Korea issued a rare reproach of China, its main diplomatic backer, over the ban.  . . .

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

COMMCOMMENTARY

COMM_a17.

A. Tanchyk & E.W. Sitarchuk: “DOJ Issues New Guidance on Corporate Compliance Programs”

 
* Authors: Alison Tanchyk, Esq.,
alison.tanchyk@morganlewis.com, 305-415-3444; and Eric W. Sitarchuk, Esq.,
eric.sitarchuk@morganlewis.com, 215-963-5840. Both of Morgan, Lewis & Bockius LLP.
 
The DOJ Fraud Section’s “Evaluation of Corporate Compliance Programs” puts chief compliance officers on notice about how the adequacy of their companies’ compliance programs is evaluated by prosecutors.
 
On February 8, the Fraud Section of the US Department of Justice (DOJ) published a list of “important topics and sample questions” it uses when evaluating the effectiveness of corporate compliance programs-titled ”
Evaluation of Corporate Compliance Programs“. [F/N1]
 
This is the first formal guidance issued by the Fraud Section since the change in US presidential administration and confirmation of the new US attorney general. Its publication follows the DOJ’s
hiring of Compliance Counsel Expert Hui Chen in November 2015 and the
revision of the FCPA Resource Guide in June 2015.
 
Prosecution of Business Organizations and the “Filip Factors”
 
The DOJ’s corporate charging guidelines-the “Principles of Federal Prosecution of Business Organizations” [FN/2]-outline the 10 factors that federal prosecutors should consider when assessing the resolution of cases involving corporate wrongdoing. These factors, commonly known as the “Filip Factors,” include “the existence and effectiveness of the corporation’s pre-existing compliance program” as well as the corporation’s remedial efforts “to implement an effective corporate compliance program or to improve an existing one.”
 
The Compliance Program Guidance is intended to provide the public with more transparency about federal prosecutors’ review of compliance programs under the Filip Factors. While the Compliance Program Guidance cautions that “each company’s risk profile and solutions to reduce its risks warrant particularized evaluation,” the document addresses a number of issues that apply to practically all compliance programs.
 
Sizing Up Compliance Programs
 
The
Compliance Program Guidance is divided into 11 sections:
 
  (1) Analysis and Remediation of Underlying Conduct
  (2) Senior and Middle Management
  (3) Autonomy and Resources
  (4) Policies and Procedures
  (5) Risk Assessment
  (6) Training and Communications
  (7) Confidential Reporting and Investigation
  (8) Incentives and Disciplinary Measures
  (9) Continuous Improvement, Periodic Testing and Review
  (10) Third Party Management
  (11) Mergers & Acquisitions
 
The Compliance Program Guidance draws from existing resources, including US Sentencing Guidelines as well as several Organizations for Economic Cooperation and Development publications. [FN/3]
 
Key Areas of Focus
 
Policies and procedures are a foundational component of any corporate compliance program, and the Compliance Program Guidance devotes considerable attention to this topic. As a threshold matter, prosecutors consider the “design and accessibility” of policies and procedures-including whether they are tailored to a company’s risk profile, have been effectively implemented and communicated, and have been evaluated to ensure usefulness. Prosecutors also consider the “operational integration” of a company’s compliance policies and procedures-including the adequacy of payment systems and other controls that should have helped detect or prevent misconduct.
 
The Compliance Program Guidance also focuses on questions concerning the value assigned and resources devoted to compliance programs. For example, the guidance contains pointed questions like the following: “How has the compliance function compared with other strategic functions in the company in terms of stature, compensation levels, rank/title, reporting line, resources, and access to key decision-makers?”
 
Prosecutors look for signs of “autonomy,” such as whether compliance personnel have “direct reporting lines to anyone on the board of directors” and whether “relevant control personnel in the field have reporting lines to headquarters.” They also look for signs of “empowerment,” such as instances where “specific transactions or deals . . . were stopped, modified, or more closely examined as a result of compliance concerns.” 
 
The DOJ has previously advised companies that their compliance programs “should be tailored to [their] specific needs, risks, and challenges,” [FN/4] and the Compliance Program Guidance indicates that the DOJ looks for signs of risk awareness when assessing compliance initiatives. Considerations include the “methodology [that] the company used to identify, analyze, and address the particular risks it face[s],” the “information or metrics [that] the company collect[s] and use[s] to help detect” misconduct, and the scope of the company’s risk assessments.
 
Recent enforcement actions suggest that third parties continue to pose major risks for companies operating overseas, and the DOJ looks for evidence that such companies are proactively addressing third-party risks. Prosecutors want to know whether a company has a “third-party management process [that] correspond[s] to the nature and level of [its] enterprise risk[s]” and will consider whether the company (i) engages in third-party due diligence and monitoring, (ii) requires that its third parties enter into written contracts with “appropriate” payment terms, and (iii) addresses any red flags that arise during the course of the relationship.
 
Conclusion
 
While the Compliance Program Guidance is “required reading” for companies and their counsel when preparing compliance-related presentations or submissions to the DOJ, it is also a valuable resource for officers and directors who want to ensure that their compliance programs satisfy regulator expectations. The DOJ expects compliance programs to be both strong on paper and in practice, [FN/5] and this 119-question resource offers critical intelligence for chief compliance officers looking for ways to weave compliance into the fabric of their organizations.
 
——-
  [FN/1] US Dep’t of Justice, Criminal Division, Fraud Section, ”
Evaluation of Corporate Compliance Programs” (Feb. 8, 2017).
  [FN/2] Chapter 9-28.000 of the US Attorneys’ Manual
  [FN/3] OECD, Good Practice Guidance on Internal Controls, Ethics, and Compliance (February 18, 2010); OECD, Anti-Corruption Ethics and Compliance Handbook for Business (2013).
  [FN/4] FCPA Resource Guide at 57.

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COMM_a2
8O. Torres & M. Fogarty: “Outlook for Export Controls and Economic Sanctions Under the Trump Administration”

(Source:
Torres Law PLLC)
 
* Authors: Olga Torres, Esq.; and Matt Fogarty, Esq. Both of Torres Law PLLC.  Contact: 214-593-7120,
info@torrestradelaw.com.
 
The first weeks of the Trump Administration have been eventful, but there has been little action in the area of export controls and economic sanctions. In this regard, there’s no clear consensus just yet as to whether and how significantly President Trump plans to deviate from the course set over the last eight years of the Obama Administration.
 
As is said, personnel is policy and many of the key export and sanctions officials are not yet in place. In many cases, the officials who will be charged with the ground-level implementation of the Trump Administration’s export and sanctions initiatives have not even been named. Moreover, one of the new President’s first acts was to issue
a freeze on any new regulations that essentially stalled any export or sanctions reforms that may have been in the works.
 
Nevertheless, the new President has hinted at his foreign policy and national security priorities in responding to certain provocations from, for example, Iran. These hints, along with policy changes late in the Obama Administration and some more recent less consequential regulatory developments, give some insight into where export and sanctions policy may impact U.S. and non-U.S. companies in the coming months and years.
 
Iran
 
Candidate Trump pledged to undo the Joint Comprehensive Plan of Action (“JCPOA”), also known as the Iran nuclear deal. In some respects, the JCPOA appeared to represent an easing of sanctions on Iran by the United States and Europe. However, with the exception of certain secondary and nuclear-related sanctions, the Obama Administration retained most sanctions on Iran. We saw some minor adjustments to the Office of Foreign Assets Control’s (“OFAC”) Iran sanctions program in late 2016, including
the addition of a Frequently Asked Question clarifying that the Iranian Transactions and Sanctions Regulations (“ITSR”) authorize certain limited transshipments of non-Iranian origin items through Iran to another destination so long as they are shipped on vessels or aircraft and do not leave the boundaries of the port. Additionally, OFAC cleared the way for certain significant sales of civil aircraft to Iran.
 
President Trump has been less adamant about withdrawing from the JCPOA and early indications are that the Trump Administration will honor the JCPOA but will strictly enforce its terms. However, particularly following Iran’s testing of a ballistic missile in late January, the Trump Administration has taken a harder line than the Obama Administration, with new National Security Adviser Michael Flynn suggesting that President Obama had been soft with respect to Iran.
 
Perhaps most telling of the direction the Trump Administration may take, however, is the round of
designations of 25 entities and individuals imposed in response to the ballistic missile test. The designations appeared to target parties affiliated with the Iranian Revolutionary Guard Corps (“IRGC”) and their supplier network, including some suppliers in China. President Trump could use this approach in the future-targeting individuals and entities in areas outside those covered by the JCPOA-to apply additional pressure on the Iranian regime in advance of the Iranian elections in May 2017.
 
Russia
 
Acting on intelligence community assessments that both private individuals and state actors in Russia were involved in manipulating the U.S. election (via cyber and other means), in late 2016, the Obama Administration added to its Crimea-related Russia sanctions by
designating several individuals and entities, including certain Russian government agencies, under a number of executive orders. Indeed, President Obama left office having set U.S.-Russia relations on a clear path toward conflict and further tightened sanctions.
 
It is as yet unclear how the new Administration will deal with Russia, though it appears unlikely that the Trump Administration will continue to ratchet up sanctions. President Trump has indicated a willingness to engage with Russia, particularly with respect to Syria, but has also made clear that he will continue to press Russia to cease its support for the regime in Tehran.
 
As one of its only actions relating to Russia during the Trump Administration,
OFAC issued a new general license allowing U.S. persons to engage in certain limited transactions with the Russian FSB, which is responsible for issuing import permits for encryption items (including consumer electronic devices) and which had been designated under OFAC’s Cyber Sanctions. Some in the media took this action as evidence of a potential easing of sanctions. However, OFAC officials and the White House rightly clarified that the general license was intended as a technical fix similar to another
general license issued in December with regard to the FAU Glavgosekspertiza Rossii, a Russian government agency responsible for issuing construction-related permits. In both cases, OFAC’s designation of the agency had unintentionally prevented U.S. companies from requesting and paying for permits needed to do business with non-designated parties in Russia; both general licenses simply correct this mistake.
 
Sudan
 
One of the more surprising developments in the waning days of the Obama Administration was the issuance by OFAC of a broad general license
authorizing essentially all transactions prohibited under the Sudanese Sanctions Regulations (“SSR”). The general license was the result of positive steps taken by the regime in Sudan. In an accompanying executive order, President Obama outlined the efforts toward ending the conflict in Sudan and established a six-month timeline after which, assuming the Sudanese conflict continues toward resolution, Sudan sanctions and the SSR will be lifted entirely.
 
Indications are that the Trump Administration is supportive of the lifting of sanctions on Sudan and that the general license will remain in force. Note, however, that OFAC’s Darfur sanctions are still in place and that Sudan is still designated by the State Department as a State Sponsor of Terrorism. Note also that, based in part on this designation, many states still have divestment laws prohibiting investment in companies that do business in Sudan.
 
Cuba, North Korea, and Syria
 
As of now, it appears the Trump Administration will continue the Obama Administration’s approach to liberalizing sanctions with regard to Cuba and tightening sanctions on North Korea and Syria. On Cuba, since 2014, the Obama Administration has gradually scaled back U.S. sanctions to allow U.S. companies to do business in Cuba, including reopening respective embassies in Havana and Washington and authorizing a number of commercial airline flights to Cuba in mid-2016. The Trump Administration appears poised to continue this gradual rapprochement, though perhaps at a slower pace, or at the very least not to undo the Obama Administration’s efforts to ease sanctions.
 
With respect to Syria and North Korea, the Obama Administration continued to identify and designate sanctions targets in both countries through 2016 and January 2017 given ongoing conflict in Syria and ongoing defiance in North Korea, and even reimposed a full prohibition on transactions involving North Korea in late 2016. The Trump Administration seems likely to continue these measures unless and until hostilities cease and the regimes in either country demonstrate a willingness to abide by international norms.
 
Export Controls
 
The path ahead for the Obama Administration’s export control reform initiative is unclear. In many ways, whether and how vigorously the Trump Administration continues working to achieve the aim of “higher fences” and a “smaller yard” will depend on who incoming Commerce Secretary Wilbur Ross appoints to key positions like that of Assistant Secretary for Export Administration, previously occupied by Kevin Wolf.
 
President Trump has expressed an interest in rebalancing trade with China primarily through tariffs and other import-related mechanisms. However, we could see greater attention on China in the export controls arena, as well, potentially involving stricter licensing requirements with regard to exports of technology to China and additional restrictions on Chinese companies that supply Iran and other U.S. sanctions targets. For example, as noted above, a number of Chinese suppliers were implicated in the Trump Administration’s recent Iran sanctions.
 
Conclusion
 
Until the new administration fills key leadership positions at the various agencies, it is difficult to predict how President Trump will use export controls and economic sanctions to implement the foreign policy objectives he outlined during the campaign and in the first weeks of his administration. However, based on the limited evidence discussed above, it appears that the Trump Administration will continue to utilize export and sanctions tools as a means of applying economic and political pressure in trouble spots around the world. It also appears likely we may see heightened enforcement efforts, particularly in regions of greatest concern to the Trump Administration like Iran and Syria. In any case, without clearer signals as to potential export and sanctions revisions under the new administration, U.S. and non-U.S. companies alike would be best advised to proceed with caution in potential new or opening markets like Sudan and Cuba while continuing to be conservative with activities in hot spots like Iran, Syria, and Russia.

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a19. ECTI Presents How to Improve Export Compliance with Effective Audits Webinar, 18 Apr
(Source: Danielle McClellan,
danielle@learnexportcompliance.com)
 
* What: How to Improve Export Compliance
 
with Effective Audits 
* When:
 
April 18, 201
7
; 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Felice Laird
* Register: Here or Danielle McClellan, 540-433-3977, danielle@learnexportcompliance.com.
* * * * * * * * * * * * * * * * * * * *

MSEX/IM MOVERS & SHAKERS

MS_a210. Kimberly Fordham Joins Northrop Grumman Aerospace Systems

(Source: Kimberly Fordham, kimberly.fordham@ngc.com)

Kimberly Fordham has moved from Northrop Grumman Mission Systems in McLean, VA, to Northrop Grumman Aerospace Systems in Melbourne, FL, as Manager of the Manned Aircraft Division. Contact Kimberly at 571-326-3047 or kimberly.fordham@ngc.com.

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MS_a111. Monday List of Ex/Im Job Openings: 105 Jobs Posted

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

* AbbVie Inc.; Chicago IL;
Senior Analyst, Global Trade Compliance
; Requisition ID: 1607976

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

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

* 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

#
Chromalloy; Orangeburg NY;
International Trade Compliance Manager
; 
Dsinski@chromalloy.com
; Requisition ID: 00935

* 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

# DB Schenker; Atlanta GA, and Long Beach CA;
Area Customs Director
;
Crystal.Adair@dbschenker.com
; Requistion ID: 17P009

* 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; Coeur d’Alene ID;
Compliance Engineer
; Requisition ID:
9296BR

* 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

* FD Associates, Tysons Corner VA;
Senior Export Compliance Associate
;
jobs@fdassociates.net

* 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
*
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

* 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

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

* 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; 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
*
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; McKinney TX;
Sr Exp License & Compliance Adv;
Jennifer.a.martindale@raytheon.com
; 310-334-7499; Requisition ID:
91503BR

* Rolls-Royce; Indianapolis IN;
Export Control Specialist
; Requisition ID: JR6016567

* 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

* Synopsys; Mountain View CA;
Senior Manager, Export Compliance
;
moudakas@synopsys.com
;
650-584-1676; Requisition ID: 13208BR

* 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 – CMC
; Requisition ID: 42143BR

* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
International Trade Compliance Business Process Analyst
; Requisition ID:
34007BR

* United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
Manager, International Trade Compliance;
Requisition ID:
42268BR

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

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

International Trade Compliance Intern
; Requisition ID:
39406BR

# United Technologies Corporation, UTC Aerospace Systems; Fairfield CA;
International Trade Compliance Analyst
; Requisition ID:
40602BR
# United Technologies Corporation, UTC Aerospace Systems; Hodges SC;
Site ITC Lead;
Requisition ID:
42571BR

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

* 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) 

 
*
John Steinbeck (John Ernst Steinbeck, Jr., 27 Feb 1902 – 20 Dec 1968, was an American author of 27 books, including 16 novels, six non-fiction books, and five collections of short stories. He is widely known for novels
Tortilla Flat (1935) and
Cannery Row (1945), the multi-generation epic
East of Eden (1952), and the novellas
Of Mice and Men (1937) and
The Red Pony (1937).  The Pulitzer Prize-winning
The Grapes of Wrath (1939) is considered Steinbeck’s masterpiece. In 1962, Steinbeck received the Nobel Prize in Literature.)

  – “I have never smuggled anything in my life. Why, then, do I feel an uneasy sense of guilt on approaching a customs barrier?”

  – “I’ve lived in good climate, and it bores the hell out of me. I like weather rather than climate.”

*
Buffalo Bill Cody (William Frederick “Buffalo Bill” Cody, 26 Feb 1846 – 10 Jan 1917, was an American scout, bison hunter, and showman.)

  – “Every Indian outbreak that I have ever known has resulted from broken promises and broken treaties by the government.”

 

*
Henry Wadsworth Longfellow (27 Feb 1807 – 24 Mar 1882, was an American poet and educator whose works include
“Paul Revere’s Ride”,
The Song of Hiawatha, and
Evangeline).

  – “In character, in manner, in style, in all things, the supreme excellence is simplicity.”

 

Monday is pun day.

Q. Which knight invented the Round Table?

A. Sir Cumference.

  — Michael Jones, Milwaukie, OR 

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

EN_a313
. 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: 24 Feb 2017: 82 FR 11505-11506: Temporary General License: Extension of Validity 

  
*
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.

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

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