17-0306 Monday “The Daily Bugle”

17-0306 Monday “Daily Bugle”

Monday, 6 March 2017

The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, Customs, NISPOM, EAR, FACR/OFAC, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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  1. Commerce/BIS Submits Collection of Information Concerning Technical Data Letter of Explanation to the OMB 
  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. Canada Changes Sanctions Against Iran 
  1. Defense News: “Despite Brexit, France Wants to Include UK in European Defense Efforts” 
  2. Defense News: “UN Report Shows North Korea Using Africa to Slip Sanctions” 
  3. The Salt Lake Tribute: “Man Put on Probation For Trying to Export Rifles to Belarus” 
  4. ST&R Trade Report: “Trade Policy Agenda Vows to Defend U.S. Sovereignty, Open Export Markets” 
  5. ST&R Trade Report: “CBP to Focus on Enforcement, Facilitation, Regulatory Burdens to Promote Economic Growth” 
  1. M. Volkov: “DOJ Compliance Expectations Concerning Training, Internal Investigations and Audits (Part IV of IV)” 
  1. Monday List of Ex/Im Job Openings: 111 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) 



1. Commerce/BIS Submits Collection of Information Concerning Technical Data Letter of Explanation to the OMB

Federal Register
82 FR 12536: Submission for OMB Review; Comment Request; Technical Data Letter of Explanation
The Department of Commerce will submit to the Office of Management and Budget (OMB) for clearance the following proposal for collection of information under the provisions of the Paperwork Reduction Act (44 U.S.C. Chapter 35).
Agency: Bureau of Industry and Security.
Title: Technical Data Letter of Explanation.
Form Number(s): N/A.
OMB Control Number: 0694-0047.
  Type of Review: Regular submission.
Estimated Total Annual Burden Hours: 6,226.
Estimated Number of Respondents: 6,313.
Estimated Time per Response: 30 minutes-2 hours.
Needs and Uses: These technical data letters of explanation will assure the Bureau of Industry and Security that U.S.-origin technical data will be exported only for authorized end-uses, users and destinations.
Affected Public: Business or other for-profit organizations.
Frequency: On Occasion.
Respondent’s Obligation: Voluntary.
  This information collection request may be viewed at reginfo.gov http://www.reginfo.gov/public/. Follow the instructions to view Department of Commerce collections currently under review by OMB.
  Written comments and recommendations for the proposed information collection should be sent within 30 days of publication of this notice to OIRA_Submission@omb.eop.gov.
Sheleen Dumas, PRA Departmental Lead, Office of the Chief Information Officer. 

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

* Commerce Department; NOTICES; Request for Information; Impact of Federal Regulations on Domestic Manufacturing [Publication Date: 7 Mar 2017.] 

* Commerce; Industry and Security Bureau; NOTICES; Meetings [Publication Date: 7 March 2017.]:
  – Emerging Technology and Research Advisory Committee
  – Regulations and Procedures Technical Advisory Committee
  – Sensors and Instrumentation Technical Advisory Committee

* Commerce; Industry and Security Bureau; NOTICES; Recruitment of Private-Sector Members: Technical Advisory Committees [Publication Date: 7 March 2017.]  

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Canada Amends Iran Sanctions

On February 5, 2016, the Minister of Foreign Affairs and the Minister of International Trade announced changes to Canada’s economic sanctions against Iran.
Canada will continue to maintain tight controls on exports to Iran of goods and technologies which are considered sensitive from a national and international security perspective.
Applications for export permits for all items listed on the Export Control List pursuant to the Export and Import Permits Act will be considered on a case-by-case basis.
In addition, applications for export permits to export to Iran any goods or technologies covered under any of the following items on the Export Control List, (i.e., those items which are considered the most sensitive from a national and international security perspective, including nuclear goods and technologies, as well as those goods and technologies which could assist the development of Iran’s ballistic missiles program), will normally be denied:
Group 1 (Dual-Use List)
  – Test, inspection, and production equipment for special materials and related equipment as outlined in item 1.1.B, and its associated software and technology
  – Materials as outlined in item 1-1.C, and its associated software and technology
  – Test, inspection, and production equipment for materials processing as outlined in item 1-2.B and its associated software and technology
  – Intrusion equipment, systems and components as outlined in 1-4.A.5, and its associated software and technology
  – Telecommunications intercept, surveillance and jamming equipment, systems and components as outlined in 1-5.A.1.f, 1-5.A.1.j, and its associated software and technology
  – Optical sensors, high-speed instrumentation cameras, image intensifier cameras, focal plane array imaging cameras, lasers as outlined in 1-6.A.2, 1-6.A.3.a, 1-6.A.3.b.3, 1-6.A.3.b.4, 1-6.A.5, and its associated software and technology
  – All items on Category 9 of Group 1, with the exception of those parts and components intended for civil aircraft as outlined in 1-9.A.1, 1-9.A.3, 1-9.A.12, as well as software and technology related to 1-9.A.1, 1-9.A.3, 1-9.A.12
Group 2 (Munitions List)
  – All items on Group 2
Group 3 (Nuclear Non-Proliferation List)
  – All items on Group 3
Group 4 (Nuclear-Related Dual-Use List)
  – All items on Group 4
Group 5 (Miscellaneous Goods and Technology)
  – Item 5501 Blinding laser weapons
  – Item 5502 Nuclear fusion reactors
  – Item 5503 Antipersonnel mines
  – All items in 5504 (Strategic goods and technology), with the exception of 5504.2.a.1, 5504.2.b as they relate to the use of 5504.2.a.i only
  – Item 5505 Goods and technology for certain uses (Catch-all)
Group 6 (Missile Technology Control Regime List)
  – All items on Group 6, with the exception of those parts and components intended for civil aircraft as outlined in 6-3.A.1, 6-3.E.1, 6-9.A.3, 6-9.A.4, 6-9.A.5, 6-9.A.8, as well as software and technology related to  6-3.A.1, 6-3.E.1, 6-9.A.3, 6-9.A.4, 6-9.A.5, 6-9.A.8
Group 7 (Chemical and Biological Weapons Non-Proliferation List)
  – Chemical Weapons Convention Materials as outlined in 7-3, and its corresponding technology
  – P3 and P4 containment facilities as outlined in 7-12.1, and its corresponding technology
  – Human toxins as outlined in 7-13.1.d, and its corresponding technology
For further information, please contact the Export Controls Division at Global Affairs Canada by phone or email: 613-996-2387 /
Note that the Government of Canada has made changes to its economic sanctions against Iran under the Special Economic Measures Act and the United Nations Act. For further information, please consult
Canadian Sanctions Related to Iran.

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Defense News: “Despite Brexit, France Wants to Include UK in European Defense Efforts”

France is seeking a greater integrated European defense and has invited Britain to play a role, despite its plan to leave the European Union, said French President François Hollande, The Guardian daily reported Monday.
The U.K. has close bilateral defense ties with France, which explains the French invitation to take part in “a more integrated European defense policy” despite London’s EU departure, the report said.
  “In my mind, the U.K., even outside the E.U., should be associated with that,” Hollande was quoted as saying.
France is drawing on concerns over the Trump administration’s loosening of international ties to boost the move toward greater defense cooperation in Europe, the report said. 
  “As for his (U.S. President Donald Trump’s) ignorance of what the European Union is, that means we must prove to him the E.U.’s political cohesion, its economic weight and its strategic autonomy,” Hollande reportedly said. Europe must seek to avoid a “submissive” role arising from a dependence on outside powers, he added.
London has long resisted a drive from Paris for a stronger European military cooperation, as NATO and Washington’s leading role in the transatlantic alliance have been the reference point for British policy.
Hollande spoke to The Guardian and four other European papers – Le Monde, La Vanguardia, La Stampa and Süddeutsche Zeitung – ahead of a mini-summit Monday with the leaders of Germany, Italy and Spain at Versailles, just west of the capital. 
Britain and France, seen as the leading military powers in Europe, signed in 2010 the Lancaster House defense treaty, seeking to boost bilateral cooperation in operations and industrial efforts, including nuclear weapons research.
Meanwhile, Germany opposes a French and Italian proposal to use government-backed bonds in the capital markets to fund a planned €5 billion (U.S. $5.3 billion) EU defense research fund, Reuters reported.
Such funding would “violate the basic principles of good budget practices and therefore is not a viable option for financing European defense efforts,” Handelsblatt reported, quoting a German government paper, according to Reuters. 
Germany also objected to national contributions to the EU defense fund to be exempt from the European stability and growth requirements, which seek to reduce the national debt to 3 percent of gross domestic product, Reuters reported. The European Commission proposed the fund in November as a cost-cutting measure, allowing European states to buy together helicopters and planes. 

France and Italy backed the commission proposal to allow the fund to be raised by government-backed issuance on capital markets, Reuters reported. 

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Defense News: “UN Report Shows North Korea Using Africa to Slip Sanctions”

Defense News) [Excerpts.]
North Korean weapons barred by U.N. sanctions ended up in the hands of U.N. peacekeepers in Africa, a confidential report says. That incident and others in more than a half-dozen African nations show how North Korea, despite facing its toughest sanctions in decades, continues to avoid them on the world’s most impoverished continent with few repercussions.
The annual report by a U.N. panel of experts on North Korea, obtained by The Associated Press, illustrates how Pyongyang evades sanctions imposed for its nuclear and ballistic missile programs to cooperate “on a large scale,” including military training and construction, in countries from Angola to Uganda.  . . . .

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The Salt Lake Tribute: “Man Put on Probation For Trying to Export Rifles to Belarus”

A United Arab Emirates man who admitted he conspired to export sniper rifles from the United States to Belarus has been sentenced by a federal judge in Utah to five years of probation.
U.S. District Judge Dee Benson also ordered Kolar Rahman Anees Ur Rahman to forfeit more than $13,000 he sent to an undercover Department of Homeland Security agent as payment for the unlawful shipment of the weapons to the eastern European country.
Rahman, 47, was indicted in December 2015 with conspiracy to commit an offense against the United States, violating the Arms Export Control Act, smuggling goods from the United States and money laundering. He pleaded guilty to the four counts and was sentenced Jan. 30. …  

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ST&R Trade Report: “Trade Policy Agenda Vows to Defend U.S. Sovereignty, Open Export Markets”

The Trump administration intends to pursue “a new trade policy” that defends U.S. sovereignty, enforces U.S. trade laws, uses leverage to open foreign markets, and negotiates new trade agreements that are fairer and more effective for both the U.S. and the world trading system, according to the annual trade policy agenda the White House submitted to Congress March 2. The agenda contrasts this approach with that of the past 20+ years, which focused on “trade policies that emphasized multilateral and other agreements designed to promote incremental change in foreign trade practices, as well as deference to international dispute settlement mechanisms” but too often put the U.S. “at an unfair disadvantage in global markets.” The “overarching purpose” of this new policy, the agenda states, will be to “increase [U.S.] economic growth, promote job creation in the United States, promote reciprocity with our trading partners, strengthen our manufacturing base and our ability to defend ourselves, and expand our agricultural and services industry exports.” 
Asserting U.S. Sovereignty. The administration is committed to “aggressively defend U.S. national sovereignty over trade policy” by resisting efforts by other countries or international bodies like the World Trade Organization to “advance interpretations that would weaken the rights and benefits of, or increase the obligations under, the various trade agreements to which the United States is a party.” The agenda highlights the “clear and express legal limitation” in the WTO’s Dispute Settlement Understanding that WTO dispute settlement findings or recommendations may not add to or diminish U.S. rights or obligations under the WTO agreements. It also points out that adverse WTO decisions do not automatically lead to a change in U.S. law or practice.
Addressing Unfair Trade Practices. Proclaiming it “essential to both the United States and the world trading system that all U.S. trade laws be strictly and effectively enforced,” the administration pledges to “act aggressively as needed” against the unfair trade practices that have distorted important sectors of the global economy and significant markets around the world, including foreign government subsidies, theft of intellectual property, currency manipulation, unfair competitive behavior by state-owned enterprises, violations of labor laws, and use of forced labor. Tools that may be used in this effort include the following.
  – Antidumping and countervailing duty laws, noting that the Department of Commerce has the right to self-initiate AD/CV cases if circumstances warrant;
  – Section 201 safeguards that may be imposed if increasing imports are a substantial cause of serious injury to a domestic industry; and
  – Section 301 actions in response to foreign actions that violate an international trade agreement or are unjustifiable, unreasonable, or discriminatory and burden or restrict U.S. commerce, which when “properly used … can be a powerful lever to encourage foreign countries to adopt more market-friendly policies”
Opening Foreign Markets. The agenda states that exports of manufactured goods, agricultural products, and services are “an important and essential aspect of the U.S. economy” and that the administration will “use all possible leverage to encourage other countries to give U.S. producers fair, reciprocal access to their markets.” Among the challenges the administration will seek to address as part of this effort are lack of adherence to free-market principles and insufficiently transparent legal and regulatory systems.
The agenda also pledges a “major review of how we approach trade agreements” because the results of existing agreements “have often not lived up to expectations.” For example, the U.S. has seen slower economic growth, lower median incomes, higher trade deficits, and a sharp net loss of manufacturing jobs. The administration’s new approach will focus on negotiating bilateral (rather than multilateral) trade agreements, particularly with countries committed to a market-based economy. 

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ST&R Trade Report: “CBP to Focus on Enforcement, Facilitation, Regulatory Burdens to Promote Economic Growth”

Federal officials said recently that the trade community can expect to see a continued emphasis on both enforcement and facilitation, including a renewed effort to lower regulatory burdens, as part of the Trump administration’s focus on promoting economic growth.
Acting U.S. Customs and Border Protection Commissioner Kevin McAleenan told a meeting of the Commercial Customs Operations Advisory Committee that new Department of Homeland Security John Kelly will be a major supporter of CBP’s dual roles of enforcing U.S. trade laws and facilitating legitimate trade. Both are needed to help U.S. companies be competitive in the global marketplace, which is vital to the president’s goals of increasing domestic economic growth and employment. Christa Brzozowski, deputy assistant secretary of homeland security, trade and transport, and Daniel Ragsdale, deputy director of U.S. Immigration and Customs Enforcement, said ensuring trade compliance will be a priority for their agencies as well.
Enforcement. McAleenan said CBP will continue to focus on implementation of the Trade Facilitation and Trade Enforcement Act. In a recent blog post McAleenan reviewed CBP’s progress in this area over the past year, including electronic filing of allegations of evasion of antidumping and countervailing duty orders, utilizing enhanced authorities to protect intellectual property rights, and issuing withhold release orders on several commodities from China over concerns about forced labor.
Leaders of COAC’s Trade Enforcement and Revenue Collection Subcommittee noted that they have been considering a number of TFTEA-related items to ensure transparency and dialogue between CBP and the trade community. These include CBP’s joint strategic plan on trade enforcement, which is currently under review by DHS; the importer of record program, which is dependent on CBP’s new Form 5106 being discussed with the Office of Management and Budget; importer risk assessment, which a CBP internal working group is currently reviewing; and the establishment of a Trade Remedy Law Enforcement Directorate within CBP’s Office of Trade, which will assume the former Commercial Targeting & Enforcement responsibilities plus the newly established Enforce and Protect Act branch for AD/CV duty evasion allegations.
Facilitation. With respect to trade facilitation, McAleenan noted that 100 percent of all pre-release functionality within the Automated Commercial Environment has been deployed along with 85 percent of post-release functionality. CBP is still working to determine an effective date for the final deployment and will advise the trade community at least 30 days ahead of time through a Federal Register notice.
Both Brzozowski and Tim Skud, deputy assistant secretary of the treasury for tax, trade, and tariff policy, said one of the ways the new administration will actively seek to facilitate trade is by eliminating, simplifying, or streamlining regulations that make it difficult for importers and exporters to do business. President Trump recently directed the establishment of regulatory reform teams within federal agencies to focus on this task, and Brzozowski and Skud invited the trade community to submit their ideas to DHS and Treasury. COAC’s Trade Modernization Subcommittee, co-chaired by ST&R attorney Lenny Feldman, is also working on various ways to reduce trade-related regulation and cost, such as modernizing CBP’s revenue collection process and accelerating the agency’s issuance of rulings. 



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M. Volkov: “DOJ Compliance Expectations Concerning Training, Internal Investigations and Audits (Part IV of IV)”

Volkov Law Group Blog. Reprinted by permission.)
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
[Editor’s note: This commentary is the final part of a series of items concerning this topic.  Part I, II and III were posted in The Daily Bugle of 1, 2 and 3 March 2017, respectively.]
DOJ’s Compliance Evaluation questions provide important indications of “new” trends and approaches to compliance functions and issues.
In the area of training, DOJ’s Compliance Evaluation reiterates DOJ’s concern that companies tailor their training programs to their specific risk profile. In the FCPA Guidance issued in 2012, DOJ explained that training programs should be tailored to specific audiences.
DOJ has refined this requirement to focus on training “employees in relevant control functions”? This refinement is more significant than first appears. An accounts payable employee serves in a “relevant control function” involving the payment of money to vendors and suppliers. An employee responsible for third party due diligence checks serves in  a “relevant control function” responsible for third party risk management. The list continues with a large number of “relevant control parties.” Companies have to design a variety of training programs to address these specific risks and controls.
Companies have to ensure that they provide training in different languages, as needed, and they have to measure the overall effectiveness of their training programs. Similarly, companies have to make sure that employs can access guidance on legal and compliance issues.
Reporting Misconduct and Investigations
In a shot against legal and internal audit departments, DOJ’s Compliance Evaluation asks whether compliance has had full access to reporting and investigative information. Turf battles are often fought over these issues, and DOJ is clearly stating that the compliance function has to receive access to investigative information.
Companies often fall short on their internal investigation functions, failing to make sure they are conducted properly, fairly, independently, and consistently across the organization. DOJ’s questions reiterate the importance of meeting such standards when conducting internal investigations.
DOJ’s Compliance Evaluation reiterates the importance of sharing investigative findings with senior leadership, addressing compliance concerns raised by internal investigations and understanding senior management and supervisory lapses that may have occurred when investigating misconduct.
Discipline and Incentives
DOJ’s Compliance Evaluation requires careful evaluation of misconduct and accountability of managers and employees. In particular, DOJ emphasized the importance of disciplining supervisors for failures to exercise proper supervision. In this context, DOJ stated that it expects companies to keep track and weigh its overall disciplinary program to ensure consistent treatment and accountability for misconduct.
In addressing the discipline process, DOJ expects to see a broad range of functions (e.g. human resources, compliance, legal) involved in the review of discipline. In promoting the discipline and consequences functions, DOJ included questions concerning disclosure of disciplinary actions to communicate to managers and employees the importance of ethical conduct.
DOJ reiterated the importance of creating positive incentives for ethical behavior.
Audit Function
Interestingly, DOJ’s Compliance Evaluation includes a detailed set of questions concerning a company’s audit function. These questions show that DOJ is embracing a robust examination of the company’s audit function, in recognition of the growing importance of monitoring and auditing to the overall effectiveness of a company’s compliance program.
DOJ’s examination includes:
  – The number and type of audits, especially in high-risk areas;
  – The reporting of audit findings and remediation progress;
  – The involvement of board and senior management in follow up to audit findings and remediation;
  – The examination of potential misconduct and audit and testing of relevant controls, collection and analysis of compliance data and interviews of employees and third parties; and
  – The testing of controls.
DOJ’s analysis suggests that it is focusing on an important relationship – compliance and auditing/monitoring. While companies often coordinate these functions, DOJ is expecting increased collaboration and focus on compliance controls and auditing.

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MS_a112. Monday List of Ex/Im Job Openings: 111 Jobs Posted

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

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

* 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
; Requisition ID: 00935

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

* Cummins Inc.; Daventry, United Kingdom;
Lead Export Controls Analyst

* DB Schenker; Atlanta GA, and Long Beach CA;
Area Customs Director
; Requistion ID: 17P009

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

* 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:

* 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;

* 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

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

* FLIR; Arlington VA;
Manager of Defense Trade Licensing
; 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  
* 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

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

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

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

* 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

Space Systems Loral; Palo Alto CA; 
Senior Export Compliance Specialist
; Requisition ID: 6930

* Synopsys; Mountain View CA;
Senior Manager, Export Compliance
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

* 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:

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

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

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

International Trade Compliance Intern
; Requisition ID:

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

* United Technologies Corporation, UTC Aerospace Systems; Vergennes, VT;
International Trade Compliance Lead
; Requisition ID:
* 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:
* Vigilant; Unknown location in the U.S.;
BioTech/Pharmaceutical Global Trade Analyst
# Vista Outdoor; Various locations in the U.S.;
Sr. Specialist Imports & Customs Operations, ITO
; Requisition ID: R0001996
# Vista Outdoor; Various locations in the U.S.;
Sr. Specialist Imports & Customs Programs, ITO
; Requisition ID: R0001997 

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

* XPO Logistics; Greenwich CT;
Global Trade Compliance Analyst

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(Source: Editor) 

Elizabeth Barrett Browning (née Moulton-Barrett, 6 Mar 1806–29 Jun 1861, was one of the most prominent English poets of the Victorian era, popular in Britain and the United States during her lifetime.)

  – “But the child’s sob curses deeper in the silence than the strong man in his wrath!”


Cyrano de Bergerac (Savinien de Cyrano de Bergerac, 6 Mar 1619 – 28 Jul 1655, was a French novelist, playwright, and epistolarian.)

  – “A large nose is the mark of a witty, courteous, affable, generous, and liberal man.”


Michelangelo (Michelangelo di Lodovico Buonarroti Simonim; 6 Mar 1475 – 18 Feb 1564, was an Italian sculptor, painter, architect, and poet of the High Renaissance who exerted an unparalleled influence on the development of Western art, and is considered one of the greatest artists of all time. He is often considered the archetypal Renaissance man, along with his rival and fellow Florentine Medici client, Leonardo da Vinci.)

  – “Genius is eternal patience.”


Monday is pun day:

Q. What did the cannibal say to the cannibal who arrived late for dinner?

A. “Where have you been? Everyone’s eaten.”

  — Remy Sedlmayr, Paradise Valley, AZ  

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

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

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

  – Last Amendment: 24 Feb 2017: 82 FR 11505-11506: Temporary General License: Extension of Validity 

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment:
10 Feb 2017: 82 FR 10434-10440: Inflation Adjustment of Civil Monetary Penalties. 
: 15 CFR Part 30
  – Last Amendment: 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
  – 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.
, 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
  – HTS codes that are not valid for AES are available
  – Latest Amendment: 11 Jan 2017: 82 FR 3168-3170: 2017 Civil Monetary Penalties Inflationary Adjustment
  – The only available fully updated copy (latest edition 6 Mar 2017) of the ITAR is Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III. The BITAR contains all ITAR amendments to date, plus a large Index, over 750 footnotes containing case annotations, practice tips, DDTC guidance, and explanations of errors in the official ITAR text.  Subscribers receive updated copies of the BITAR in Word by email, usually revised within 24 hours after every ITAR amendment.  The BITAR is available by annual subscription from the Full Circle Compliance website.  BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please contact us to receive your discount code.

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* 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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