17-0410 Monday “The Daily Bugle”

17-0410 Monday “Daily Bugle”

Monday, 10 April 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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[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. Council of the EU Publishes Statement Concerning ATT 
  1. Al Jazeera: “How the ‘Dual-Use’ Ruse is Employed to Sell Spyware” 
  2. ST&R Trade Report: “Imports and Exports of Synthetic Cannabinoids Restricted” 
  3. ST&R Trade Report: “Some Export Rules on Hold Due to Regulatory Directives” 
  1. D.M. Edelman: “Recent Raid on Caterpillar Headquarters Underscores Need to Be Wary When Dealing with Syria, Sudan, and Iran” 
  2. J. Vankerckhoven & G. Kreijen: “The Rosneft Judgment: CJEU Upholds and Clarifies Russia sanctions” 
  3. J.H. Fisher II: “Sally Yates was Already Famous for Changing the Focus of Compliance Investigations – The Yates Memorandum” 
  1. Monday List of Ex/Im Job Openings: 96 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 (6 Apr 2017), FACR/OFAC (10 Feb 2017), FTR (15 May 2015), HTSUS (7 Mar 2017), ITAR (11 Jan 2017) 



[No items of interest noted today.]

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

* Industry & Security Bureau; NOTICES; Meetings: Information Systems Technical Advisory Committee [Publication Date: 11 April 2017.]

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Council of the 
EU Publishes Statement Concerning ATT

The Council of EU has published the following statement concerning the Arms Trade Treaty (ATT).
Key EU Messages, Second Informal Preparatory Meeting for the 
Third Conference of States Parties to the Arms Trade Treaty 
Geneva, 7 April 2017
Mr. President,
  (1) At the outset, the EU wishes to commend Ambassador Klaus Korhonen of Finland for the transparent and solid preparatory process of the 3rd Conference of States Parties. We thank Ambassador Korhonen for his continued efforts to promote the universalisation of the Arms Trade Treaty and his proposals to achieve a substantive conference in September.
  (2) The EU welcomes the recent accession of Honduras to the Arms Trade Treaty, bringing the number of States Parties to 92.
  (3) Establishing the highest possible common international standards for regulating the international trade in conventional arms and preventing and eradicating the illicit trade in conventional arms and preventing their diversion is a global ambition. The EU and its Member States continue to support this ambition by all relevant means, especially through the effective implementation of the Arms Trade Treaty.
  (4) The EU welcomes the background paper for a thematic discussion on the relationship between the Sustainable Development Goals and the Arms Trade Treaty prepared by the ATT Secretariat.  We support the idea of exploring how the Arms Trade Treaty could contribute to better achieving the SDGs, especially targets 16.4 and 5.2.
  (5) The 2030 Agenda features strongly on the EU’s agenda and we are committed to playing an active role in international fora to maximize progress towards the SDGs. Gender equality, SDG 5, remains one of our priorities. In this respect, we underline that implementation of Article 7.4 of the ATT can contribute to preventing gender-based violence.
  (6) Preventing the diversion of arms and ammunition, SDG 16,  is another important and relevant topic and we support inclusion of the diversion of arms in the agenda for discussion at the 3rd Conference of States Parties. The need to assess the risk of diversion is one of the eight risk criteria set out in the EU Common Position of 2008 defining common rules governing the control of exports of military technology and equipment of the EU Member States. In line with the Common Position, EU Member States also assess criteria concerning the human rights, including the risk of gender based violence, and violation of the international humanitarian law.
  (7) The EU has provided support for a global reporting mechanism on arms diversion through an ‘iTrace’ project of the Conflict Armament Research, which has documented and traced the provenance of conventional weapons, ammunition, explosive precursors and dual-use items that have been illegally diverted to conflict areas. Consequently, the project provides valuable data that can help agencies tasked with the control of arms transfers to assess the risk of diversion in accordance with Article 11 of the Treaty, ensuring that the ATT will be as effective as possible. In this respect, the EU encourages ATT States Parties to consider ways to exchange information on illicit arms flows and diversion trends.
  (8) The EU Common Position has increased the exchange of information and transparency among EU Member States. The EU also therefore sees merit in exploring the role of transparency in reducing illicit arms flows, as proposed in the Secretariat’s background paper.
  (9) As we are still at an early stage of implementation of this historic Treaty, it will be important to ensure the broad and active involvement of all State Parties and Signatories to contribute to the direction of our future work and benefit from the exchange of information, priorities and experience.  The first Informal Preparatory Meeting, as well as the useful thematic discussions in the three Working Groups on Implementation, Universalisation, Transparency and Reporting, have proved that we are on the right track, and yet more assistance to enable the participation of experts from capitals is required.
  (10) In conclusion, we welcome the progress made and we are ready to engage in further discussions on workplans for the period 2017-2018, appropriate mandates for working groups, and substantive issues that were identified at the working group meetings in February.
Thank you, Mr. President. 

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Al Jazeera: “How the ‘Dual-Use’ Ruse is Employed to Sell Spyware”

Al Jazeera) [Excerpts.]
Sidestepping sanctions can be surprisingly simple. Here’s how it’s done:
Start by manufacturing products with two uses in a single product – what’s known in the industry as “dual-use” technology. 
This includes equipment that can be used as a simple wi-fi router, for example, but which can also be programmed to privately spy on phone calls or internet traffic. 
Then, when it comes time to export, refer to the item simply as a “wi-fi router” and don’t mention that the equipment has other capabilities.
In a four-month undercover operation, Al Jazeera’s Investigative Unit sought to buy such high-powered and heavily restricted spyware on behalf of some of the world’s most notorious regimes, including the Islamic Republic of
Iran and the government of
South Sudan. … 

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ST&R Trade Report: “Imports and Exports of Synthetic Cannabinoids Restricted”

The Drug Enforcement Administration has issued an order that temporarily schedules the following six synthetic cannabinoids, along with their optical, positional, and geometric isomers, salts, and salts of isomers, into schedule I pursuant to the temporary scheduling provisions of the Controlled Substances Act.
  – methyl 2-(1-(5-fluoropentyl)-1H-indazole-3-carboxamido)-3,3-dimethylbutanoate
  – methyl 2-(1-(5-fluoropentyl)-1H-indazole-3-carboxamido)-3-methylbutanoate
  – N-(adamantan-1-yl)-1-(5-fluoropentyl)-1H-indazole-3-carboxamide
  – N-(1-amino-3,3-dimethyl-1-oxobutan-2-yl)-1-(4-fluorobenzyl)-1H-indazole-3-carboxamide
  – methyl 2-(1-(cyclohexylmethyl)-1H-indole-3-carboxamido)-3,3-dimethylbutanoate
  – methyl 2-(1-(4-fluorobenzyl)-1H-indazole-3-carboxamido)-3,3-dimethylbutanoate
As a result, these substances are subject to the regulatory controls and administrative, civil, and criminal sanctions applicable to the manufacture, distribution, reverse distribution, importation, exportation, research, conduct of instructional activities and chemical analysis, and possession of schedule I controlled substances. This order is effective April 10 and will be in effect for two years, with a possible extension of one year, pending completion of the permanent scheduling process.
According to the DEA, available data and information indicate that these substances have a high potential for abuse, no currently accepted medical use in treatment in the U.S., and a lack of accepted safety for use under medical supervision.

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7. ST&R Trade Report: “Some Export Rules on Hold Due to Regulatory Directives”

A revision of the Foreign Trade Regulations is among the Commerce Department rules on hold due to White House efforts to reduce government regulation. Bureau of Industry and Security officials told a recent meeting of the Regulations and Procedures Technical Advisory Committee that DOC agencies are continuing to discuss internally how to implement these efforts.
In March 2016 the Census Bureau issued a
proposed rule that would amend the FTR to reflect new export reporting requirements related to the implementation of the International Trade Data System. It would also add two new data elements in the Automated Export System, the original internal transaction number field and the used electronics indicator. In addition, Census proposed to incorporate into the FTR the revised timeframes for split shipments that were addressed in FTR Letter #6.
However, on Jan. 20 the White House directed federal agencies to freeze new or pending regulations until a senior agency official appointed by President Trump has reviewed and approved them. An executive order issued Jan. 30 further required agencies to eliminate two existing regulations for each new regulation issued and to ensure the costs of the new regulation are offset by eliminating the costs associated with at least two prior regulations. This EO applies only to regulations deemed “significant” and exempts certain types of regulations, including those associated with national security.
BIS officials said a rule finalizing the FTR changes has been delayed in light of these developments. This rule appears to meet the definition of “significant” but officials said they are hopeful it may qualify for one of the exceptions.
In the meantime, BIS officials are continuing to discuss which other rules might be covered by the 2-for-1 and cost accounting requirements and how to comply. Rules to implement changes in the multilateral export control regimes to which the U.S. is a party appear to be significant but could qualify for a national security exemption. Other rules, such as those making changes to the Entity List or Unverified List, are not significant and have been making their way through BIS. Officials are also starting to evaluate which regulations they might be able to eliminate to comply with the 2-for-1 requirement.

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D.M. Edelman: “Recent Raid on Caterpillar Headquarters Underscores Need to Be Wary When Dealing with Syria, Sudan, and Iran”

* Author: Doreen M. Edelman, Esq., Baker Donelson LLP, 202-508-3460,
You may not have heard of the Office of Export Enforcement (OEE), but if you or your subsidiary is doing business abroad, you should take note. Last month, the OEE, which is part of the Department of Commerce’s Bureau for Industry and Security (BIS),
raided the Peoria headquarters of Caterpillar, whose Swiss subsidiary, Caterpillar SARL, is suspected of violating U.S. export control and sanctions laws.
Caterpillar has historically done business with Syria, Sudan, and Iran, all of which are subject to comprehensive economic and trade sanctions and to which exports are severely restricted by U.S. export controls. While foreign subsidiaries of U.S. companies are allowed some leeway to operate in these countries, doing so bears significant risk. As I have written here before, the
jurisdictional reach of both BIS and the Treasury Department’s Office of Foreign Assets Control is considerable. Foreign subsidiaries of U.S. companies are not necessarily out of reach.
As OFAC’s recent
nearly $1.2 billion settlement with Zhongxing Telecommunications Equipment Corporation (ZTE), it is absolutely critical that companies operating abroad implement rigorous compliance programs that include numerous accounting controls and extensive training not only of senior management but also sales representatives. Although violations may unintentionally happen, a rigorous compliance program mitigates the risk. Further, under OFAC and BIS penalty guidelines, such a program is a mitigating factor when assessing penalties.
According to Commerce Secretary Wilbur Ross,
speaking after the ZTE settlements were announced, “We are putting the world on notice: the games are over. Those who flout economic sanctions and export control laws will not go unpunished-they will suffer the harshest of consequences. Under President Trump’s leadership, we will be aggressively enforcing strong trade policies with the dual purpose of protecting American national security and protecting American workers.”
If you have any concerns about your compliance program, now is the time to put those concerns front and center.

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J. Vankerckhoven & G. Kreijen: “The Rosneft Judgment: CJEU Upholds and Clarifies Russia sanctions”

* Authors: Jochen Vankerckhoven, Esq., Loyens & Loeff Brussels,
jochen.vankerckhoven@loyensloeff.com; Gerard Kreijen, Esq., Loyens & Loeff Amsterdam,
gerard.kreijen@loyensloeff.com, +31-(0)20-578-5395.
In a recent judgement of 28 March 2017 (
Case-72/15), involving PJSC Rosneft Oil Company (Rosneft), the Court of Justice of the European Union (CJEU) has ruled on the validity of the EU sanctions against Russia and clarified some important issues concerning the scope of these sanctions. The judgement has drawn attention, because the interpretation and scope of the sanctions has posed difficulties for Western companies as well as EU Member States.
The sanctions in question rest on
EU Council Decision 2014/512 of 31 July 2014 and
Council Regulation (EU) 833/2014 adopted at the same date. The measures impose restrictions on (i) certain financial transactions and the export of sensitive goods and technologies, (ii) the access of certain Russian entities to EU capital markets, and (iii) the provision of services required for certain oil transactions.
Rosneft has been directly affected by the sanctions and had challenged before the UK High their validity in the light of EU law and the validity of the implementing measures that were adopted by the United Kingdom. The UK High Court decided to refer questions to the CJEU for a preliminary ruling.
Legal Certainty
One of these was the fundamental question whether it is contrary to the principles of legal certainty and nulla poena (no penalty without a law) for a Member State to impose criminal penalties before the scope of the relevant offense has been sufficiently clarified by the CJEU. Rosneft had argued that the fact that certain provisions of Regulation 833/2014 are not clear and precise means that individuals are not in a position to ascertain unequivocally what their rights and obligations are. The ECJ inter alia observed that the expressions which Rosneft claimed to be unclear are general in nature and that since legislation must be of a general application its wording cannot be absolutely precise. It concluded that the fact that the terms used in Regulation 833/2014 may be subject to clarification, gradually and subsequently, by the ECJ does not prevent a Member State from establishing penalties on the basis of the regulation in order to ensure its effective implementation.
Financial Assistance
Another important question concerned the meaning of the term ‘financial assistance’ in Article 4(3) of Regulation 833/2014, which may trigger prior authorization if the assistance relates to the sale, supply, transfer or export of listed equipment for the Russian oil sector. In their respective guidance on the Russia sanctions the EU Commission and the UK government have interpreted the term broadly to include payment services. This view was rejected by the CJEU which held that financial assistance, ‘does not include the processing of a payment, as such, by a bank or other financial institution’. The CJEU took into account the underlying purpose of the provision and found in this respect that the regulation only intends to restrict financial assistance comparable to loans, credits or export credit insurance, and not intermediary payment services as these do not touch the funds of a bank. If the EU had intended to restrict fund transfers it would have used a different term according to the CJEU.
Transferable Securities
A third question concerned transferable securities and sought to ascertain whether Article 5 of Regulation 833/2014 prohibits the issuing of Global Depositary Receipts (GDRs) issued on or after 12 September 2014 under a deposit agreement with a targeted entity (including Rosneft) in respect of shares in such an entity which were issued before 12 September 2014. The CJEU answered this question in the affirmative having noted (i) that transferable securities pursuant to the definition used in the regulation include depositary receipts and (ii) that it is plain that Article 5 prohibits the issuance, after 12 September 2014, of GDRs in respect of the shares of a targeted entity irrespective of the date of issue of those shares. The CJEU convincingly rejected Rosneft’s argument that such an interpretation essentially affects the shareholders of the targeted entities (listed in Annex VI) which is at odds with the objective pursued by Regulation 833/2014, notably to apply pressure on the Russian Federation by restricting the capacity of the targeted entities to raise capital. The CJEU considered that ‘restrictive measures, in so far as they affect a company, are inherently liable to have a negative effect on the interests of that company’s shareholders’. Rosneft’s argument, the CJEU added, was wholly unfounded since the object of the restrictive measures is precisely to increase the cost for the Russian Federation, which is Rosneft’s majority shareholder.

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J.H. Fisher II: “Sally Yates was Already Famous for Changing the Focus of Compliance Investigations – The Yates Memorandum”

* Author: John H. Fisher II, Esq.,
jfisher@ruderware.com, Ruder Ware LLSC.
By now the whole world knows about Sally Yates.  We are likely to see a lot more of her as a central figure in Congressional investigations.  For some of us who deal with compliance investigations, Sally Yates was famous long before her refusal to defend the immigration ban.  She was the author of the famous “Yates Memorandum” that changed the focus of corporate investigations to require investigation of potential individual wrongdoing in order to receive cooperation credit from Federal prosecutors.
The Yates Memo directs federal prosecutors, as well as civil attorneys investigating corporate wrongdoing, to maintain a focus on responsible individuals, recognizing that holding them accountable is an important part of protecting the public in the long term.  In fact, prosecutors are directed to first look at potential individual wrongdoing when investigating a case.  The new policy requires companies facing potential Federal civil and criminal charges to investigate individual wrongdoing and report it to the government in order to receive government cooperation credit.  The new federal policy applies to all federal criminal and civil prosecutions in all industries.
The Yates Memo is the most recent in a line of actions by Federal prosecutors that began in the late 1990s that have increased the focus on seeking accountability from the individuals who perpetrate wrongdoing.  The Yates Memo resulted in an update to the U.S. Attorney’s Manual (“USAM”) provisions covering Principles of Federal Prosecution of Business Organizations (USAM § 9-28.000).  Inclusion of principles into the USAM means the concepts in the Yates Memo are now operational and are required to be integrated into the prosecutorial decision making process across the country.
Six General Principles of the Yates Memorandum:
  – Principle 1:  “To be eligible for any cooperation credit, corporations must provide the Department all relevant facts about the individuals involved in corporate misconduct.”
  – Principle 2:  “Both criminal and civil corporate investigations should focus on individuals from the inception of the investigation.”
  – Principle 3:  “Criminal and civil attorneys handling corporate investigations should be in routine communication with one another.”
  – Principle 4:  “Absent extraordinary circumstances, no corporate resolution will provide protection from criminal or civil liability for any individuals.”
  – Principle 5:  “Corporate cases should not be resolved without a clear plan to resolve related individual cases before the statute of limitations expires and declinations as to individuals in such cases must be memorialized.”
  – Principle 6:  “Civil Attorneys should consistently focus on individuals as well as the company and evaluate whether to bring suit against an individual based on considerations beyond that individual’s ability to pay.”

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MS_a111. Monday List of Ex/Im Job Openings: 96 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:

* Aerojet Rocketdyne; Huntsville AL; 
Specialist, International Trade & Compliance
; Requisition ID: 11972

* 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;
NA Compliance Analyst
; Requisition ID: 256357

* Amazon; Seattle WA;
Senior Compliance Manager, Global Trade Compliance
; Requisition ID: 486942

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

* Amazon; Tokyo, Japan;
Trade Compliance Specialist
; Requisition ID: 481891

# Advanced Micro Devices (AMD); Austin TX;
Import/Export Compliance Manager; Requisition ID: 24061

* American Science & Engineering; Billerica MA;
Sr. Trade Compliance Analyst
Requisition ID: 10799

* Barnes Group Inc.,; Bristol CT and Windsor CT;
Counsel & Director of Trade Compliance, Government Contracts Program; Requisition ID: 2200-271

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

# Bemis Company; Neenah WI;
Director – Global Trade Compliance
; Requisition ID: REQ_13735
# Berry Plastics Corporation; Evansville IN;
International Trade Compliance Administrator
; Requisition ID: 4054

* Biogen; Cambridge MA;
Trade Compliance Specialist
; Requisition ID: 30956BR

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

# CSL Behring; King of Prussia PN;
Global Trade Compliance Senior Analyst
; Requisition ID: R-038869

# Danaher; Wash DC (Other locations possible);
Global Trade Compliance Manager; Requisition ID: DAN000510

* DB Schenker (2 positions); Atlanta GA, and Long Beach CA;
Area Customs Director
; Requisition ID: 17P009

* Elbit Systems; Forth Worth TX or Merrimack NH;
Import Compliance Manager
; Requisition ID: 017-4965

* Erickson Inc.; Portland OR;
Trade Compliance Manager
Joanna Rafiner-Jarboe
; Requisition 2017-2267

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

* Expeditors; Sunnyvale CA;
Customs Compliance Specialist
* Export Solutions Inc.; Melbourne FL; Trade Compliance Specialist;

* FD Associates, Tysons Corner VA;
Senior Export Compliance Associate

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

FLIR; Billerica MA; 
Sr. Defense Trade Licensing & Compliance Analyst
; Requisition ID: 8008

* General Dynamics Information Technology; Falls Church VA;
Principal Contracts Administrator – Export Compliance Coordinator
; Requisition ID: 2017-21288

* General Dynamics; South Wales, UK;
Senior Trade Compliance Officer
; Requisition ID: 6079
* Givaudan; Bogor, Indonesia;
Compliance Manager
; Requisition ID: 68063

* The Hershey Company; Hershey PA;
Global Customs and Trade Analyst
* Infinera Corporation; Sunnyvale CA;
Director, Global Logistics and Trade Compliance
; Requisition ID: 2016840

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; Monroe NC;
Shipping Logistics Coordinator; Requisition ID: 1710087

* Lam Research Corporation; Fremont CA;
Foreign Trade Intern 1

* Lam Research Corporation; Shanghai, China;
Foreign Trade Analyst 

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

* L-3 Technologies; Arlington VA;
Sr. Mgr. Corporate Customs Compliance
; Requisition ID: 087862

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

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

* Meggitt PLC; Maidenhead, UK;
Trade Compliance Officer 

* Meggit-USA, Inc.; Simi Valley CA;
Trade Compliance Administrator
; Requisition ID: 25172

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

* Netflix; Los Gatos CA;
Global Export Compliance Manager

* 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 Sperry Marine; New Malden, UK;
Trade Compliance Coordinator
* Pall Corporation; Portsmouth, UK;
Trade Compliance Specialist
; Requisition ID: SHA000201

* Panduit; Tinley Park IL;
Global Trade Compliance Agent
; Requisition ID: PAND-03297

* Parexel; Billerica MA;
Vice President, Chief Compliance Officer; Requisition ID: pare-00024091

* Parexel; Kiev, Ukraine;
Global Trade Compliance Specialist
; Requisition ID: pare-10056329

* Plexus Corporation; Neenah Wi;
Manager – Export Compliance
; Requisition ID: 14645BR
* Plexus Corporation; Neenah Wi;
Manager – Import Compliance
; Requisition ID: 14593BR

* Roanoke Insurance Group; Schaumburg IL;
Carnet Service Representative
; Requisition ID: 1019

* Raytheon; Andover MA and Woburn MA;
Manager of Export Import Control, Empowered Officials
; Requisition ID: 93622

* Raytheon; Arlington VA;
Export Licensing Manager I
; Requisition ID: 94113BR

* Raytheon Australia; Canberra, Australia;
Export/Import Operations Advisor; Requisition ID: 86438BR

* Raytheon; Fullerton CA;
Manager of Export-Import Control, Empowered Official (RCCS); Requisition ID: 93625BR

* Raytheon; McKinney TX;
Counsel Global Trade Compliance
; Requisition ID: 94826BR

* Raytheon; Portsmouth RI;
Manager of Export Import Control, Empowered Official
; Requisition ID: 93628

* Raytheon; Rosslyn VA;
Customs Counsel; Requisition ID: 93887BR

* Raytheon; Woburn MA;
Supply Chain Compliance Manager; Requisition ID: 93734BR

* Raytheon; Woburn MA;
Supply Chain Subcontract Manager; Requisition ID: 93615BR

* Raytheon Integrated Defense Systems; Andover MA;
Export Licensing & Compliance Advisor, Global Trade; Requisition ID: 93670BR

* Raytheon Integrated Defense Systems; Woburn MA;
Training Manager, IDS Global Trade Compliance; Requisition ID: 93597BR

* Raytheon Intelligence, Information and Services; Annapolis Junction MD or Dulles VA;
Sr Exp License&Compliance Adv; Requisition ID: 91338BR

* Raytheon Intelligence, Information and Services; Orlando FL;
Sr Exp License&Compliance Adv; Requisition ID: 92852BR

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

* Synopsys; Mountain View CA;
Senior Manager, Export Compliance
650-584-1676; Requisition ID: 13208BR
* Talbots; Hingham MA;
Sr Mgr Global Trade & Customs Compliance
; Requisition ID: 1077
* Talbots; Lakeville MA;
Dir., Global Logistics & Customs Com
; Requisition ID: 1085

* Tesla Motors; Fremont CA;
Global Supply Manager – Logistics
; Requisition ID: 38153

* Thales Defense and Security, Inc.; Clarksburg MD; Manager Trade Compliance
; William.Denning@thalesdsi.com; Requisition ID: 2592

* 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
Intern, International Trade Compliance
; Requisition ID: 45442BR

* 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, Otis; Farmington CT;
Senior International Trade Compliance Counsel
; Requisition ID: 38518BR

* United Technologies Corporation, Otis; Farmington, CT;
International Trade Compliance (ITC) Program Manager
; Requisition ID: 44984BR

# United Technologies Corporation, UTC Aerospace Systems; Santa Fe Springs CA;
Sr. Analyst, International Trade Compliance
; Requisition ID: 46184BR

* United Technologies Corporation, UTC Aerospace Systems; Troy OH;
Sr. Manager, Intl Trade Compliance
; Requisition ID: 44065BR 

* United Technologies Corporation, UTC Aerospace Systems; Vergennes, VT;

ITC Generalist
; Requisition ID:
* United Technologies Corporation, UTC Aerospace Systems; Westford MA;
Senior Analyst, International Trade Compliance
; Requisition ID: 31576BR
* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks, CT;
IT Export & Compliance Intern
; Requisition ID: 42148BR
* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks, CT; 
Spec, Intl Trade Compl
; Requisition ID: 44177BBR

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

* Wurth Industry of North America; Indianapolis IN; Trade Compliance Officer;
International Trade Compliance Officer
; Requisition ID: 389-720
* Wurth Snider Bolt and Screw; Louisville KY; 
Trade Compliance Specialist
; Sylvia Smith,
; Requisition ID: 1124

* XPO Logistics; Greenwich CT;
Global Trade Compliance Analyst

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(Source: Editor) 

Tom Lehrer (Thomas Andrew Lehrer, born April 9, 1928, is a retired American singer-songwriter, satirist, and mathematician. He has lectured on mathematics and musical theater. He is best known for the pithy, humorous songs he recorded in the 1950s and ’60s.)
  – “I feel that if a person has problems communicating, the very least he can do is to shut up.”
Clare Boothe Luce (10 Mar 1903 – 9 Oct 1987, was an American author, politician, U.S. Ambassador, and public conservative figure. She was the first American woman appointed to a major ambassadorial post abroad. A versatile author, she is best known for her 1936 hit play,
The Women,
 which had an all-female cast. She was the wife of Henry Luce, publisher of Time, Life, Fortune, and Sports Illustrated.)
 – “No good deed goes unpunished.”
Monday is pun day.
* Yesterday a clown held a door open for me.  I thought it was a nice jester.
* Don’t try to spell “part” backwards. It’s a trap!
* How did I escape from Iraq?  Iran.

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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: 6 Apr 2017: 82 FR 16730-16733: Revisions to the Unverified List (UVL)

: 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: 7 Mar 2017: Harmonized System Update 1702, containing 1,754 ABI records and 360 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 8 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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