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17-0605 Monday “The Daily Bugle”

17-0605 Monday “Daily Bugle”

Monday, 5 June 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. DHS/CBP Posts Update Concerning ACE FTZ CATAIR 
  4. DHS/CBP Posts Recap of 2017 West Coast Trade Symposium 
  5. State/DDTC: (No new postings.) 
  6. Canada GA Seeks Comments on NAFTA 
  1. Expeditors News: “Canadian Senate Ratifies Canada-European Union Trade Agreement” 
  1. J.E. Bartlett: “How to Handle a Hostile Audience — Tips for Corporate Compliance Trainers” 
  2. W. Shahid, R. Cook & R. Giambalvo: “Evaluating an Export Compliance Program: Defining Key Performance Indicators” 
  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 (26 May 2017), FACR/OFAC (10 Feb 2017), FTR (19 Apr 2017), HTSUS (7 Mar 2017), ITAR (11 Jan 2017) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

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

OGSOTHER GOVERNMENT SOURCES

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

* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 6 June 2017.]

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

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

 

(Source:
CSMS #17-000328, 5 June 2017.)
 

CBP has updated the format of the Foreign Trade Zone (FTZ) CATAIR to allow user to navigate more quickly. There were no changes to the content of FTZ CATAIR and therefore trade will not be impacted. However, batch and block control records will need to be updated to align with the ACE format. 

CBP will begin testing in the Cert environment in the end of July and deploy to Production in the end of August. To view the updated FTZ CATAIR click here, select “Chapters: Drafts For Future Capabilities” and select Foreign Trade Zone. 

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

(Source:
DHS/CBP) [Excerpts.]
 
Partnerships between the U.S. government and private sector were the theme of this year’s U.S. Customs and Border Protection 2017 West Coast Trade Symposium. The two-day panel and breakout sessions convened in Scottsdale Arizona, and focused on “looking ahead together” as we write a story of continuity.
 
The CBP trade symposium opened with a series of questions between recently nominated Acting Commissioner Kevin McAleenan and Vincent Iacopella, Executive Vice President Growth and Strategy, Alba Wheels Up International Inc. The on-stage interview touched on many of the agency’s top trade priorities: reducing supply chain barriers without slowing down the facilitation, leveraging new technologies such as unique identifiers and block chain to assist with risk-management, as well as CBP’s recent engagement with Mexico and Canada on harmonizing the North America Single Window. …
 
[Editor’s Note: More on the topics discussed at the 2017 West Coast Trade Symposium can be found here.]

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

OGS_a55. State/DDTC: (No new postings.)
(Source: State/DDTC)

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

OGS_a66. Canada GA Seeks Comments on NAFTA
(Source: Canada GA)
 
Canada is committed to a progressive trade agenda that creates jobs and opportunities for the middle class and those working hard to join it. 
 
The input of Canadians is essential when considering trade agreements, and the Honourable Chrystia Freeland, Minister of Foreign Affairs, today announced expanded, online consultations with Canadians on the renegotiation of the North American Free Trade Agreement (NAFTA). 
 
The consultations are an important next step toward the renegotiation process. The views gathered from Canadians will inform the federal government’s approach as we engage with the United States and Mexico.
 
In recent months, the Minister and her colleagues have been listening to Canadians from across the country and from all sectors and backgrounds. 
 
The government is steadfastly committed to free trade in the North American region and ensuring that the benefits of trade are enjoyed by all Canadians. 
 
We want to hear from Canadians, and we invite them to share their ideas, experiences and priorities on the modernization of NAFTA by visiting: www.international.gc.ca/nafta.

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

NWSNEWS

 
On 11 May 2017 the Canadian Senate’s standing committee ratified the Canada-European Union Comprehensive Economic Trade Agreement (CETA). Though not confirmed at this time, the implementation date is tentatively scheduled for July 1st, coinciding with Canada Day.
 
To qualify for the CETA trade agreement, products must be deemed originating. Qualifying products will be subject to a zero rate of duty.
 
Additionally, CETA will:
 
  – Increase duty-free tariffs between Canada and the EU
  – Provide favorable Rules of Origin
  – Simplify Customs and Trade Facilitation
  – Protect Workers Rights’ and the Environment
 
An outline of CETA issued by the Canadian Government can be accessed here.
 
Additional information on the Rules of Origin under CETA can be accessed here.
* * * * * * * * * * * * * * * * * * * *

COMMCOMMENTARY

COMM_a01
8
. J.E. Bartlett: “How to Handle a Hostile Audience — Tips for Corporate Compliance Trainers”

(Source: Author) (Outline of remarks delivered to Partnering for Compliance, Orlando, Mar 2017)

* Author: James E. Bartlett III, Partner, Full Circle Compliance,
JEBartlett@JEBartlett.com
, 202-802-0646


I.  Introduction   


These tips are for corporate and government agency compliance trainers who train for trade controls, ethics, sexual harassment, or other compliance training employees are required to attend.  Employees often come with a bad attitude because they don’t want to be there.  Ever heard any of these remarks muttered?



  – “I’m too busy for this.”


  – “This is going to be a waste of my time.”


  – “We’ve already covered this stuff.”


  – “Can’t you just summarize this in 20 minutes?”

But your audience may become interested in your presentation if you can convince them that.


  – This stuff is important.  Even CEOs, VPs, and senior military officers get fired and sometimes go to jail for breaking these rules.


  – They may win business or improve profits based on what they learn today.


  – They may get answers to questions they’ve wondered about.


  – You will not waste their valuable time.

II. Rules for Smooth Presentations – Summary:

  – Prepare thoroughly.  
  – Get support from the highest level of management.
  – Look sharp.
  – Start on time. 
  – Take charge of the room.
  – Don’t try to be funny.
  – Teach the regulations, not morals or philosophy.
  – Answer the hardest questions before they are asked.
  – If you don’t know the answer, admit it.  
  – End a few minutes early, especially if you will be followed by another speaker.
  – Stay afterwards for questions.

          

III. Before the Lecture

  – Get support from the highest level of management available.  Arrange to be introduced by their boss or other respected senior executive.  Never walk into a room and try to get the audience’s attention by yourself.  (“Okay, everybody . can we please get started?”)  That indicates that you are a person of little consequence.  Important persons are introduced.  Prepare your introduction on an index card for your host to read.
     — And if you are the host, always give the speaker a warm introduction including his or her qualifications, to increase the speaker’s credibility.  Don’t just say: “The speaker’s bios are in the hand-out materials.”
  – Know your subject.  Don’t talk from someone else’s slides.  If you don’t have time to fully prepare, decline the invitation.  Don’t force attendees to listen to someone who is not prepared.
  – Tailor your presentation to your audience.
     — If it’s an intro lecture, keep it simple.  Define all acronyms and hand out acronym definitions.
     — For senior officers and managers, emphasize business consequences of good and bad compliance practices, listing recent major penalties.
     — For engineers, concentrate on technical definitions and exemptions.
     — For contracts and procurement employees, emphasize the need to plan far ahead for the time needed to obtain permits and licenses, and to budget for compliance costs.
     — Don’t bore people by telling them how to apply for permits and licenses unless that will be their responsibility.  Managers need to know when a license is necessary, but not how to fill out an application.
  – Prepare readable slides.  Why do so many speakers use slides with tiny print that can’t be read past the first row?  Slides must be readable from the back of the room.  The fewer words per slide, the better.  And don’t overdue those cute cartoons and action graphics — they may become distracting.
  – Solicit questions in advance.  It stimulates interest and lessens the chance that you will be surprised by questions you can’t answer.
  – Check out the room before your presentation.
     — Is everything arranged?  Does all the equipment work?  Try the remote slide clicker.  Don’t make the audience wait while the tech assistant teaches you how to use the equipment.
     — Test the mike. Ask for a wireless mike or cord long enough to walk into audience and get questions.  
     — Need to change seating?  There’s nothing like standing on a stage of a nearly empty room trying to talk to people on the back three rows.  Remove chairs or rope off back rows if the room will not be full.

                   

IV.  The day of the lecture  

  – Look sharp.  Don’t dress like the guys who set up the chairs.
  – Get there early.  
     — Nobody will accept your lame apology for being late because “the traffic was really heavy this morning!”  
     — If you are a morning speaker, stay overnight in the conference hotel or within walking distance.
     — Test all the equipment again.
     — Put a glass of water nearby.
  – Chat with members of the audience before the event.  What kind of work they do?  Why are they attending this lecture?  What questions will they have?  It helps you focus your remarks.
  – Distribute copies of your slides.  
     (There are differing opinions on this point.  Some lecturers prefer to distribute copies of slides after their lecture to avoid the distraction of people flipping through the future slides.  Give out advance copies of presentations heavy in regulations so people can make notes.  If you are discussing basic principles or using pop-quizzes with answers on following slides, it may be best to hand out copies after your presentation.)

                   

V. The Lecture    

  – Start on time and end a little early.  Speakers rarely do that, and your audience will be grateful.


     — Ask someone on the front row to warn you as time gets short.


     — Say you’ll stay to answer questions during the break.


  – Take charge!


     — Don’t wait politely for everyone to get coffee and sit down.


     — Say, “I don’t want to penalize those of you who are here on time, so I’m going to start. Latecomers will miss some of my best material, but let’s begin!”  


     — Ask for the doors to be closed to avoid distracting noise from the lobby.


  – Don’t ever apologize for lack of preparation or put yourself down. 


     — Never say you are the “stuckee” forced to give this training. 


     — If your audience senses that you are unprepared, you’ve lost them.  They will resent you for wasting their time.


  – Get out from behind the lectern.  (Vocabulary note: A lecturn is what you stand behind, where you put your notes.  A podium is the raised platform you stand on.)


     — Unless you are unable, stand while speaking.  It shows respect for the audience.


     — Don’t talk while seated at a table unless you are part of a panel and other panelists do the same.


     — Walk around with the microphone so people can ask questions that everyone will hear.


  – Take questions throughout your presentation unless you are speaking to a large audience.


     — If you make them wait until the end, you may run out of time, or they may forget their questions.


     — But watch the time and defer questions if necessary to complete your presentation on time.


     — If asked a question you can’t answer, admit it, and say you will get the answer after the presentation.  


     — If someone asks a long, complicated set of facts related to his company that nobody else cares about, interrupt early and say, “I’ll need more information to answer that question, so let’s discuss it during the break. Then change the subject. 


  – Don’t try to be funny.


     — Be friendly, but don’t try to be a comedian.  Let your natural humor come out, but don’t try to “tell jokes.”   


     — It may be viewed as overly familiar, and familiarity breeds contempt.


     — Many will be silently suffering what they think is a waste of time, so don’t further abuse it with lame jokes and cartoons.


     — “We never respect those who amuse us, however we may smile at their comic powers.” – Marguerite Gardiner, Countess of Blessington

VI.  At the end of your presentation:

  – Tell the audience you will be available later for questions.
  – Get out of the way quickly if you are followed by another speaker.  Go outside if people want to talk with you.
  – Make sure the room is put back in order and equipment is returned.
  – Read the evaluations and contact people who have questions.
  – Modify your presentation for future use while it is still fresh in your mind.
  – Write a note of appreciation to your host or the person who set things up.

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

 
* Authors: Waqas Shahid, Esq., waqas.shahid@ankuraconsulting.com, 646-291-8546;
Randy Cook, Esq., randy.cook@ankuraconsulting.com, 646-291-8545; and Rosanne Giambalvo, Esq., rosanne.giambalvo@ankuraconsulting.com, 646-291-8575.  All of Ankura Consulting.
 
Systematic compliance program evaluations are an important part in the life cycle of any compliance program. Not only do they improve program effectiveness and efficiency, but if problems arise, they also show government enforcement agencies that you are serious about compliance. In fact, the US Department of Justice has recently emphasized the importance of information gathering and analysis to show that a compliance program is effective.
 
The basic performance evaluation process involves several steps. Of course, you need to know your business and understand the systems through which transactions occur (including those related to compliance). But appropriately evaluating the health of your program involves going a step further and defining exactly what you want to measure by setting up key performance indicators (KPIs) and metrics for monitoring performance. Creating KPIs allows you to gather appropriate data for analysis, which in turn provides the best insight on how to enhance your compliance program to better address your company’s unique characteristics, risks, and objectives.
 
UNDERSTAND YOUR BUSINESS
 
Understanding your business is an important first step in creating effective KPIs. A formal self-assessment of your systems and processes is a great way to get a clear picture of the current state of affairs and should focus not only on your company’s operations, but also on your company’s compliance efforts.

For instance, if you want to assess your company’s compliance with export controls, find out (if you do not already know) what goods you manufacture; your geographic footprint (in terms of business sites, engineering and manufacturing centers, customer locations, and infrastructure); what drives your transactions (e.g., customer requests, local agents, or company marketing efforts); your company’s strategic objectives; the regulatory frameworks that apply to your export activities (both in the US and abroad); and the touchpoints where your company’s activities implicate these regulatory regimes. From the compliance perspective, you should also learn about the processes and systems your company already has in place to comply with export controls requirements, how they are working, and how they compare to industry standards regarding export controls compliance. Armed with a thorough understanding of your business, you are now (almost) ready to start defining your KPIs.
 
DEFINE SPECIFIC KPIS BASED ON YOUR COMPANY’S RISK PROFILE AND GOALS
 
The truth of the matter is, you cannot know everything, and you cannot measure everything either. To avoid “death by data,” any performance evaluation needs to have a defined scope of analysis. In other words, based on your understanding of your business goals and risk profile (through a formal self-assessment or otherwise), determine which issues are most important to monitor and articulate KPIs against those issues.
 
Every business is unique, which is why a self-assessment exercise is so critical to defining the issues your company should examine. In addition, every company defines “success” differently when it comes to compliance. For example, you could view success as actual adherence to your compliance program and the law, as mitigating risk, as proactively addressing business imperatives, or as some combination of these factors. Your company’s history of regulatory or compliance problems should also inform your focus, as should your knowledge of areas known to present “weak links” in your operations and compliance program.
 
DECIDE WHAT QUESTIONS TO ASK
 
Once you have decided where to focus your efforts, make a list of questions for each issue area that will help you understand how your company is performing in each area. For example, you might want to consider the following issue areas and questions (among others) when assessing the performance of your export controls compliance program:
 
Below are example issue areas to assess with related KPI questions:
 
Ability of the Company to Manage Export Compliance
  – How many export compliance professionals does the company have?
  – How many export authorizations does the company currently hold?
  – What is the quarterly growth?
  – Which specific functions or programs do they support?
 
Timely Execution of Export Requests
  – In the last quarter, what percentage of export requests were reviewed and approved within 5 days of request?
 
Regulatory Compliance Performance
  – What percentage of agreement management notices last quarter were sent to DDTC on time?
  – What percentage of name/address change amendments were executed and submitted on time?
  – How many export violations were reported last year?
  – How many reported export violations involved repeat offenders?
 
Compliance Awareness and Knowledge
  – What percentage of the workforce is certified as an export liaison?
  – What percentage of the workforce is trained on ITAR/EAR?
  – What is the distribution of these among different business units?
 
Operational Risk
  – Who are the top three export reviewers in the company and what percentage of exports are they reviewing?
  – What is the export activity to export resources ratio of different business units?
 
Regulatory Risk
  – How many ITAR-controlled items did the company export to France last month?
  – What percentage of the company’s exports are highly controlled?
  – Where are exports of ITAR products going?
 
CREATE A SCORECARD
 
Once you have defined what you want to measure – and what questions to ask in these issue areas – create a scorecard for assessing performance of these measures. To structure the scorecard, start with the qualitative description of what you want to measure, translate that into one or a set of metrics, and finally, assign performance targets for those metrics.
 
For example, if Company A wants to assess the timeliness of its export request review and approval process, it might consider the following metrics to examine the efficiency of its export request approval process:
 
KPI 1 TIMELINESS OF EXPORT REQUEST REVIEW AND APPROVAL
 
Metric 1
: In the last quarter, what percentage of export requests were reviewed and approved within 5 days of request?

* Compliance levels:
  – >90%:  On track; no further work needed at this time
  – 60-90%:  Some attention needed in this area
  – <60%:  Needs immediate attention
 
Metric 2
: In the last quarter, what was the average time (in days) to approve an export request?

* Compliance levels:
  – < 3 days:  On track; no further work needed at this time
  – > 3 but < 5 days:  Some attention needed in this area
  – > 5 days:  Needs immediate attention
 
Once you understand your company and have a list of KPIs based on your company’s unique characteristics, you can gather data for each KPI and evaluate that data to determine if you need to adjust your company’s compliance program.
 
For example, going to the KPI above, if you find that a low percentage of export requests are being reviewed and approved within five days, you can ask further questions to get to the heart of the matter. For example, where is the bottleneck in this approval process, and why is it occurring? Is it due to resource issues, such as a lack of appropriately trained personnel to review the requests? Or is it perhaps due to the number of high-risk reviews needed, which reflects on the nature of the company’s risk profile? The answers to these questions will help the company determine what processes and mechanisms it can implement to overcome the identified problem.
 
In short, knowing where you stand with compliance requires knowing your business, understanding your risks, and then engaging in a systematic analysis that relies on real data about your company’s performance in specifically identified areas. Not only does engaging in this process help you perform better where compliance is concerned, but it also creates an important record for the future.
* * * * * * * * * * * * * * * * * * * *

MSEX/IM MOVERS & SHAKERS

MS_a110. 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 jobs@fullcirclecompliance.eu.
 
COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFO; REQ ID
 
#” New listing this week:
 
* Abcam; Cambridge, United Kingdom;
Trade Compliance Coordinator; Requisition ID: CAM-012-996


Akin Gump Strauss Hauer & Feld LLP; Washington DC; 
International Trade and Customs Specialist
; 
staffrecruiter@akingump.com
; Requisition ID: 147

* Amazon; Mexico City, Mexico; Mexico Trade Compliance Program Manager; Requisition ID: 520481

* Amazon; Mexico City, Mexico;
Senior Manager, Mexico Trade Compliance
; Requisition ID: 520460

* Amazon; Seattle WA; NA Compliance Analyst; Requisition ID: 256357

* 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

* Ansell; Iselin NJ;
Senior Specialist NA Trade Compliance; Requisition ID: IRC6513
* Applied Materials; Alzenau, Germany;
Europe Trade Manager
; Requisition ID: (M3)-1701376

* ASML; Veldhoven, the Netherlands;
Senior Manager Trade & Customs;
Requisition ID: RC05619
* Babcock; Portsmouth, United Kingdom; 
Divisional Trade & Compliance Manager

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

* Boeing; Sydney, Australia, and other locations;
Global Trade Control Manager; Requisition ID: 1700006067

* Boeing; Amsterdam, The Netherlands, and Brussels, Belgium;


Trade Control Specialist
; Requisition ID: 1700006121

* Brunswick Corporation; Lake Forest IL;
Trade Compliance Auditor
; Becky Longrie, 847-735-4755,
becky.longrie@brunswick.com
; Requisition ID: 22999

* Cobham Advanced Electronic Solutions; Exeter, NH, Plainview, NY, Eatontown, NJ, or Lansdale, PA;
Export Compliance Manager
; Charles Trokey
Charles.trokey@yoh.com

* CSRA Inc.; Falls Church VA;
Global Trade & Compliance Principal
; Alan Strober 571-375-4890; Requisition ID: 17002RN

* 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
;
Crystal.Adair@dbschenker.com
; Requisition ID: 17P009

* Eaton; Titchfield, United Kingdom;
Global Trade Manager (Trade Compliance); Requisition ID: 020681

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

* Expeditors; Sunnyvale CA;
Customs Compliance Specialist
* Export Solutions Inc.; Melbourne FL; Trade Compliance Specialist;
info@exportsolutionsinc.com

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

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

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

* Fluke: Everett WA; 
Trade Compliance Manager
; Requisition ID: FLU005544

* General Atomics Aeronautical Systems, Inc.; San Diego CA; 


International Trade Compliance Analyst (ITC) / Export Import Specialist / Global Trade Administrator
; Requisition ID: 12252BR

* General Dynamics Information Technology; Falls Church VA;
Division Export Compliance Coordinator
;
Kara.Reynolds@gdit.com
; Requisition ID: 2017-21288

* George Washington University; Washington DC;
Research Compliance Officer, Export Control; Requisition ID: PI97906765

* Givaudan; Bogor, Indonesia;
Compliance Manager
; Requisition ID: 68063
* Harris Corporation; Clifton NJ; 
Trade Compliance Analyst

lsolomon@harris.com
; Requisition ID: ES20172404-18675

* KPMG; Antwerp, Brussels;
Manager Global Trade & Customs – SAP GTS
; 122756BR

* 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
#
Livingston International; Western Region (TX, CA, OR, WA preferred)
;

Trade Ad
visory
Consu
ltant

#
Livingston International; Western Region (TX, CA, OR, WA preferred);
Research Consultant

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

* L-3 Technologies, Platform Integration Division; Waco TX;
 
Import/Export Compliance Administrator 3
; Requisition ID 
089343

* Lockheed Martin; Orlando FL;
International Trade Compliance Sr Staff / ITAR / EAR / Export Control Officer
; Requisition ID: 387435BR

* Mars – Wrigley; Chicago IL; 
Global Trade Compliance Analyst (Corporate Export)
;
Ryan.Martin@effem.com
; Requisition ID: 69452

* Maxim Integrated; Dallas TX;
Manager, Global Trade
; 3304BR

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

* Medtronic; Wash DC;
Global Trade Lawyer
;
stacy.m.johnson@medtronic.com
; Requisition ID: 170002ON

* Meggitt PLC; Maidenhead, UK;
Trade Compliance Officer 

* Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 2
; Requisition ID: 17010105

* Northrop Grumman Corporation; Herndon VA;
International Trade Compliance Analyst 3/4; Requisition ID: 17001180

* Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 1
; 17003433
* Northrop Grumman Corporation; Linthicum MD;
International Trade Compliance Analyst 3
; 17005262

* Northrop Grumman Sperry Marine; New Malden, UK;
Trade Compliance Coordinator
;
careers.uk@sperry.ngc.com

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

* Plexus Corporation; Neenah Wi;
Manager – Export Compliance
; Requisition ID: 14645BR
* Plexus Corporation; Neenah Wi;
Manager – Import Compliance
; Requisition ID: 14593BR
* Premier Farnell Organisation; Leeds, UK;
Trade Compliance Specialist – Europe
; 4301

* 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, Intelligence, Information and Services Business Unit; Dulles VA,
Sr. Advisor Export Licensing and Compliance, Requisition ID: 97752BR

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

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

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

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

* Saab Defense and Security USA LLC; Syracuse NY;
Senior Import/Export Analyst
; Requisition ID: USA_00413
* SABIC; Houston TX;
Analyst Import/Export Compliance
;
danielle.cannata@sabic.com
; Requisition ID: 7792BR

* SIRE: Noord-Brabant province, the Netherlands;
Trade Compliance Expert; Requisition ID: 33934

* Talbots; Hingham MA;
Sr Mgr Global Trade & Customs Compliance
; Requisition ID: 1077
* Talbots; Lakeville MA;
Dir., Global Logistics & Customs Com
; Requisition ID: 1085

* Teledyne Microwave Solutions; Mountain View CA;
 


Trade Compliance Administrator 2
; Requisition ID: 2017-4111

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

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

* ThermoFisher Scientific; Breda, the Netherlands;
Import/Export Specialist – EMEA CMD Commercial Offices
; Requisition ID: 44930BR

* UBC; Monheim, Germany;
Manager Customs and Trade Compliance 
* Ultra Electronics; Greater London, United Kingdom;
International Trade and Export Compliance Specialist

* United Technologies Corporation, UTC Aerospace Systems; Brea CA;
Sr. Anlst, Intl Trade Compl
; Requisition ID: 46798BR

# United Technologies Corporation, UTC Aerospace Systems; Burnsville MN;
Senior International Trade Compliance Analyst- Imports
; Requisition ID:33469BR
# United Technologies Corporation, UTC Aerospace Systems; Burnsville MN;
ITC Tech Manager- SIS
; Requisition ID:38565BR

* United Technologies Corporation, UTC Aerospace Systems; Chula Vista CA; 
International Trade Compliance Intern
; Requisition ID:
39406BR

* United Technologies Corporation, UTC Aerospace Systems; Chula Vista CT;
International Trade Compliance Analyst
; Requisition ID: 46876BR


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

* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks, CT; Investigations and Disclosures Specialist; Requisition ID: 46282BR

* United Technologies Corporation, UTC Aerospace Systems; Windsor Locks CT;
Sr. Anlst, Intl Trade Compl
; Requisition ID: 48594BR

* VAG; Mannheim, Germany;
Trade Compliance Manager (m/w)
; Contact: Mr. Florian Uhl, +49 621 749 – 1870

* Varex Imaging Corp; Salt Lake City UT; 
Senior Customs Compliance Analyst
; Requisition ID: 
11402BR

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

* XPO Logistics; Greenwich CT;
Global Trade Compliance Analyst

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ENEDITOR’S NOTES

* Rosalind Russell (Catherine Rosalind Russell, 4 Jun 1907 – 28 Nov 1976, was an American actress of stage and screen, known for her role in the Howard Hawks screwball comedy, His Girl Friday, as well as for her portrayals of Mame Dennis in Auntie Mame, and Rose in Gypsy. A noted comedian, she won all five Golden Globes for which she was nominated.)
  – “Taking joy in living is a woman’s best cosmetic.” 
 
* Pancho Villa (Francisco Villa, born José Doroteo Arango Arámbula; 5 Jun 1878 – 20 Jul 1923, was a Mexican Revolutionary general and a prominent figure of the Mexican Revolution. Although he evaded capture by U.S. Army General John J. Pershing after hit and run raids on U.S.-Mexican border towns, Villa was assassinated by his political opponents.)
  – “Don’t let it end like this. Tell them I said something.”
 
* Adam Smith (5 Jun 1723 – 17 Jul 1790, was a Scottish economist, philosopher, and author. He was a moral philosopher, a pioneer of political economy, and was a key figure during the Scottish Enlightenment era. He is best known for two classic works: The Theory of Moral Sentiments, and An Inquiry into the Nature and Causes of the Wealth of Nations. The latter, usually abbreviated as The Wealth of Nations, is considered his magnum opus and the first modern work of economics.)
  – “It is not from the benevolence of the butcher, the brewer, or the baker that we expect our dinner, but from their regard to their own interest.”
  – “The real tragedy of the poor is the poverty of their aspirations.”
 
Monday is pun day.
 
Q. What do you call the two guys who hang around your window?
A. Kurt and Rod.  
  — Michael Lusk, Nampa, Idaho

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EN_a312
. 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: 26 May 2017: 82 FR 24242-24248: Addition of Certain Persons and Revisions to Entries on the Entity List

  
*
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: 19 Apr 2017: 82 FR 18383-18393: Foreign Trade Regulations: Clarification on Filing Requirements 
  – HTS codes that are not valid for AES are available
here.
  – The latest edition (19 Apr 2017) 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: 7 Mar 2017: Harmonized System Update 1702, containing 1,754 ABI records and 360 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 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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Review last week’s top Ex/Im stories in “Weekly Highlights of the Daily Bugle Top Stories” published
here

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EPEDITORIAL POLICY

* The Ex/Im Daily Update is a publication of FCC Advisory B.V., edited by James E. Bartlett III and Alexander Bosch, and emailed every business day to approximately 8,000 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOJ/ATF, DoD/DSS, DoD/DTSA, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

* RIGHTS & RESTRICTIONS: This email contains no proprietary, classified, or export-controlled information. All items are obtained from public sources or are published with permission of private contributors, and may be freely circulated without further permission. Any further use of contributors’ material, however, must comply with applicable copyright laws.

* CAVEAT: The contents of this newsletter cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.

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