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17-0710 Monday “Daily Bugle”

17-0710 Monday “Daily Bugle”

Monday, 10 July 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 
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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. DHS/CBP Announces ACE PRODUCTION Care Release Deployment on 11 July
  4. State/DDTC: (No new postings.)
  5. EU Publishes Implementing Regulations Concerning the Classification of Certain Goods in the Combined Nomenclature, Amends Restrictive Measures Against ISIL and Al-Qaida
  6. UK/DIT ECO Updates OGEL for Printed Circuit Boards and Components for Military Goods
  1. Reuters: “London High Court Rejects Bid to Halt British Arms Sales to Saudi”
  2. Reuters: “Siemens to Press Charges After Turbines Moved from Russia to Crimea”
  3. SpaceNews: “One Small Step for U.S.-China Space Cooperation”
  4. ST&R Trade Report: “Streamlined Filing, Exports, Defense Services to be Reviewed by Defense Trade Committee”
  5. Swissinfo.ch: “Swiss Block Sale Over Concern About Pakistani Nuclear Programme”
  1. M. Volkov: “DOJ’s “Filip” Factors and Corporate Prosecutions”
  2. Gary Stanley’s ECR Tip of the Day
  1. Monday List of Ex/Im Job Openings 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (30 Jun 2017), DOD/NISPOM (18 May 2016), EAR (7 Jul 2017), FACR/OFAC (16 Jun 2017), FTR (19 Apr 2017), HTSUS (28 Jun 2017), ITAR (11 Jan 2017) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

[No items of interest noted today.] 

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

OGSOTHER GOVERNMENT SOURCES

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

[No items of interest noted today.]
* * * * * * * * * * * * * * * * * * * *

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OGS_a33.

DHS/CBP Announces ACE PRODUCTION Care Release Deployment on 11 July

(Source:
CSMS# 17-000396, 10 July 2017.)
 
There will be an ACE Cargo Release PRODUCTION deployment on Tuesday morning, 11 July 2017, during the 0500 – 0700 ET window, which will impact ACE Cargo Release and ACE Entry Summary processing.
 
To be deployed:
 
  – SE-8733: If entry has tariff 9801.00.10 (American Goods Returned) and a non-American Goods tariff, then entry should be rejected if entry value is over $2500.
  – SE-8734: Turn on validation for Entry Type 11 to reject if over $2500, but allow if tariff number is 9801.00.10 and entry value is $10,000 or less.
  – SE-8753: An entry with a port code ending in 00 will be rejected with INVALID PORT CODE error.
  – SE-8686: Ticket# 7707934 – Send the latest entry type and port code in SO (Cargo Release status notification) message.
  – SE-8756: Ticket# 8371839 – For truck entries, if EDA (estimated date of arrival) is future date, use the actual arrival date to set the release date instead of the EDA.

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

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OGS_a55
. EU Publishes Implementing Regulations Concerning the Classification of Certain Goods in the Combined Nomenclature, Amends Restrictive Measures Against ISIL and Al-Qaida

(Source: Official Journal of the European Union, 8 July 2017.)
 
Regulations
  – Commission Implementing Regulation (EU) 2017/1232 of 3 July 2017. concerning the classification of certain goods in the Combined Nomenclature
  – Commission Implementing Regulation (EU) 2017/1233 of 3 July 2017. concerning the classification of certain goods in the Combined Nomenclature
  – Commission Implementing Regulation (EU) 2017/1234 of 3 July 2017. concerning the classification of certain goods in the Combined Nomenclature
  – Commission Implementing Regulation (EU) 2017/1235 of 6 July 2017 amending for the 270th time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organisations 

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

OGS_a66
. UK/DIT ECO Updates OGEL for Printed Circuit Boards and Components for Military Goods

(Source:
UK/DIT ECO)
 
The Export Control Organisation (ECO) of the UK Department of International Trade (DIT) has amended and republished the Open General Export Licence (OGEL) Printed Circuit Boards (PCBs) and Components for Military Goods.
 
This open general export licence (OGEL) permits the export or transfer of printed circuit boards (PCBs) and items for military goods. It is subject to reporting requirements under the transparency initiative.
 
The main change to this OGEL is that the schedule has been extended to include component parts and complete knock-down kits of the components set out in the schedule.
 
The schedule includes:
 
  – general parts such as: unpopulated (bare) printed circuit boards, wiring looms and harnesses, connectors, fasteners, mechanical switches, electric cooling fans, heat sinks, headsets, voice communications antennae, batteries, hoses, clamps, EMI/RFI filter windows, gaskets, fire extinguisher assemblies, anti-vibration/shock mounts;
  – additional vehicle parts such as: brake discs, alternators and generators, axles, bearings, windshield washer, seats, doors;
  – additional vessel parts such as: doors, hatches and portholes, and mountings; and
  – additional aircraft parts such as: micro-switches, ducts, diaphragms, passenger and crew seat assemblies, ejection-seat mounted survival aids, aircraft windows and windshield washers.
 
Note: As a result of the above amendment, the following OGELs are revoked:
 

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

NWSNEWS

(Source:
Reuters, 10 July 2017.) [Excerpts.]
 
London’s High Court on Monday rejected a claim by campaigners that Britain’s multi-billion-pound arms sales to Saudi Arabia should be halted because they were being used in Yemen in violation of international humanitarian law.
 
The ruling was condemned by activist groups and charities, with Oxfam saying it “sets back arms control 25 years”, but it was welcomed by the British government.
 
  “I welcome the High Court judgment today … it shows that we do in this country operate one of the most robust export- control regimes in the world,” British Prime Minister Theresa May told parliament when asked about the ruling. … 
 
The court, which heard much of the government’s case in hearings closed to the media and public, said there had been extensive political and military engagement with Saudi Arabia regarding operations in Yemen and the Saudis had “sought positively to address concerns about International Humanitarian Law”. … 
 
Trade minister Liam Fox said that Britain would monitor the situation in Yemen and would stop granting export licenses and suspend current licenses if the risk of violations increased.
 

The court also said the British government had access to “a wider and qualitatively more sophisticated range of information than that available to the claimant’s sources”, although campaigners said the evidence they had gathered should be taken seriously. … 

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NWS_a28
.

Reuters: “Siemens to Press Charges After Turbines Moved from Russia to Crimea”

(Source:
Reuters, 10 July 2017.) [Excerpts.]
 
Germany’s Siemens said on Monday at least two of its gas turbines had been moved “against its will” from Russia to Crimea, a region subject to sanctions barring EU firms providing it with energy technology.
 
The European Union imposed the sanctions after Russia’s 2014 annexation of the peninsula from Ukraine, a move it sees as breaking international law.
 
Siemens, which has repeatedly insisted it was not aware the turbines were destined for Crimea, said it would press criminal charges against those responsible for diverting the turbines. … 
 
A Siemens spokesman said the customer in question was Russian state-owned engineering company Technopromexport, which bought the turbines from Siemens. Technopromexport had no immediate comment, and Russia’s energy ministry declined to comment. …
 
Three sources close to the matter told Reuters last week that Russia’s ZAO Interautomatika had been hired to help install the turbines in Crimea.
 
Siemens said on Monday it had expanded investigations by an internal taskforce to all of its Russian-based entities and relevant partners to ensure that no equipment or services could be supplied that could violate export control restrictions. 


  “This also applies to Siemens’ minority stake in Interautomatika,” it said, adding that Interautomatika had confirmed in writing Siemens’ insistence that all relevant activities with respect to Crimea be immediately terminated.
 
Siemens added that it would file lawsuits to halt any further deliveries to Crimea and to return already-dispatched equipment to its original destination. It said it was evaluating what additional actions were possible.
 
The Siemens source had earlier told Reuters that the company was taking legal steps to address the issue. 

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NWS_a39
.

SpaceNews: “One Small Step for U.S.-China Space Cooperation”

(Source:
SpaceNews, 10 July 2017.) [Excerpts.]
 
Collaboration between China and the United States in space is difficult. Federal law prohibits NASA from bilateral cooperation with China unless the agency first receives congressional approval. Export control restrictions prevent U.S. companies from selling hardware to Chinese companies, or launching satellites on Chinese rockets.
 
One initiative, though, could open the door for greater cooperation between the two space powers, eventually. One of the payloads delivered to the International Space Station on a Dragon cargo spacecraft in early June was an experiment developed by Deng Yulin, a professor at the Beijing Institute of Technology in China. The experiment will test the effects of the space radiation environment on DNA. …
 
The experiment was able to navigate a narrow path to overcome legal obstacles to U.S.-China space cooperation. Because the agreement is with NanoRacks, and not NASA, it does not violate existing limitations on bilateral cooperation between NASA and China. Moreover, since the experiment is imported to the United States, it does not run afoul of export control restrictions.
 

The company, in a June 5 statement, emphasized that the experiment will remain installed on a NanoRacks platform inside the station, with no access to NASA or other ISS systems. There is, NanoRacks added, no transfer of technology between NASA and China. … 

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NWS_a410
.

ST&R Trade Report: “Streamlined Filing, Exports, Defense Services to be Reviewed by Defense Trade Committee”

 
The State Department’s Directorate of Defense Trade Controls has requested input from the Defense Trade Advisory Group within the next six months on the following issues.
 
  – Streamlined Filing
. DDTC has proposed a consolidated licensing form (DS-7788) to replace all currently required unclassified licensing forms (GSP 5, 6, 61, 62, 73, and 74). This electronic form would allow applicants to enter all data currently required by existing forms, transmittal letters, agreement documents, and other supporting documentation and to electronically sign the application. Users could continue to provide data on a machine-to-machine basis (batch filing) and would be able to make corrections after submittal during the DDTC review process. Once DDTC has reviewed and approved an application the system would product a license that provides information for the applicant and foreign parties to ship against it.
 
DTAG is being asked for feedback on whether industry would benefit from (1) a single interagency form where the data elements needed by DDTC, the Bureau of Industry and Security, and the Office of Foreign Assets Control are collected using a single system user interface or single machine-to-machine data interface; (2) an expansion of the current license-based batch filing, to include registration filings and updates, notifications, commodity jurisdictions, etc.; and (3) a modified user access/authentication process.
 
  – Exports and Reexports. DTAG is being asked to examine the challenges of compliance with the current rules on releases of technical data to foreign dual nationals, which provide that any release outside the U.S. of technical data to a foreign person is a controlled event that requires authorization to all countries where that person holds or has held citizenship or is a permanent resident and that such authorization must authorize all applicable destinations. DDTC has learned that it may be difficult, impossible, or (in some countries) illegal to fully ascertain whether individuals have contacts with countries listed in ITAR section 126.1 arising from citizenship or residency that would preclude export authorizations. DTAG is therefore also tasked with identifying alternative options that sufficiently facilitate risk assessment and mitigation.
 
  – Defense Services. There has been confusion about servicing items subject to the Export Administration Regulations that are integrated into larger defense articles and the difficulty of establishing proof of knowledge. DTAG is therefore being asked to identify key areas of concern with a June 2015 proposed definition of “defense services” as well as any aspects of that definition that would constitute positive change.
 
  – Manufacturing. Considering the possibility of revisions to categories I-III and the removal of most commercial firearms and related activities from the International Traffic in Arms Regulations, DTAG is being asked to provide feedback to accurately and effectively define manufacturing (and to distinguish it from related activities like assembly, integration, installment, and various services) for remaining defense articles and services.
 
  – Agreement Expiration. DDTC is considering standardizing the expiration date for all new agreements to a fixed ten-year period from the date of initial approval. Under the current system the expiration month is established by a table based on the registered company name. This system is efficient for DDTC because it prevents an overwhelming number of extension requests at the end of the calendar year but may not be efficient for applicants because it requires companies to renew all expiring licenses during the designated month.

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NWS_a511
.

Swissinfo.ch: “Swiss Block Sale Over Concern About Pakistani Nuclear Programme”

(Source:
Swissinfo.ch, 10 July 2017.) [Excerpts.]
 
Swiss government officials say they denied an export permit to a domestic manufacturer because of indications that its products would have supported the production of Pakistani nuclear weapons.
 
The decision by Switzerland’s State Secretariat for Economic Affairs (SECO) prevented the undisclosed Swiss company from being able to sell its valves abroad for use in ventilation systems.

The incident, first reported in the Swiss newspaper NZZ am Sonntag, shows the risk of “dual-use goods” that can be sold commercially but put to military use. SECO generally does not allow items to be sold that can be used for both purposes. A spokesman, Fabian Maienfisch, confirmed to swissinfo.ch that SECO denied the export application for the valves.
 
Officials with SECO have denied 330 export applications worth CHF159 million ($165 million) in blocked sales since the law regulating dual-use goods took effect two decades ago. They included 161 suspected breaches of export control regulations which were, in many cases, alleged formal offenses and not intentional violations.
 
SECO has previously denied exports of machine tools and similar products to Pakistan, which the agency believed would go to the country’s nuclear program, according to Maienfisch.
 
  Not the First Time
 
In the most recent case involving products bound for Pakistan, Maienfisch wrote that the company that sought an export permit is not suspected of breaching regulations.
 
SECO based its decision, he said, on “information that these valves will not remain with the industrial plant declared on the final declaration of the end-of-life declaration, but will be passed on to a nuclear-relevant entity involved in the Pakistani nuclear weapons program.”
 
The SECO file to deny the export application says the proposed sale of valves was worth CHF76,626.35. It cites two reasons under the Swiss law on dual-use goods. One is that the item is meant to be used to make nuclear weapons; the other is that the recipient of the item intends to pass it on. In this case, the proposed sale of the valves apparently involved a decoy company or third-party country.
 
The valves can be used for civilian or military purposes – and it is not the first time that SECO has denied an export permit to sell them abroad. Maienfisch said that SECO could not publicly disclose the basis for its decision that the sale involved the Pakistani procurement network for its nuclear program.

The use of decoy companies and third-party countries to hide the real intent for purchasing something is a growing phenomenon.
 
  “Procurement is increasingly carried out by camouflage companies and by third countries to obscure the actual recipient and the critical use,” Maienfisch wrote. “Machine tools, measuring instruments, navigation equipment, valves and compressors are mainly the focus of procurement.”
 
To counter this trend, SECO works with export authorities from other countries and with officials from other Swiss agencies such as the Federal Customs Administration to make border checks, and the Federal Intelligence Service to obtain sensitive information. …
 
  Grey Zones
 
Last year marked the first instance when SECO authorised the export of goods that could have both civilian and military applications. The sale involved CHF100 million worth of encryption devices for Iraq, part of CHF1.2 billion in war materiel or dual-use exports shipped to various countries in 2016, according to Swiss public television SRF.
 
SECO confirmed to SRF that the Iraqi civilian government ministry ordered the shipment of encrypted telephones to enable secure communication systems. Under Swiss export regulations, dual-use goods must pass less stringent restrictions than for war materiel.
 
The exception is surveillance equipment that can be rejected for export if there is evidence of it being used for repressive purposes. But SECO did not believe the encrypted phones fell into the surveillance category or could pose a threat if they fall into the wrong hands, since they can be remotely disabled.
 

At least CHF7 billion in war materiel or dual-use goods have been exported from Switzerland in the last five years to 146 different countries, including training planes and drones worth CHF3 billion. …. 

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COMMCOMMENTARY

COMM_a01
12. M. Volkov: “DOJ’s “Filip” Factors and Corporate Prosecutions”

(Source: Volkov Law Group Blog. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
 
Companies that experience a Justice Department criminal investigation undergo a long and painful process. DOJ prosecutors hold the cards when reviewing the facts and deciding whether to indict a company.
 
The United States Attorneys’ Manual (“USAM”) is a comprehensive collection of DOJ policies regarding civil and criminal enforcement issues. The USAM includes specific policies concerning corporate prosecution guidelines.  Specifically, whether to criminally charge a corporation is governed by USAM 9-27.280 (available here), which sets out what is referred to as the “Filip Factors,” referring to former Deputy Attorney General Mark Filip (who I had the honor of serving with at DOJ during the Bush Administration).
 
In 2008, DOJ revised its corporate prosecution guidelines in response to concerns that prosecutors were requiring companies to waive attorney-client privilege in order to earn cooperation credit. Over the last 20 years, DOJ has revised its corporation prosecution guidelines several times: in 1999, when Eric Holder was the Deputy Attorney General (“Holder Memorandum”); in 2003, when Larry Thompson served as the Deputy Attorney General (“Thompson Memorandum).
 
Defense counsel who represent companies usually present facts and circumstances under the Filip Factors to support their argument for a specific resolution. Prosecutors are required to weigh all of the factors normally considered in the exercise of prosecutorial judgment: the sufficiency of the evidence; the likelihood of success at trial; the probable deterrent, rehabilitative and other consequences of conviction; and the adequacy of noncriminal approaches.
 
When it comes to corporations, the USAM adds the Filip Factors to guide a decision on whether to bring charges, negotiate a plea or other agreement (i.e. deferred or non-prosecution agreement).
 
As set forth below, the Filip Factors include two specific factors focused on corporate compliance programs – one for the existence of a corporate compliance program at the time the wrongdoing occurred (number 5), and another focused on remedial actions taken by the company to enhance its compliance program in response to the misconduct (number 7).
 
The specific Filip Factors include:
 
  (1) The nature and seriousness of the offense, including the risk of harm to the public, and applicable policies and priorities, if any, governing the prosecution of corporations for particular categories of crime (see USAM 9-28.400);
  (2) The pervasiveness of wrongdoing within the corporation, including the complicity in, or condoning of, the wrongdoing by corporate management (see USAM 9-28.500);
  (3) The corporation’s history of similar misconduct, including prior criminal, civil and regulatory enforcement actions against it (see USAM 9-28.600);
  (4) The corporation’s willingness to cooperate in the investigation of its agents (see USAM 9-28.700);
  (5) The existence and effectiveness of the corporation’s pre-existing compliance program (see USAM 9-28.800)
  (6) The corporation’s timely and voluntary disclosure of wrongdoing (see USAM 9-28.900);
  (7) The corporation’s remedial actions, including any efforts to implement an effective corporate compliance program or to improve an existing one, to replace responsible management, to discipline or terminate wrongdoers, to pay restitution, and to cooperate with relevant government agencies (see USAM 9-28.1000);
  (8) The collateral consequences, including whether there is disproportionate harm to shareholders, pension holders, employees, and others not proven personally culpable, as well as impact on the public arising from the prosecution (see USAM 9-28.1100);
  (9) The adequacy of remedies such as civil or regulatory enforcement actions (see USAM 9-28.1200); and
  (10) The adequacy of the prosecution of individuals responsible for the corporation’s malfeasance (see USAM 9-28.1300).
 
While there is nothing surprising in the Filip Factors list, the emphasis on voluntary disclosure, enhancement of corporate compliance programs, and remediation underscore the importance that a company facing possible prosecution quickly assess the potential misconduct, decide whether to disclose and cooperate, initiate significant remediation efforts, and, most importantly, improve its corporate compliance program.

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

(Source: Defense and Export-Import Update; available by subscription from
gstanley@glstrade.com
)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
.
 
For purposes of the definitions of “specially designed” in the ITAR and EAR, the term “equivalent” used in subparagraph (b)(3) means the form has been modified solely for fit purposes. The function and performance capabilities must be the same. Any change in form besides a change solely for fit purposes would mean the “part,” “component,” “accessory,” “attachment” or “software” is not “equivalent.”

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MSEX/IM MOVERS & SHAKERS

MS_a114. Monday List of Ex/Im Job Openings

(Source: Editor)  
 
Published every Monday or first business day of the week. Please send openings in the following format to jobs@fullcirclecompliance.eu.
 
* COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFORMATION; REQUISITION ID
 
#” New listing this week:
 
* Abcam; Cambridge, United Kingdom;
Trade Compliance Coordinator; Requisition ID: CAM-012-996
* Acteon Group Ltd.; Norwich, Suffolk, or London, UK;
Head of Compliance; or email
Mike Pay
* Advanced Micro Devices (AMD); Austin TX; 
Import/Export Compliance Manager
; Requisition ID: 24061


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

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

* Arthrex; Naples FL;
Senior Compliance Officer;

* 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
*
Cubic Corporation; San Diego, CA; 
Senior Export Compliance Analyst

Requisition ID: 5982


* 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

* DRS Technologies; Dayton, OH;
Senior Trade Compliance Manager

* 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

* Esterline CMC Electronics; Montreal, Quebec, Canada;
Senior Manager Trade Compliance; Requisition ID: 9971BR

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

* 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 Land Systems; Sterling Heights, MI; Site Lead/Compliance OfficerRequisition ID: 
SHC-LC-17-19647


General Dynamics Land Systems; Sterling Heights, MI; Compliance Officer

SHC-LC-17-19648

* 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

*
 Huntington Ingalls Industries, Newport News Shipbuilding Division; Newport News, VA; International Trade Compliance Analyst 3; Requisition ID:  18350BR

* Indiana Mills & Manufacturing, Inc.; Westfield, IN;
International Trade Compliance Manager

* 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

* ManTech International; Herndon VA; 
Director of Corporate Export Control
;
Jenna.Brady@ManTech.com
; Requisition ID: 90965BR

* 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
; Requsition ID: 16000DYY

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

* Meggitt PLC; Maidenhead, UK;
Trade Compliance Officer 
* Momentive Performance Materials, Inc.; Waterfield, NY;
Manager, Global Trade Compliance

* North Dakota State University; Fargo ND;
Director for Research Integrity Compliance; Requisition ID: 1700372

* Northrop Grumman; Falls Church VA; 
International Trade Compliance Analyst 3/4
; Patricia Vives, 
patricia.vives@ngc.com
; Requisition ID: 17011893

* 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
; Requisition ID: 4301
* Raytheon; (El Segundo CA, McKinney TX, Dallas TX, Marlborough MA, or Washington D.C.);
Senior Manager of Global Trade Management
; Requisition ID: 98724BR

* Raytheon; Rosslyn, VA; 
Export Trade Compliance Specialist; Requisition ID: 97978BR

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

* Saab Defense and Security USA LLC; Syracuse NY;
Senior Import/Export Analyst
; Requisition ID: USA_00413

* Science and Engineering Services, LLC; Huntsville AL;
Export Compliance Specialist
bob.davis@ses-i.com; Requisition ID: 157

* 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

* 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;


ITC Tech Manager- SIS
; Requisition ID:38565BR

International Trade Compliance Analyst
; Requisition ID: 46876BR


*
United Technologies Corporation, UTC Aerospace Systems; Rockford IL;
Specialist, International Trade Compliance- Operations and Licensing
; Requisition ID: 50118BR

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

* University of North Carolina; Chapel Hill, NC;
Export Control Officer

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

Vertiv (formerly Emerson Network Power); Columbus, OH,  
International Trade Management (ITM) Senior Specialist
; Req #1700001087

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

* Xilinx, Inc.; San Jose, CA, US;
Global Trade Compliance Program Manager; Requisition ID: 153811

* XPO Logistics; Greenwich CT;
Global Trade Compliance Analyst

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ENEDITOR’S NOTES

* William Blackstone (Sir William Blackstone SL KC, 10 Jul 1723 – 14 Feb 1780, was an English jurist, judge, and Tory politician of the eighteenth century. He is most noted for writing the Commentaries on the Laws of England.)
  – “It is better that ten guilty escape than one innocent suffer.”
  – “Free men have arms; slaves do not.”
 
Monday is Pun Day.
 
Q: Why did the cookie go to the doctor? 
A: He was feeling crummy.
  – Sarah Carroll, Minneapolis, MN
 
Q: What did the doctor give to the sick balloon? 
A: Healium.
  – Cara Andreassi, White Plains, NY

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EN_a316
. 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: 30 Jun 2017:
82 FR 29714-29719
: Modernization of the Customs Brokers Examination [Effective Date: 31 July 2017.] 


* 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 cancelled Supp. 1 to the NISPOM  (Summary here.)


EXPORT ADMINISTRATION REGULATIONS (EAR)
: 15 CFR Subtit. B, Ch. VII, Pts. 730-774

  – Last Amendment:7 July 2017: 
82 FR 31442-31449: Revisions to the Export Administration Regulations Based on the 
2016 Missile Technology Control Regime Plenary Agreements. 

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 16 Jun 2017: 82 FR 27613-27614: Removal of Burmese Sanctions Regulations 
 
*
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: 28 Jun 2017: Harmonized System Update 1704, containing 2,564 ABI records and 463 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.
  – Last Amendment: 11 Jan 2017: 82 FR 3168-3170: 2017 Civil Monetary Penalties Inflationary Adjustment
  – The only available fully updated copy (latest edition: 10 Jun 2017) of the ITAR with all amendments is contained in Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III.  The BITAR contains all ITAR amendments to date, plus a large Index, over 800 footnotes containing amendment histories, 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.

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

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., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, John Bartlett. The Ex/Im Daily Update is 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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