;

17-0821 Monday “Daily Bugle”

17-0821 Monday “Daily Bugle”

Monday, 21 August 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. DoD/DSCA Publishes DSCA Policy Memo, 20-26 Aug
  4. State/DDTC: (No new postings.)
  5. Australia DEC Seeks Comments on Proposed Amendments to Regulation 13E of the Customs (Prohibited Exports) Regulations 1958
  6. EU Amends Restrictive Measures Against ISIL and Al-Qaida
  1. Defense News: “General Atomics: Export Restrictions Help China Grow its Drone Tech”
  2. Expeditors News: “CBP Releases Updated ACE CATAIR and AESTIR Documentation”
  3. Fox Business: “U.S. Formally Begins Probe of China Technology Transfer”
  4. ST&R Trade Report: “Cargo Ships Stopping in Micronesia May be Denied Entry”
  5. ST&R Trade Report: “CBP Reviewing Vessel Entrance or Clearance Statement”
  1. D.M. Edelman: “New Sanctions Law: Congress Seeks to Limit President Trump’s Ability to Modify U.S. Policy Toward Russia”
  2. M. Miller Proctor: “Trump Administration Launches Review of U.S. Export Policy on Military Drones”
  3. M. Volkov: “OFAC Pushes Iran Sanctions Enforcement”
  1. Monday List of Ex/Im Job Openings 
  1. ECTI Presents “Specially Designed: Increase Your Accuracy and Decrease Burdensome Controls Webinar – A Two Part Series” on 14 & 28 Sep 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (28 Jul 2017), DOD/NISPOM (18 May 2016), EAR (15 Aug 2017), FACR/OFAC (16 Jun 2017), FTR (19 Apr 2017), HTSUS (25 Jul 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

* State: NOTICES; Notifications to Congress of Proposed Commercial Export Licenses [Publication Date: 22 Aug 2017.]

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

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OGS_a44. 
State/DDTC: (No new postings.)

(Source: State/DDTC)

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OGS_a55.

Australia DEC Seeks Comments on Proposed Amendments to Regulation 13E of the Customs (Prohibited Exports) Regulations 1958

 
Australia Defense Export Controls invites the public and interested stakeholders to comment on proposed amendments to regulation 13E of the Customs (Prohibited Exports) Regulations 1958. The intent behind the proposed amendments is to update current export control processes, bringing regulation 13E into line with the more modern regulatory powers contained in the Defense Trade Controls Act 2012 (DTC Act).
 
Broadly, the key updates in the proposed amendments include the addition of a specific personal use exemption for individuals exporting controlled technology and uncontrolled goods containing controlled technology, enhanced powers (into line with the DTC Act) to revoke a permit where the export would prejudice the security, defense or international relations of Australia, as well as the inclusion of decision-making criteria and the addition of mechanisms to review decisions made under regulation 13E.
 
The proposed amendments to Regulation 13E can be viewed here and the draft Explanatory Statement can be viewed here. Further information is available on the Defense Export Controls (DEC) Branch website.
 
The closing date for comments on the proposed amendments is close of business Friday, 8 September 2017. Submissions can be emailed to exportcontrols@defence.gov.au or posted to Defense Export Controls, R1-1-A037, PO Box 7901, Canberra BC ACT 2600. 

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OGS_a66.

EU Amends Restrictive Measures Against ISIL and Al-Qaida

 
Regulations
 
* Commission Implementing Regulation (EU) 2017/1488 of 18 August 2017 amending for the 274th 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.

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NWSNEWS

NWS_a17. 
Defense News: “General Atomics: Export Restrictions Help China Grow its Drone Tech”

(Source: Defense News, 18 Aug 2017.)  
 
At the beginning of the century, U.S. drone makers were king, but export restrictions on UAVs have allowed China to begin closing the technology gap, the president and CEO of General Atomics said Wednesday.
 
Many government entities don’t understand that when the United States denies UAV manufacturers the ability to sell drones to allies and partner nations, those companies also lose the chance to provide logistics and sustainment services that bring even more business over the life cycle of the product, said Linden Blue, the company’s chief executive.
 
  “What you are enabling the competition to do is not just to sell some hardware,” he told reporters during an Aug. 16 roundtable at the company’s headquarters in Poway, California. “You’re enabling it to build a customer base for at least 20 years, I would say. You’re enabling them to build a logistics system. It will take them many years to get to where we are right now, but you’re helping them start out. They should be very thankful.”
 
There is a technical and political component to this as well, Blue said. By relinquishing UAV sales to U.S. competitors like China, the U.S. government allows those countries to learn more about how to effectively use and sustain unmanned aircraft. Perhaps even more importantly, that sale paves the way for a deeper partnership between U.S. adversaries and other nations.
 
  “They are going to learn how to provision spare parts, they are going to learn what kind of maintenance is really necessary, they’re going to learn how to integrate the UAVs into those local militaries’ other assets and after a few years they will become an inextricable part of those countries’ militaries,” he said.
 
Interest in General Atomics’ MQ-1 Predator exploded at the turn of the century as the wars in Iraq and Afghanistan began, and defense companies from around the world raced to develop their own version of the Predator. But the days when the Predator was the only medium-altitude, long-endurance, or MALE, UAV around are long gone.
 
At the Paris Air Show this year, Chinese defense firm Chengdu Aircraft Industry Group exhibited a static display of the Wing Loong, a MALE drone that bears a strong resemblance to the Predator and its larger counterpart, the MQ-9 Reaper.
 
David Alexander, GA’s president, acknowledged that China had already breeched the technology gap, at least on the low-end side of the market.
 
  “They’re here,” he said.
 
In recent years, General Atomics has been active in trying to educate Congress and the White House about UAV export controls and the effects, both to GA’s business and on a wider level, Blue said.
 
An administration official told Defense News earlier this month that the Trump administration has launched a review of drone restrictions, meaning relief could be coming soon.
 
The most damaging restriction is the Missile Technology Control Regime, an informal, multinational agreement meant to help check the spread of nuclear weapons. The MTCR labels any UAV that has a range of more than 300 kilometers and a payload of more than 500 kilograms as a Category I system on par with ballistic missile and space launch vehicles.
 
Changing the MTCR is likely a long-term endeavor that will require the participation of many countries, but in the short term, the United States could change its own drone export policies – which in effect have made it difficult to export UAVs outside NATO countries and treaty allies.
 
  “MTCR does allow some level of judgement by the participating country. It’s not a black or white decision every time,” Blue said. “So if you can address the current U.S. UAV export policy, that would be a quicker thing that could bring results.” 

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NWS_a28. 
Expeditors News: “CBP Releases Updated ACE CATAIR and AESTIR Documentation”

(Source: Expeditors News, 18 Aug 2017.)
 
On 18 August 2017 U.S. Customs and Border Protection (CBP) released Cargo Systems Messaging Service (CSMS) #17-000503 announcing an update to specific chapters in the Automated Commercial Environment (ACE) CBP & Trade Automated Interface Requirements (CATAIR) and Automated Export System Trade Interface Requirements (AESTIR) have been posted to the CBP website.
 
The updated documentation includes:
  – AESTIR: Appendix C-ISO Country Codes and Summary of Changes
  – CATAIR: In-Bond Chapter, Cargo Release Chapter, and FTZ Chapter
 
The updated documentation of the CATAIR and AESTIR can be viewed and accessed on the CBP website.

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NWS_a39. 
Fox Business: “U.S. Formally Begins Probe of China Technology Transfer”

(Source: Fox Business, 18 Aug 2017.) [Excerpts.]
 
President Donald Trump’s trade chief on Friday (18 Aug) formally launched an investigation into Chinese efforts to secure technology and Beijing’s treatment of intellectual property. …
 
In addition to probing Chinese efforts to obtain U.S. technology and intellectual property, the investigation under Section 301 of a 1974 trade law will also look into whether Beijing supports cyber intrusion to obtain trade secrets or technology in ways that harm American companies, the trade representative’s office said.
 
The case is the first formal China trade action taken by a president who has long blasted the country for what he says are improper commercial practices. On Monday as he signed the directive, Mr. Trump said: “This is just the beginning.”
 
White House aides said the probe could run for a year before any decisions are made on imposing trade sanctions. … 

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NWS_a410. 
ST&R Trade Report: “Cargo Ships Stopping in Micronesia May be Denied Entry”

 
Effective 5 September, the Coast Guard will impose certain conditions of entry on all vessels that visited any port in the Federated States of Micronesia in their last five port calls. Any vessel that does not meet these conditions may be denied entry into the U.S. The Coast Guard is imposing these conditions because it has determined that ports in this country are not maintaining effective anti-terrorism measures and that this country’s designated authority oversight, access control, security monitoring, security training programs, and security plans, drills, and exercises are all deficient.
 
Under the conditions of entry, affected vessels must do the following.
 
  – implement measures per the ship’s security plan equivalent to security level 2 while in port in Micronesia
  – ensure that each access point to the ship is guarded and that the guards have total visibility of the exterior (both landside and waterside) of the vessel while it is in port in Micronesia
  – attempt to execute a declaration of security while in port in Micronesia
  – log all security actions in the ship’s security records
  – report actions taken to the cognizant Coast Guard captain of the port prior to arrival into U.S. waters
 
In addition, based on the findings of the Coast Guard boarding or examination, vessels may be required to ensure that each access point to the ship is guarded by armed private security guards who have total visibility of the exterior (both landside and waterside) of the vessel while in U.S. ports.
 
The current list of countries not maintaining effective anti-terrorism measures and therefore subject to conditions of entry is as follows: Cambodia, Cameroon, Comoros, Cote d’Ivoire, Equatorial Guinea, Federated States of Micronesia, the Gambia, Guinea-Bissau, Iran, Liberia, Libya, Madagascar, Nauru, Nigeria, Sao Tome and Principe, Syria, Timor-Leste, Venezuela, and Yemen.

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NWS_a511

ST&R Trade Report: “CBP Reviewing Vessel Entrance or Clearance Statement”

 
U.S. Customs and Border Protection is accepting through Oct. 20 comments on the proposed extension without change of CBP Form 1300, Vessel Entrance or Clearance Statement. This form allows the master of the vessel to attest to the truthfulness of all CBP forms associated with the manifest package and collects information about the vessel, cargo, purpose of entrance, certificate numbers, and expiration for various certificates. It also serves as a record of fees and tonnage tax payments to prevent overpayments.

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COMMCOMMENTARY

COMM_a0112.
D.M. Edelman: “New Sanctions Law: Congress Seeks to Limit President Trump’s Ability to Modify U.S. Policy Toward Russia”

      
* Author: Doreen M. Edelman, Esq., Baker Donelson LLP, 202-508-3460, dedelman@bakerdonelson.com
.
 
On 2 August 2017, President Trump signed into law the “Countering America’s Adversaries Through Sanctions Act” (H.R. 3364), which gives the President the power to solely waive or terminate sanctions against Russia if Congress reviews and approves of the action. President Trump argues that that bill is “seriously flawed” because it encroaches on his authority to conduct foreign affairs.
 
Due to the continuing controversy over Russia policy and pending investigations of the 2016 election, this Act has generated a lot of press attention. The bill also authorizes new sanctions on Iran and North Korea.
 
Here are three key takeaways from H.R. 3364:
 
  (1) Official U.S. sanctions policy toward Russia is not likely to change in the foreseeable future.
  (2) Congress has endorsed President Trump’s harsher view of Iran compared to the Obama Administration.
  (3) Congress and the Trump Administration agree on strengthening the existing sanctions regime on North Korea and the need to keep pressure on China.
 
With this bill authorizing new sanctions on Iran and North Korea, conducting business for exporters may be more difficult, especially when it comes to China. By endorsing President Trump’s view of Iran, the Act may also place burdens on exporters already doing business. Only time will tell exactly how much of an effect this bill will have.

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COMM_a2
13M. Miller Proctor: “Trump Administration Launches Review of U.S. Export Policy on Military Drones”

 
* Author: Melissa Miller Proctor, Esq.,
mproctor@polsinelli.com
, Polsinelli PC.
 
As has been reported recently by Defense News, the Trump Administration has launched a formal review of the current policy on U.S. military drone exports, which was rolled out under President Obama in February 2015. U.S. manufacturers are hoping that the Trump Administration may be considering relaxing controls on international sales of military Unmanned Aerial Systems (“UAS”) to key allies and strategic partners around the world. For years, industry has argued that the current controls on military UAS have put U.S. manufacturers at a competitive disadvantage in the global marketplace. See here for further.
 
By way of background, military UAS as well as related components, systems, software and technical data have historically been controlled under the U.S. State Department’s International Traffic in Arms Regulations (“ITAR” at 22 C.F.R. Parts 1210-130) in U.S. Munitions List Category VIII. The ITAR impose stringent licensing requirements on exports, reexports and temporary imports unless a specific license exemption applies. In particular, certain military UAS are subject to Missile Technology Control Regime (“MTCR”) controls, for example-
 
  – MTCR Category I UAS includes cruise missile systems, target drones and reconnaissance drones (as well as certain subsystems) capable of delivering at least a 500 kg payload to a range of at least 300 km-prior to February 2015, ITAR license applications for exports of such items were subject to a presumption of denial; and,
  – MTCR Category II covers UAS capable of a range ≥300 kg but that cannot carry a payload of 500 kg or more-prior to February 2015, ITAR license applications for exports of such items were considered on a case-by-case basis; however, if the items in question were intended for the delivery of weapons of mass destruction (“WMD”), then license applications were subject to a presumption of denial.
 
Commercial and dual-use UAS, on the other hand, are subject to the U.S. Commerce Department’s Export Administration Regulations (“EAR” at 15 C.F.R. Part 730 – 774)-they are not controlled under the ITAR.  
 
As noted above, the current U.S. policy on exports of military UAS was announced under the Obama Administration on February 17, 2015, whereby exports of MTCR Category I UAS (as well as Category II UAS intended for WMD delivery) were for the first time allowed to be authorized on “rare occasions” after the U.S. Government’s assessment of the nonproliferation and export control factors listed in the MTCR Guidelines. In addition, the 2015 policy stipulated that international sales of military UAS were to be made through the Foreign Military Sales (“FMS”) program. Further, approved foreign end-users were required to provide written end-use assurances that:
 
  – the UAS would be used in accordance with international law, international humanitarian and human rights law, as well as international law on the use of force and self-defense;
  – the UAS would not be used for unlawful surveillance or unlawful force against civilian populations;
  – appropriate training would be provided to UAS operators;
  – the UAS would not be transferred or sold, and related training or other defense services associated with the U.S. military UAS would not be provided, to anyone that was not an officer, employee or agent of the receiving country;
  – the UAS would not be used for purposes other than those for which it was furnished without prior U.S. government approval; and
  – the U.S. military UAS and related components would be secured and all reasonable efforts would be taken to prevent security lapses.
 
These end-use assurances were required to be submitted to the U.S. State Department’s Directorate of Defense Trade Controls (“DDTC”) as an addendum to the DSP-83 Non Transfer and Use Certificate.
 
In launching the newest policy review, the Trump Administration is reportedly focusing on finding a balance among delivering U.S. defense articles to allies and strategic partners, allowing U.S. industry to maintain its edge in UAS technology and development, and preserving America as a leader in promoting international security and nonproliferation. Manufacturers and exporters of military and dual-use drones should carefully monitor these developments not only to ensure their ongoing compliance with U.S. export laws and regulations, but to explore potential new international business opportunities that may come about in the near future.

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COMM_a3
14M. Volkov: “OFAC Pushes Iran Sanctions Enforcement”

(Source: Volkov Law Group Blog. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
 
Many companies have been laser-focused on anti-corruption compliance, and with good reason given the risks and consequences of an anti-corruption enforcement action. In doing so, companies have to be careful to avoid ignoring sanctions risks, especially in the ever-evolving nature of sanctions rules and regulations.
 
The Office of Foreign Asset Control is an enforcement agency that coordinates its investigations activity with the Department of Justice in a similar manner to the SEC and Department of Justice’s collaboration on FCPA enforcement. OFAC is responsible for civil enforcement of sanctions laws and regulations, while DOJ is responsible for criminal enforcement of transactions laws.
 
The new administration continues to enforce vigorously OFAC’s sanctions program, and has responsibility for enacting new regulations required under the new sanctions law. (See here for summary of new requirements).
 
In two recent enforcement actions, OFAC reminded companies of the importance of sanctions compliance, especially with regard to the continuing Iran sanctions program. In particular, the enforcement actions focused on the risks associated with USD transactions and subcontractor/third party services in Iran. Interestingly, the IPSA settlement described below involved a due diligence company that investigated the activities of Iranian nationals.
 
Both of these cases reinforce the importance of due care and diligence with respect to potential transactions involving the Iran sanctions program. Companies have to ensure that interactions with companies doing business with Iranian companies do not involve USD transactions, and that subcontractors and third parties, at whatever level, do not engage in otherwise prohibited activities.
 
TransTel Settlement
 
On 27 July 2017, OFAC announced a $12 million settlement with TransTel, a subsidiary of CSE Global, a Singapore-based telecommunications company that provides equipment and services to companies in the oil and gas sector, for violation of the Iran sanctions program. (See here for copy of settlement agreement).
 
TransTel provided equipment and services to oil and gas projects in Iran, and retained a number of third party subcontractors to assist in the projects. TransTel maintained USD and non-USD bank accounts in a Singapore bank. As part of its agreement with the Singapore bank, TransTel specifically agreed not to conduct any banking services through the Singapore bank related to the Iran project. Despite this specific assurance, within two months of beginning the project, TransTel engaged in prohibited USD transactions to pay its third parties for services and equipment provided as part of the Iran projects.
 
Specifically, from June 2012 to March 2013, TransTel conducted 104 separate transactions in violation of the Iran sanctions prohibition, totaling $11 million. As a result, six US banking institutions processed prohibited transactions involving the Iran projects. The 104 transactions contained no information referencing the Iran projects or the connection to Iran.
 
TransTel faced a penalty of $38 million but reduced the penalty to $12 million by cooperating with the OFAC investigation and enhancing its sanctions compliance program. TransTel did not disclose the conduct to OFAC.
 
IPSA International Services
 
On 10 August 2017, OFAC announced a settlement agreement with IPSA International Services, based in Phoenix, Arizona (“IPSA”) for $259,200 for 72 apparent violations of the Iran sanctions program. (See here for copy of settlement).
 
IPSA is an investigative company that provided due diligence services for citizenship for investment programs for financial institutions and a foreign country. Through two foreign subsidiaries, IPSA provided such services to a financial institution and a foreign country to investigate and conduct due diligence of several individuals, including some Iranian nationals.
 
In order to verify information in Iran, the IPSA subsidiaries hired subcontractors to collect, review and analyze information about individuals inside Iran. The subcontractors, in turn, hired Iranian third parties to validate information about these Iranian nationals.
 
On 44 occasions, IPSA imported Iranian-origin goods and services, i.e. information about Iran nationals. On 28 occasions, IPSA reviewed and initiated payments to providers of Iranian-origin services.
 
OFAC noted that IPSA did not disclose the conduct but IPSA enhanced its sanctions compliance program and cooperated with the OFAC investigations.

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MSEX/IM MOVERS & SHAKERS

MS_a215. 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 or amended listing this week.
 
* 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

* Amazon; Mexico City, Mexico; Mexico Trade Compliance Program Manager; Requisition ID: 520481 
* Amazon; Seattle WA;
NA Compliance Analyst; Requisition ID: 256357

* Ansell; Iselin NJ;
Senior Specialist NA Trade Compliance; Requisition ID: IRC6513

# Autodesk; San Rafael CA; 
Export Compliance Manager
; Requisition ID: 17WD24183
# Baylor University; Waco, TX; Manager/Director of Export Compliance; Vacancy ID S030428

* Berry Plastics Corporation; Evansville IN;
International Trade Compliance Administrator
; Requisition ID: 4054
# Carpenter Technology Corporation; Reading, PA; Senior Specialist, International Trade Compliance



DRS Technologies; Dayton OH;
Senior Trade Compliance Manager 

* Eaton; Titchfield, United Kingdom;
Global Trade Manager (Trade Compliance); Requisition ID: 020681
# Elbit Systems of America; NH, TX, AL; Licenses and Agreement Officer
; 2017-5671

*
 Esterline Technologies Corporation;
Bellevue, WA;
 
Manager, Trade Compliance Investigations and Disclosures


* Expeditors; Sunnyvale CA;
Customs Compliance Specialist
* Export Solutions Inc.; Melbourne FL; Trade Compliance Specialist;
info@exportsolutionsinc.com
# FLIR;
Wilsonville, OR/Billerica, MA
Director, Global Customs Compliance
# FLIR;
Wilsonville, OR/Billerica, MA/Arlington, VA; 
Sr. Corporate Counsel, Global Trade Compliance
# FLIR;
Wilsonville, OR/Billerica, MA; 
Senior Director, Dual-Use Licensing

* 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; Compliance Officer

SHC-LC-17-19648

* George Washington University; Washington DC;


Research Compliance Officer, Export Control
; Requisition ID: PI97906765


Harris Corporation; Clifton, New Jersey;
Trade Compliance Analyst
;
lsolomon@harris.com
; Requisition ID: ES20171608-20394 


Harsco; Columbia, SC; 
Import/Export Specialist

# Henderson Group Unlimited, Inc.; Alexandria, VA;
Defense Controls Analyst – Office of Defense Trade Controls Licensing

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

*
Intel Corporation; Gdansk, Poland or Swindon/High Wycombe, England, UK;
EMEA Export Project Manager / Trade Specialist
; Job ID JR0033212; OR contact 
Joy Robins
# Jet Propulsion Laboratory; Pasadena, CA;
Export Compliance Advisor III

* Johnson and Johnson; Skillman, NJ;
Export Trade Compliance Lead

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

* Lutron; Coopersburg PA;
Trade Manager-Export
; Requisition ID: 2926
* 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; Simi Valley, CA;
Trade Compliance Officer
* Meggitt PLC; Akron, OH;
Import Specialist;

*
 
NetApp; Singapore; Trade Compliance Mananger – APAC; Requisition ID 43338BR

* Nissan/Kelly Services; Franklin, TN;
CONTRACT Position – Contract Customs Compliance Analyst;
frankie.bryson@nissan-usa.com; Requisition ID: 55224BR

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

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

* Northrop Grumman Sperry Marine; New Malden, UK;
Trade Compliance Coordinator
;
careers.uk@sperry.ngc.com
* Northrop Grumman; Herndon, VA;
International Trade Compliance 5; Requisition ID: 17018159

* 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
# Raytheon; Arlington, VA;
Export License and Compliance Manager; Requisition ID: 97599BR

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

# The Safariland Group; Jacksonville, FL; 
Import/Export Director
;  
amber.hobble@safariland.com
; Requisition ID: 2017-1855

* Science and Engineering Services, LLC; Huntsville AL;
Export Compliance Specialist
bob.davis@ses-i.com; Requisition ID: 157
* Sierra Nevada Corporation; Arlington, VA; 
International Trade Compliance Analyst II; Req ID: R0003259

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

* Tesla Motors; Fremont CA; 
Global Supply Manager – International Logistics
; Requisition ID: 49362

* 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; Chula Vista CA; 
ITC Operational Excellence Manager
; Requisition ID: 49904BR
# United Technologies Corporation, UTC Aerospace Systems; Troy OH;
Sr. Manager, Intl Trade Compliance
Requisition ID: 44065BR 
# United Technologies Corporation, UTC Aerospace Systems; Chula Vista CA;
ITC Specialist
; Requisition ID: 51240BR
# United Technologies Corporation, UTC Aerospace Systems; Chula Vista CA;
ITC Specialist
; Requisition ID: 51710BR
# United Technologies Corporation, UTC Aerospace Systems; Chula Vista CA;
Sr Eng, ITC
; Requisition ID: 48780BR
# United Technologies Corporation, UTC Aerospace Systems; Westford MA;
Sr Analyst, ITC
; Requisition ID: 51450BR
# United Technologies Corporation, UTC Aerospace Systems; Charlotte NC;
Sr Analyst, ITC;
Requisition ID: 51733BR

* 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
; Requisition ID: 1700001087

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

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a116
.

ECTI Presents “Specially Designed: Increase Your Accuracy and Decrease Burdensome Controls Webinar – A Two Part Series” on 14 & 28 Sep

 
* What: Specially Designed: Increase Your Accuracy and Decrease Burdensome Controls – A Two Part Series
* When: 14 Sep 2017 (Part 1) and 28 Sep 2017 (Part 2); 1:00 p.m. (EDT)
* Where: Webinars (two part series)
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: John Black
* Register: Here or Danielle McClellan, 540-433-3977, danielle@learnexportcompliance.com.

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ENEDITOR’S NOTES

* Saint Francis de Sales (21 Aug 1567 – 28 Dec 1622; was a Bishop of Geneva and is honored as a saint in the Catholic Church. He became noted for his deep faith and his gentle approach to the religious divisions in his land resulting from the Protestant Reformation. He is known also for his writings on the topic of spiritual direction and spiritual formation, particularly the Introduction to the Devout Life and the Treatise on the Love of God.)
  – “Never be in a hurry; do everything quietly and in a calm spirit. Do not lose your inner peace for anything whatsoever, even if your whole world seems upset.”
  – “Half an hour’s meditation each day is essential, except when you are busy. Then a full hour is needed.”
 
Monday is pun day.
 
A guy walks into a library and ask the librarian for a recommendation on what classic to read. The librarian asks him, “Do you like Kipling?”  The guy replies, “I don’t know … I’ve never Kipled.”
  – Steve Duprey, Phelps, NY
 
Q. What washes up on very tiny beaches?
A. Microwaves.
  – Amanda Whinery, Oxford, OH

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EN_a318
. 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: 28 Jul 2017: 82 FR 35064-35065: Technical Corrections to U.S. Customs and Border Protection Regulations
 
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: 15 Aug 2017: 
82 FR 38764-38819: Wassenaar Arrangement 2016 Plenary Agreements Implementation

  
*
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 (18 July 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, Census/AES guidance, and to many errors contained in the official text. 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: 25 Jul 2017: Harmonized System Update 1706, containing 834 ABI records and 157 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.

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EN_a0319. 
Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

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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