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17-1106 Monday “Daily Bugle”

17-1106 Monday “Daily Bugle”

Monday, 6 November 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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  1. U.S.-China Economic Security Review Commission Announces Public Release of its 2017 Annual Report to Congress on 15 Sep in Washington DC
  1. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Announces ACE Certification Manufacturer ID Deployment on 7 Nov
  4. DHS/ICE: “Former U.S. Army Recruiter from San Antonio Sentenced to More Than 16 Years in Federal Prison for Straw Purchasing Firearms for Gulf Cartel”
  5. State/DDTC: (No new postings.)
  6. EU Implements Regulation Concerning the Classification of Certain Goods in the Combined Nomenclature
  7. Sweden Releases Report on Strategic Export Control Policy in 2016
  1. The Guardian: “Airbus Braces for a Difficult Landing After Corruption Allegations”
  2. The Jerusalem Post: “Report: Dutch Technology May Have Helped Advance Iran’s Weapons Program”
  3. Reuters: “U.S. Monitoring Sanctions Regime in Response to Myanmar Situation: Official”
  4. Wall Street Journal: “An Effective Cyber Breach Response Requires Practice”
  1. J. Killick, R. Burke & N. Erb: “State Department Identifies Parties Operating in Defense and Intelligence Sectors of Russian Federation”
  2. M. Hedwall: “The Swedish Government Proposes Stricter Rules on Weapon Export”
  3. R.L. Cassin: “Airbus Graft Probe Spreads to United States”
  4. T.B. McVey: “Is Your Business Required to Register Under ITAR?”
  1. Monday List of Ex/Im Job Openings
  1. ECTI Presents U.S. Export Control (ITAR/EAR/OFAC) Seminar Series on 22-25 Jan in San Diego, CA
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (28 Sep 2017), DOD/NISPOM (18 May 2016), EAR (1 Nov 2017), FACR/OFAC (31 Oct 2017), FTR (20 Sep 2017), HTSUS (20 Oct 2017), ITAR (30 Aug 2017) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMEX/IM ITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1.
U.S.-China Economic Security Review Commission Announces Public Release of its 2017 Annual Report to Congress on 15 Sep in Washington DC

(Source: Federal Register, 6 Nov 2017.) [Excerpts.]
 
82 FR 51475: Notice of Open Public Event
 
* AGENCY: U.S.-China Economic and Security Review Commission.
* ACTION: Notice of open public event.
* SUMMARY: Notice is hereby given of the following open public event of the U.S.-China Economic and Security Review Commission.
  The Commission is mandated by Congress to investigate, assess, and report to Congress annually on “the national security implications of the economic relationship between the United States and the People’s Republic of China.” Pursuant to this mandate, the Commission will hold a public release of its 2017 Annual Report to Congress in Washington, DC on November 15, 2017.
* DATES: The release is scheduled for Wednesday, November 15, 2017 from 9:00 a.m. to 10:00 a.m. …
* SUPPLEMENTARY INFORMATION: Topics to Be Discussed: The Commission’s 2017 Annual Report to Congress addresses the following topics:
  – U.S.-China Economic and Trade Relations, including: Year in Review: Economics Trade; Chinese Investment in the United States; and U.S. Access to China’s Consumer Market.
  – U.S.-China Security Relations, including: Year in Review: Security and Foreign Affairs; China’s Military Modernization in 2017; and Hotspots along China’s Maritime Periphery.
  – China and the World, including: China and Continental Southeast Asia; China and Northeast Asia; China and Taiwan; China and Hong Kong; and China’s Domestic Information Controls, Global Media Influence, and Cyber Diplomacy.
  – China’s High-Tech Development, including China’s Pursuit of Dominance in Computing, Robotics, and Biotechnology; and China’s Pursuit of Advanced Weapons. …
 
  Dated: November 1, 2017.
Michael Danis, Executive Director, U.S.-China Economic and Security Review Commission.

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OGSOTHER GOVERNMENT SOURCES

OGS_a12. 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_a34.

DHS/CBP Announces ACE Certification Manufacturer ID Deployment on 7 Nov

(Source: CSMS# 17-000698, 6 Nov 2017.) 

There will be an ACE CERTIFICATION Manufacturer ID (MID) deployment on Tuesday morning, November 7, 2017, in the 0600 – 0700 ET window.
 
To be deployed:
  – CAOM-13659 – ACE System Failure was returned when Filler positions did not contain spaces.
  – CAOM-13661 – Add Manufacturer Name & Address ($I) message input accepted with blank ABI Filer code in both in B, Y record at the same time.

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

OGS_a45
.

DHS/ICE: “Former U.S. Army Recruiter from San Antonio Sentenced to More Than 16 Years in Federal Prison for Straw Purchasing Firearms for Gulf Cartel”

(Source:
DHS/ICE, 2 Nov 2017.) [Excerpts.]
 
A former U.S. Army sergeant was sentenced Thursday to more than 16 years in federal prison following his role in a straw purchasing scheme that involved firearms smuggled to the Gulf Cartel. …
 
Julian Prezas, 37, from San Antonio was sentenced Nov. 2 by U.S. District Judge Orlando Garcia to 200 months in prison, three years of supervised release, and he must pay a $600 special assessment fee.  On Dec. 12, 2016, Prezas pleaded guilty to five counts of making a false statement during the purchase of firearms and one count of attempting to export into Mexico defense articles on the U.S. Munitions List without obtaining a license or written authorization. By pleading guilty, Prezas admitted to conspiring with others from April to August 2015 to illegally purchase more than 40 assault rifles. 
 
According to court records, Prezas was the actual purchaser of the firearms even though his co-defendants, other former U.S. Army soldiers, falsely indicated on their ATF form 4473 that they were buying the firearms at the time of purchase. Furthermore, Prezas, at times while in uniform and in a government vehicle, admittedly delivered the firearms to multiple individuals, one of whom was delivering them to members of the Gulf Cartel in Mexico. … 


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

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OGS_a78

Sweden Releases Report on Strategic Export Control Policy in 2016

(Source:
Government Offices of Sweden, 3 Nov 2017.)
 
In this report, the Swedish Government provides an account of Sweden’s export control policy with respect to military equipment and dual-use items in 2016.
 
Report

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

NWSNEWS

NWS_a1
9.
The Guardian: “Airbus Braces for a Difficult Landing After Corruption Allegations”

(Source: The Guardian, 5 Nov 2017.) [Excerpts.]
 
  “Prepare for turbulent and confusing times” is rarely a reassuring injunction, least of all in an all-staff email from the boss. But those were the words of Thomas Enders, chief executive of Airbus, as he warned employees in October that they would soon be reading about yet another allegation of corruption in the morning papers.
 
Within days the German magazine Der Spiegel had published a lengthy investigative piece alleging that Europe’s largest aerospace multinational had operated a London slush fund, distributing millions of dollars to accounts held by companies in tax havens. Before the month was out, the firm would reveal to investors that it had reported itself to authorities in the US, this time over potentially breaching regulations on the use of agents to sell sensitive weapons technology. …
 
U.S. disclosures are the latest to augur potential damage. During a conference call with shareholders last Tuesday, the company revealed that it had informed the US state department about inaccuracies discovered in historical regulatory filings about its use of commercial agents. The filings related to the US International traffic in arms regulations, which are intended to preserve American control over sensitive weapons technology. … 

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

NWS_a2
10. The Jerusalem Post: “Report: Dutch Technology May Have Helped Advance Iran’s Weapons Program”

(Source: The Jerusalem Post, 4 Nov 2017.) [Excerpts.]
 
Iran, along with Syria and Pakistan, may have obtained technology that can be applied to military programs that can cause widespread destruction, intelligence services in the Netherlands said late last month.
 
  “Dutch technology was used in programs of weapons of mass destruction and means of delivery in Iran, Pakistan or Syria,” wrote the Dutch ministers of defense, foreign affairs and foreign trade in a letter sent to the lower house of parliament in the last week of October.
 
The ministers said Dutch intelligence services are aware of “indications in a number of cases” where technology from the Netherlands played a role in weapons of mass destruction programs, reported ANP, the country’s largest news agency.
 
Onno Eichelsheim, the head of the Dutch Military Intelligence and Security Service, told ANP in September that his country is “almost a supermarket for countries that want to develop these types of weapons.” … 

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NWS_a3
11. Reuters: “U.S. Monitoring Sanctions Regime in Response to Myanmar Situation: Official”

(Source: Reuters, 4 Nov 2017.) [Excerpts.]
 
The U.S. government will constantly monitor its sanctions regime to respond to violence in Myanmar’s Rakhine state that has sent hundreds of thousands of Rohingya Muslim refugees across the border to Bangladesh, a senior U.S. official said on Saturday.
 
  “We are constantly evaluating the situation,” Simon Henshaw, Acting Assistant Secretary of State for the Bureau of Population, Refugees, and Migration, told reporters at a news briefing in Dhaka after visiting camps in Cox’s Bazar where hundreds of thousands of Rohingya refugees are sheltering.
 
  “Congress has given us a number of tools we can use,” he said, noting disturbing reports of atrocities in Rakhine state.
 
  “We call for a full investigation of these reports, we call for those who committed (the atrocities) to be held accountable,” he said. … 

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NWS_a4
12. Wall Street Journal: “An Effective Cyber Breach Response Requires Practice”

(Source: Wall Street Journal, 3 Nov 2017.) [Excerpts; subscription required.]
 
A lot of companies with cybersecurity programs will have a process or a playbook for what to do when a breach occurs, but when it comes to executing the plan while an event is happening, the chances for success rise if there was some practice of the plan before it is implemented for real. 

Sean Curran, senior director at firm West Monroe Partners, a business and technology consulting firm, said planning starts by having the right people involved. With a team in place, begin to walk through the process and ask each person what they would do, then ask what they would do next, he said. That includes any outside response, so make sure public relations is included, said Mr. Curran. “It’s not just what happens in the event of a breach and talking through that talking, it’s about what actual steps to take, who would be responsible?” asked Mr. Curran. “If an organization walks through these it will know exactly what [should happen], instead of working it out at the time.” … 

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COMMCOMMENTARY

COMM_a01
13.
J. Killick, R. Burke & N. Erb: “State Department Identifies Parties Operating in Defense and Intelligence Sectors of Russian Federation”

(Source: White & Case LLP, 3 Nov 2017.)
 
* Authors: James Killick, Esq., jkillick@whitecase.com; Richard Burke, Esq., rburke@whitecase.com; and Nicole Erb, Esq., nerb@whitecase.com. All of White & Case LLP.
 
On October 27, 2017, the US Department of State issued public guidance on the implementation of Section 231 of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA). CAATSA requires the imposition of certain sanctions on persons who have knowingly engaged in a significant transaction, on or after August 2, 2017, with a person that is part of or operating for or on behalf of the defense or intelligence sectors of the Government of the Russian Federation. The guidance specifies 39 entities that the State Department determined are part of, or are operating for or on behalf of, the defense or intelligence sectors of the Government of the Russian Federation. [FN/1]
 
Beginning on or after January 29, 2018, the President will be required to impose certain secondary sanctions (selected from a menu of potential measures provided in Section 235 of CAATSA) on persons who have knowingly engaged in a significant transaction on or after August 2, 2017 with any of the entities identified in the guidance. Secondary sanctions can be imposed upon non-US persons for engaging in certain activities outside of the United States that have been deemed “sanctionable” by the US government. Secondary sanctions can be imposed even where activities have no connection to the United States.
 
State Department Guidance
 
The State Department determined that the following entities operate for or on behalf of the defense sector of the Government of the Russian Federation:
 
  – Admiralty Shipyard JSC Almaz-Antey Air and Space Defense Corporation
  – JSC Dolgoprudny Research Production JSC Federal Research and Production Center Titan
  – Barrikady JSC (Titan Design Bureau)
  – Izhevsk Mechanical Plant (Baikal)
  – Izhmash Concern JSC
  – Kalashnikov Concern JSC
  – Kalinin Machine Building Plant JSC (KMZ)
  – KBP Instrument Design Bureau
  – MIC NPO Mashinostroyenia
  – Molot Oruzhie
  – Mytishchinski Mashinostroitelny Zavod
  – Novator Experimental Design Bureau
  – NPO High Precision Systems JSC
  – NPO Splav JSC
  – Oboronprom OJSC
  – Radio-Electronic Technologies (KRET)
  – Radiotechnical and Information Systems (RTI) Concern
  – Research and Production Corporation Uralvagonzavod JSC
  – Rosoboronexport OJSC (ROE) Rostec (Russian Technologies State Corporation)
  – Russian Aircraft Corporation MiG
  – Russian Helicopters JSC
  – Sozvezdie Concern JSC
  – State Research and Production Enterprise Bazalt JSC
  – Sukhoi Aviation JSC
  – Tactical Missiles Corporation JSC
  – Tikhomirov Scientific Research Institute JSC
  – Tupolev JSC
  – United Aircraft Corporation
  – United Engine Corporation
  – United Instrument Manufacturing Corporation
  – United Shipbuilding Corporation
 
In addition, the State Department determined that the following entities operate for or on behalf of the intelligence sector of the Government of the Russian Federation:
 
  – Autonomous Noncommercial Professional Organization/Professional Association of Designers of Data Processing (ANO PO KSI)
  – Federal Security Service (FSB)
  – Foreign Intelligence Service (SVR)
  – Main Intelligence Directorate of the General Staff of the Russian Armed Forces (GRU)
  – Special Technology Center
  – Zorsecurity
 
Many of these entities appear to have been designated previously on the US Department of the Treasury Office of Foreign Assets Control’s (OFAC) List of Specially Designated Nationals and Blocked Persons (SDN List) under the Ukraine-/Russia-related sanctions and Cyber-related sanctions. U.S. persons [FN/2] are prohibited from dealing in any property or interests in property of these parties. Additionally, a number of these entities appear to have been designated previously on OFAC’s Sectoral Sanctions Identifications List (SSI List) under Directive 3 of the Ukraine-/Russia-related sectoral sanctions. These sanctions prohibit US persons from dealing in new debt with a maturity of greater than 30 days for parties designated under Directive 3.
 
Sanctions Measures
 
Section 231 of CAATSA requires the President to impose, on January 29, 2018 and thereafter, five or more of the following sanctions measures on persons who have knowingly engaged in a significant transaction with any of the above listed entities on or after the date of enactment of CAATSA (August 2, 2017):
 
  – Denial of Export-Import Bank financing. The President may direct the Export-Import Bank of the United States not to give approval to the issuance of any guarantee, insurance, extension of credit, or participation in the extension of credit in connection with the export of any goods or services to the sanctioned person.

  – Export Sanctions. The President may order the United States Government not to issue any specific license and not to grant any other specific permission or authority to export any goods or technology to the sanctioned person under the Export Administration Act of 1979, the Arms Export Control Act, the Atomic Energy Act of 1954, or any other statute that requires the prior review and approval of the United States Government as a condition for the export or reexport of goods or services.

  – Loans from US financial institutions. The President may prohibit any United States financial institution from making loans or providing credits to the sanctioned person totaling more than $10,000,000 in any 12-month period unless the person is engaged in activities to relieve human suffering and the loans or credits are provided for such activities.

  – Loans from international financial institutions. The President may direct the United States executive director to each international financial institution to use the voice and vote of the United States to oppose any loan from the international financial institution that would benefit the sanctioned person.

  – Prohibitions on financial institutions. The following prohibitions may be imposed against the sanctioned person if that person is a financial institution.

  – Prohibition on designation as a primary dealer. Neither the Board of Governors of the Federal Reserve System nor the Federal Reserve Bank of New York may designate, or permit the continuation of any prior designation of, the financial institution as a primary dealer in United States Government debt instruments.

  – Prohibition on service as repository for government funds. The financial institution may not serve as agent of the United States Government or serve as repository for United States Government funds.

  – Procurement sanction. The United States Government may not procure, or enter into any contract for the procurement of, any goods or services from the sanctioned person.

  – Foreign exchange. The President may, pursuant to such regulations as the President may prescribe, prohibit any transactions in foreign exchange that are subject to the jurisdiction of the United States and in which the sanctioned person has any interest.

  – Banking transactions. The President may, pursuant to such regulations as the President may prescribe, prohibit any transfers of credit or payments between financial institutions or by, through, or to any financial institution, to the extent that such transfers or payments are subject to the jurisdiction of the United States and involve any interest of the sanctioned person.

  – Property transactions. The President may, pursuant to such regulations as the President may prescribe, prohibit any person from (1) acquiring, holding, withholding, using, transferring, withdrawing, transporting, importing, or exporting any property that is subject to the jurisdiction of the United States and with respect to which the sanctioned person has any interest; and (2) dealing in or exercising any right, power, or privilege with respect to such property; or conducting any transaction involving such property.

  – Ban on investment in equity or debt of such person. The President may, pursuant to such regulations or guidelines as the President may prescribe, prohibit any United States person from investing in or purchasing significant amounts of equity or debt instruments of the sanctioned person.

  – Exclusion of corporate officers. The President may direct the Secretary of State to deny a visa to, and the Secretary of Homeland Security to exclude from the United States, any alien that the President determines is a corporate officer or principal of, or a shareholder with a controlling interest in, the sanctioned person.

  – Sanctions on principal executive officers. The President may impose on the principal executive officer or officers of the sanctioned person, or on persons performing similar functions and with similar authorities as such officer or officers, any of the sanctions under this subsection.
 
Transactions Subject to Sanctions
 
As noted above, Section 231 provides for the imposition of sanctions only where a person engages in a “significant transaction” relating to the Russian defense or intelligence sectors. The term “significant transaction” is not expressly defined in the Act. The State Department’s guidance notes that, in determining whether a transaction is “significant” for purposes of Section 231, it will consider “the totality of the facts and circumstances surrounding the transaction and weigh various factors on a case-by-case basis.” [FN/3] The factors considered in the determination may include, but are not limited to:
 
  – The significance of the transaction to US national security and foreign policy interests, in particular whether it has a significant adverse impact on such interests;
  – The nature and magnitude of the transaction; and
  – The relation and significance of the transaction to the defense or intelligence sector of the Russian government.
 
The guidance also states that, in the initial implementation stage, the State Department intends to focus on “significant transactions of a defense or intelligence nature with persons named in the Guidance,” and that, if a transaction for goods or services has “purely civilian end-uses and/or civilian end-users, and does not involve entities in the intelligence sector, these factors will generally weigh heavily against a determination that such a transaction is significant for purposes of Section 231.”
 
The State Department also explained that if a transaction is necessary to comply with rules and regulations administered by the Federal Security Service, or law enforcement or administrative actions or investigations involving the Federal Security Service, including rules and regulations administered by the Federal Security Service for the importation, distribution, or use of information technology products in the Russian Federation and the payment of any fees to the Federal Security Service for such licenses, permits, certification, or notifications, then these factors will weigh heavily against a determination that that such transaction is significant for purposes of this Section 231.
 
Companies will need to assess whether transactions with these entities could be considered “significant” in light of the factors described above. These assessments will need to be conducted on a case-by-case basis, taking into account any available guidance and enforcement trends in this area.
 
Companies doing business or looking to do business in Russia should monitor closely any measures imposed by the United States to ensure compliance. Penalties for noncompliance can be severe.

———
  [FN/1] See here.
  [FN/2] US persons include US citizens and permanent residents, wherever located, entities organised under US law (including foreign branches), and parties located within the United States. 
  [FN/3] See here.

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COMM_a2
14. M. Hedwall: “The Swedish Government Proposes Stricter Rules on Weapon Export”

(Source: Global Compliance News, 5 Nov 2017.)
 
* Author: Matthias Hedwall, Esq., Matthias.Hedwall@bakermckenzie.com, Baker McKenzie, Stockholm.
 
On 24 October 2017, the Swedish government proposed stricter rules on weapon export. The proposal suggests that the destination country’s democratic status shall be of central consideration in a license application. The less democratic standing, the harder to get approval for the export of the military equipment. No license will be approved if there are serious violations on human rights or demerits on the country’s democratic standing. Also, whether the export countervails a sustainable development in the country will be considered during a license application.
 
The government has also appointed the advisory authority, Inspectorate of Strategic Products, to research and propose a control system for the exported military equipment. This is aimed to obtain additional tools to ensure that military equipment brought out of Sweden goes to intended recipients, thus preventing diversion to unauthorized recipients.
 
Moreover, a researcher will analyse how to consolidate the national guidelines for the export control related to military equipment with the international requirements.
 
The rules are proposed to enter into force on 15 April 2018.

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COMM_a3
15. R.L. Cassin: “Airbus Graft Probe Spreads to United States”

(Source:
The FCPA Blog
, 2 Nov 2017.) [Excerpts.]
 
* Author: Richard L. Cassin, publisher and editor of the FCPA Blog. Contact Mr. Cassin at
rlc@fcpablog.com
.
 
Airbus Group SE, already under investigation in the UK and France for suspected corruption, said in a company release Tuesday that it found “inaccuracies in filings” made with the U.S. Department of State under the International Traffic in Arms Regulations.
 
The Toulouse, France-based aircraft maker said it disclosed the inaccuracies to “U.S. authorities.” Airbus didn’t say which U.S. authorities it talked to but
said
it is cooperating.
 
The International Traffic in Arms Regulations include requirements for exporters to disclose to the State Department payments to third-party intermediaries for certain overseas sales.
 
Last year the UK Serious Fraud Office
confirmed
that it had opened an investigation into Airbus Group for criminal fraud, bribery, and corruption.
 
The SFO said “the allegations relate to irregularities concerning third party consultants.” …
 
[Editor’s Note: Due to copyright restrictions, we are not authorized to include the entire article. To read the entire article, click on the source link above.]

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COMM_a4
16. T.B. McVey: “Is Your Business Required to Register Under ITAR?”

(Source: American Shipper, 27 Oct 2017.) [Excerpts.]
 
* Author: Thomas B. McVey, Chair of the International Practice Group of Williams Mullen, tmcmcvey@williamsmullen.com.
 
Under the U.S. State Department’s International Traffic In Arms Regulations, parties that manufacture, export or temporarily import “defense articles” or furnish “defense services” are required to register with the Directorate of Defense Trade Controls.
 
One of the more frequently asked compliance questions among government contracts firms is whether they are required to register under the International Traffic In Arms Regulations (ITAR).
 

ITAR are the U.S. State Department controls that regulate defense products, technical data and services. Under ITAR 22 CFR §122.1, parties that manufacture, export or temporarily import “defense articles” or furnish “defense services” are required to register with the Directorate of Defense Trade Controls (DDTC) within the State Department. … 


[Editor’s Note: Due to copyright restrictions, we are not authorized to include the entire article. To read the entire article, click on the source link above.]

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MSEX/IM MOVERS & SHAKERS

MS_a217. Monday List of Ex/Im Job Openings; 98 Jobs Posted This Week, Including 18 New Jobs

(Source: Editor)  
 
Published every Monday or first business day of the week. Please, send job openings in the following format to jobs@fullcirclecompliance.eu.
 
* COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFORMATION; REQUISITION ID
 


#
” New or amended listing this week (
18
 new jobs)

* Aerojet Rocketdyne; Huntsville, AL, or Camden, AR; 
Senior International Trade and Compliance Analyst
; Requisition ID: 12620

*
Airbus; Barajas, Spain;
Export Control Officer 

* Airbus; Sevilla, Spain;
Export Control Officer
* Airbus; Getafe, Spain;
Export Control Officer

* Autodesk; San Rafael CA; 
Export Compliance Manager
; Requisition ID: 17WD24183


BAE Systems; Wayne, NJ; Contracts Summer Internship Program; Requisition ID: 30622BR

*
BAE Systems; Nashua, NH: Import Export Analyst II; Requisition ID: 26285BR

* Baylor University; Waco, TX;
Manager/Director of Export Compliance; Vacancy ID S030428
* Boeing; St. Louis, MO;
Trade Control Specialist
1700011280


Boeing; St. Louis, MO;
Trade Control Specialist

1700012448

* DynCorp International; Springfield, VA;
Logistics Analyst Senior (ITAR/CCI Officer)


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

* EY; Belgium; 
Senior Consultant, Global Trade; Requisition ID: BEL000PT

* FLIR;
Wilsonville, OR/Billerica, MA; 
Senior Director, Dual-Use Licensing 
* FLIR; Multiple Locations;
Senior Director, Global Regulatory Affairs 
* FLIR; Meer, Belgium;
Global Trade Compliance Administrator 
* FLIR; Billerica, MA;
International Export/Import Analyst 

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

*
 
General Atomics Aeronautical Systems, Inc.; San Diego, CA; International Contracts Manager; Requistion ID: 13583BR

*
 
General Atomics; San Diego, CA; Sr. Director of Import/Export Compliance; Job ID: 13892BR

*
 
General Atomics; San Diego, CA; Contracts Compliance Specialist; Requistion ID: 12839BR
 
# General Atomics; San Diego, CA; International Contracts Manager; Requisition ID: 14362BR
# General Atomics; San Diego, CA; International Trade Compliance Administrator; Requisition ID: 12690BR
# General Atomics; San Diego, CA; Senior Import Export Administrator; Requisition ID: 14438BR
# General Atomics; Huntsville, AL; Experienced Contracts Manager / Huntsville; Requisition ID: 13018BR

# General Atomics; San Diego, CA;
Contract Administrator / International;
Requisition ID: 13449BR
# General Atomics; San Diego, CA;
Experienced FMS International Contracts Administrator; Requisition ID: 14721BR



General Dynamics Land Systems; Sterling Heights, MI; Licensing Officer
; Requisition IDSHC-LC-17-20056

# General Dynamics Mission Systems; Scottsdale, Arizona;
Senior Contracts Manager; Requisition ID: 
2017-27442

# General Dynamics Mission Systems; Richardson, Texas; Senior Contracts Professional; Requisition ID: 2017-27389

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

* Georgia Institute of Technology; Atlanta, GA; Research Associate I; Requisition ID: PVA37002

* Georgia Institute of Technology; Atlanta, GA; Research Associate II; Requisition ID: PVA37001 


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

* Harris Corporation; Rochester, NY;
Technical Export Compliance Specialist; Job ID: CS20172308-20513

* Henderson Group Unlimited, Inc; Washington, DC; 
Process Improvement Mgr
* Henderson Group Unlimited, Inc; Washington, DC; 
Defense Control Analyst

* Henderson Group Unlimited, Inc; Washington, DC; 
Compliance Analyst;

* Johnson and Johnson; Skillman, NJ;
Export Trade Compliance Lead
* Lam Research; Fremont, CA;
Director, Foreign Trade, Export, and ITAR
* Lam Research; Fremont, CA;
Trade Classification Analyst

* Lennox International; Richardson, TX; 
Manager, Trade Compliance; Requisition ID: 2017-11661
* Livingston International; El Segundo, CA;
Research Consultant – ECCN Classification
* Livingston International; Taylor, Michigan;
Manager, Service Delivery
* Livingston International; El Segundo, CA;
ECCN Classification;
* Livingston International; El Segundo, CA;
HTS Classification;

* Lockheed Martin; Fort Worth, TX;
International Trade Compliance Export Advisor; Requisition ID: 402827BR

* Lockheed Martin; Grand Prairie, TX; 
International Trade Compliance Senior Manager; Requisition ID: 405533BR
* Lockheed Martin; Fort Worth, TX;
Aeronautics International Trade Compliance Senior Manager; Requisition ID: 407329BR
# Lockheed Martin; Manassas, VA;
International Licensing Analyst; Requisition ID: 399617BR
# Lockheed Martin; Shelton, CT;
International Trade Complaince Manager; Requisition ID: 403295BR

# Lockheed Martin; Ft Worth, TX; 
Senior Regulatory Compliance Analyst; Requisition ID: 
406664BR
# Lockheed Martin; Ft Worth, Texas; International Trade Compliance Engineer; Requisition ID: 411049BR_1
# Lockheed Martin; Orlando, FL; International Trade Compliance Engineer; Requisition ID: 411049BR_2

* Lutron; Coopersburg, PA;
Trade Manager-Export; Requisition ID: 2926
* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst; Requisition ID: 16000DYY
* Medtronic; Minneapolis, MN; 
Global Trade Supply Chain Director; Requisition ID: 17000FU4
* Medtronic; Minneapolis, MN; 
Global Trade Compliance Director; Requisition ID: 17000FC1

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

* Meggitt PLC; Simi Valley, CA;
Trade Compliance Officer

* Meggit PLC; San Diego, CA; 
Trade Compliance Officer; Requisition ID: 28255

* National Institute of Standards and Technology (NIST); Gaithersburg, MD;
Operations Research Analyst; Vacancy Number: NISTLP-2017-0003

* NetApp; Vienna, VA;
Industrial Security Program Officer;

* 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; Herndon, VA;
Manager, International Trade Compliance 2; Requisition ID: 17014690
* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 3; Requisition ID: 17020346

* Northrop Grumman; Rolling Meadows, IL;
International Trade Compliance Analyst 3; Requisition: 17015695
* Northrop Grumman; San Diego, CA; 
Reg Compliance Analyst 3/4; Requisition ID: 17016952

* OSI Optoelectronics; Hawthorne, CA;
Manager, Global Trade Compliance; Requisition ID: 12235; or contact 
Kim Butcher, Senior Talent Acquisition Partner;

* Raytheon; Andover, MA; 
Global Trade Principal Advisor/Manager; Requisition ID: 103111BR

* Raytheon; El Segundo, CA;
Global Trade Manager; Requisition ID: 
97898BR
* Raytheon; El Segundo, CA;
Global Trade Authorization Owner; Requisition ID: 100859BR
* Raytheon; El Segundo, CA;
Principal Global Trade Licensing; Requisition ID: 102832BR

Raytheon; El Segundo, CA; 
Sr. Regulatory Compliance Analyst; Requisition ID: 101593BR

* Raytheon; Tucson, AZ;
Export Compliance – Agreements Authorization Owner; Requisition ID: 99909BR
* Raytheon; McKinney, TX;
Principal Global Trade Licensing; Requisition ID: 101234 BR
# Science and Engineering Services, LLC (SES); Huntsville, AL;
Trade Compliance Administrator; OR: Contact 
julia.lang@ses-i.com
#
Science and Engineering Services, LLC (SES); Huntsville, AL;
Technical Writer II/ Trade Compliance
OR: Contact  
julia.lang@ses-i.com

* Ultra Electronics; Loudwater, United Kingdom;
International Trade Manager;

# United Technologies Corporation, UTC Aerospace Systems; Windsor Locks CT;
ITC Generalist, Operations and Licensing
;
Requisition ID: 54684BR
# United Technologies Corporation, UTC Aerospace Systems; Everet WA; 
International Trade Compliance Specialist
Requisition ID: 52787BR
# United Technologies Corporation, UTC Aerospace Systems; Westford MA;
International Trade Compliance Specialist
Requisition ID: 54366BR

* United Technologies Corporation, UTC Aerospace Systems; Chula Vista CA;
International Trade Compliance Specialist
; Requisition ID: 54684BR

* United Technologies Corporation, UTC Aerospace Systems; Foley AL; 
ITC Site Lead;
Requisition ID: 54820BR

* United Technologies Corporation, UTC Aerospace Systems; Troy OH; 
Director, International Trade Compliance
;
 Requisition ID: 53693BR

* United Technologies Corporation, UTC Aerospace Systems; Westford MA;
Senior International Trade Compliance Analyst
; Requisition ID: 54366BR

* The University of Georgia; Athens, GA; 
Director of the Center for International Trade & Security; Requisition ID: 2017_00504F

* Vigilant; Remote Opportunity; 
Classification Specialist

* Vigilant; Bhudapest, Hungary;
Jr. Compliance Specialist;

* Vigilant; Negotiable Location, USA;
Global Trade Compliance Analyst;

* Varian Medical Systems; Palo Alto, CA, Washington, D.C., or Atlanta, GA; 
Export/Sanctions Compliance Analyst; Req ID 12270BR

* Varian Medical Systems; Palo Alto, CA, Washington, D.C., or Atlanta, GA;  
Export/Sanctions Counsel; eq ID 12271BR

* Vista Outdoor; Overland Park, KS;
Import Specialist; Requisition ID: R0002750 or contact
holly.greenwood@vistaoutdoor.com

* Wurth Industry of North America; Sanford, FL; 
International Trade Compliance Specialist
; Requisition ID: 473-720

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TECEX/IM MOVERS & SHAKERS

TEC_a118. ECTI Presents U.S. Export Control (ITAR/EAR/OFAC) Seminar Series on 22-25 Jan in San Diego, CA

(Source: Jill Kincaid; jill@learnexportcompliance.com.)
 
* What: U.S. Export Control (ITAR/EAR/OFAC) Seminar Series in San Diego, CA
* When: ITAR Seminar: January 22-23, 2018; EAR/OFAC Seminar: January 24-25, 2018
* Where: San Diego: Doubletree Hotel – San Diego Downtown
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel: John Black, Scott Gearity, Greg Creeser, Marc Binder and Melissa Proctor
* Register: here, or Jessica Lemon, 540-433-3977, jessica@learnexportcompliance.com

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

ENEDITOR’S NOTES

 

* Will Durant (William James Durant; 5 Nov 1885 – 7 Nov 1981; was an American writer, historian, and philosopher. He is best known for the Pulitzer prize-winning, The Story of Civilization, eleven volumes written in collaboration with his wife, Ariel Durant. He was earlier noted for The Story of Philosophy, described as “a groundbreaking work that helped to popularize philosophy”.)
  – “Nature has never read the Declaration of Independence. It continues to make us unequal.”
  – “We are what we repeatedly do. Excellence, then, is not an act, but a habit.”
 
* Richard Jefferies (John Richard Jefferies; 6 Nov 1848 – 14 Aug 1887; was an English nature writer, noted for his depiction of English rural life in essays, books of natural history, and novels.)
  – “It would seem that the ant works its way tentatively, and, observing where it fails, tries another place and succeeds.”
 
Monday is pun day.
Q. Why did the waitress get arrested for giving a cigarette to her customer?
A. For contributing to the malignancy of a diner.
  – Mary Weare, Bartlesville, OK 

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

EN_a320
. 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 Sep 2017: 82 FR 45366-45408: Changes to the In-Bond Process [Effective Date: 27 Nov 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: 1 Nov 2017:
82 FR 50511-50517
: Export Administration Regulations for Use of License Exceptions; Clarifications
 

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 31 Oct 2017:
82 FR 50313-50315
: Global Terrorism Sanctions Regulations

 
*
FOREIGN TRADE REGULATIONS (FTR)
: 15 CFR Part 30
  – Last Amendment:
20 Sep 2017:
 
82 FR 43842-43844
: Foreign Trade Regulations (FTR): Clarification on Filing Requirements; Correction
 
  – HTS codes that are not valid for AES are available
here.
  – The latest edition (20 Sep 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: 20 Oct 2017: Harmonized System Update 1707, containing 27,291 ABI records and 5,164 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: 30 Aug 2017: 82 FR 41172-41173: Temporary Modification of Category XI of the United States Munitions List
  – The only available fully updated copy (latest edition: 1 Nov 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.

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

EN_a0321. 
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

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

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.

* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

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