;

17-1204 Monday “Daily Bugle”

17-1204 Monday “Daily Bugle”

Monday, 4 December 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. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Closes ACE User Satisfaction Survey on 8 Dec
  4. State/DDTC: (No new postings.)
  5. EU Adopts New Rules Against Unfair Trade Practices
  6. EU Amends Certain Specific Restrictions on Economic and Financial Relations with Iraq
  1. Interfax-Ukraine: “Ukraine Harmonizing Legal Framework for Export Control with EU Norms”
  1. M. Volkov: “Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy”
  2. T.B. McVey: “Small Businesses: Take Heed of Export Regulations”
  3. Gary Stanley’s ECR Tip of the Day
  1. Indialantic Rotary Club Presents: “Global Challenges: A Conversation with James Clapper”
  2. Monday List of Ex/Im Job Openings: 116 Jobs, Including 6 New Jobs
  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 (9 Nov 2017), FACR/OFAC (13 Nov 2017), FTR (20 Sep 2017), HTSUS (20 Oct 2017), ITAR (30 Aug 2017) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

[No items of interest noted today.] 

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

OGSOTHER GOVERNMENT SOURCES

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

[No items of interest noted today.]

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

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

OGS_a33.

DHS/CBP Closes ACE User Satisfaction Survey on 8 Dec

(Source:
CSMS# 17-000750, 4 Dec 2017.)
 
U.S. Customs and Border Protection (CBP) 2017 ACE User Satisfaction Survey, referenced in CSMS #17-000726, closes this week. CBP encourages all importers, brokers, carriers and other trade community users of ACE to take the 5-10 minute survey, which is voluntary and anonymous. The survey will remain open through Friday, December 8, 2017.
 
To access the survey, please click here.*
 
*This link takes you to a website created and maintained by a public and/or private organizations. For more information on the DHS Redirection linking policy go here.
 
  – Related CSMS No. 17-000726

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

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

OGS_a55.

EU Adopts New Rules Against Unfair Trade Practices

 
On 4 December, the Council approved new rules to help protect the EU against unfair trade practices. They will enter into force by 20 December.
 
This new anti-dumping methodology will identify and redress cases where prices of imported products are artificially lowered due to state intervention.
 
“Today we are strengthening our anti-dumping toolkit to provide a fair trade environment for EU producers. The new rules will be crucial in ensuring that all our trading partners are selling us their products at undistorted prices, and that fair market competition is respected.”
  – Urve Palo, Estonian minister responsible for trade

The new legal framework removes the former distinction between market and non-market economies for calculating dumping while maintaining the same level of protection for producers. The Commission will now need to prove the existence of a “significant market distortion” between a product’s sale price and its production cost. On that basis, it will be allowed to set a price for the product by referring for example to the price of the good in a country with a similar level of economic development or to relevant undistorted international costs and prices.
 
The Commission will also draft specific reports on countries or sectors describing distortions. In line with current practice, it will be for EU firms to file complaints, but they will be able to use the Commission’s reports to support their case.
 
Next Steps
 
The text adopted on 15 November by the European Parliament and on 4 December by the Council will be signed in Strasbourg on 13 December. The publication in the Official Journal of the regulation is expected on 19 December.  It will enter into force one day later, on 20 December 2017.
 
Background
 
The Commission proposed targeted amendments to the anti-dumping methodology in November 2016. This specific adaptation to the regulation on trade defense instruments – which is also in the process of being reviewed – is formulated in a country-neutral way and in full compliance with the EU’s WTO obligations.

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

OGS_a66.

EU Amends Certain Specific Restrictions on Economic and Financial Relations with Iraq

 
Regulations
* Commission Implementing Regulation (EU) 2017/2217 of 1 December 2017 amending Council Regulation (EC) No 1210/2003 concerning certain specific restrictions on economic and financial relations with Iraq. 

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

NWSNEWS

NWS_a1
7Interfax-Ukraine: “Ukraine Harmonizing Legal Framework for Export Control with EU Norms”

(Source: Interfax-Ukraine, 2 Dec 2017.).
 
Ukraine is harmonizing the regulatory and legal framework in the sphere of export control with EU norms.
 
According to a report on the website of the State Service of Export Control of Ukraine, now the service is finalizing the development of the draft law of Ukraine on amendments to the law of Ukraine on state control over international transfers of military and dual use goods, which provides for the harmonization of national procedures and rules of state export control with the norms and standards of the EU.
 
  “The bill includes three important areas of regulatory and legal regulation, namely: the harmonization of procedures and rules of state export control with the relevant EU norms and standards, the introduction of e-licensing and provision of administrative services, bringing the law in line with the law of Ukraine on administrative services in part concerning the determination of the cost of providing administrative services rendered by the State Service of Export Control of Ukraine,” reads the document.

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

COMMCOMMENTARY

COMM_a01
8. M. Volkov: “Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy”

(Source: Volkov Law Group Blog, 3 Dec 2017. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
 
In a significant FCPA enforcement development, DOJ’s Deputy Attorney General (“DAG”) Rod Rosenstein last announced the implementation of a new FCPA Corporate Enforcement Policy. (available here).  The announcement was not a surprise based on earlier statements made by DAG Rosenstein.
 
Before outlining the specific five takeaways, there are a few issues surrounding the release of the new policy that require some comment. DAG Rosenstein implemented the policy without typical fanfare or release of a policy memorandum, which would bear his name, the Rosenstein Memorandum. Instead, DOJ announced specific amendments to the US Attorney’s Manual that implements the new policy and governs all federal prosecutions.
 
Interestingly, the new policy is limited to FCPA enforcement actions and does not extend to any other corporate criminal activity, such as fraud, antitrust cartels, or tax. The justification for this limitation is the “inherent international nature” of FCPA investigations and prosecutions. Given the difficulty of international criminal investigations, the new policy is intended to provide increased incentives to corporations to voluntarily disclose, cooperate and remediate their compliance programs.
 
With these general observations, the five key takeaways from the new policy include:
 
Presumption of Declination
: Companies can earn a presumption of a declination when they comply with the FCPA Enforcement Policy requirements that they voluntarily disclose potential wrongdoing, cooperate with the Justice Department’s investigation and remediate any potential deficiencies in the company’s compliance program. The new enforcement policy preserves the ability of DOJ to prosecute a company when “aggravating circumstances” are present, including (but not limited to) involvement by executive management of the company in the misconduct; a significant profit to the company from the misconduct; pervasiveness of the misconduct within the company; and criminal recidivism.
 
The presumption of a declination is a significant incentive for corporations to re-calculate the balance between disclosure and cooperation against non-disclosure and remediation. Even when DOJ declines to prosecute a company, DOJ stated companies would be required to pay disgorgement, forfeiture or restitution, if applicable.
 
Fixed 50 Percent Discount
: Under the new FCPA Corporate Enforcement Policy, companies that do not qualify for a declination (presumably because of the presence of aggravating factors) can still earn a 50 percent discount from the bottom of the Sentencing Guidelines range, and will usually avoid the imposition of a corporate monitor. The key features here are two – a guarantee of a 50 percent discount and the probable avoidance of a corporate monitor. The two features outlined in Numbers 1 and 2 provide significant incentives for companies contemplating voluntary disclosure and cooperation to seek the benefits under the new program.
 
In the event that a company does not qualify for a voluntary disclosure but cooperates and remediates its compliance program, the company can still earn up to a 25 percent discount from the bottom of the Sentencing Guidelines range.
 
Root Cause Analysis: The new FCPA Corporate Enforcement Policy contains two significant additions to the remediation prong. The first relates to a root cause analysis and the second to the role of a chief compliance officer.  To qualify under the remediation prong, a company must conduct a “root cause analysis.”
 
The “root cause” analysis has taken on greater significance through the years, and is an important inquiry needed to understand why financial and compliance controls were not able to detect and prevent the illegal conduct. It is a more intensive review and analysis than a risk and compliance program assessment, and is targeted to the specific facts underlying the violations.
 
Chief Compliance Officer Role
: The Justice Department’s remediation requirement includes a modification from the FCPA Pilot Program. The original language included the factor, “The independence of the compliance function.” The new FCPA Corporate Enforcement Policy added the following italicized language:
 
The authority and independence of the compliance function and the availability of compliance expertise to the board;
 
The new language includes the addition of “authority” of the compliance function, and the reporting   relationship of the compliance function to the board of directors. I am not trying to make a mountain out of a molehill but the term “authority” reinforces the overall trend of maintaining an empowered CCO in corporate governance structures. Additionally, the CCO’s access to the board and regular reporting to the board is emphasized with the new language, and reflects increasing concern over the importance of regular reporting by the CCO to the board.
 
Document Retention
: The FCPA Corporate Enforcement Policy adds a new factor relating to document preservation requiring companies to maintain appropriate retention of business records and prohibiting the destruction or deletion of business records, including software that generates communications but does not retain business records (e.g. SnapChat). The Justice Department’s concern about document retention reflects unfortunate experiences when companies fail to retain documents or use technologies that do not retain the record of the communications.

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COMM_a2
9T.B. McVey: “Small Businesses: Take Heed of Export Regulations”

(Source:
National Defense Magazine
, Dec 2017 Issue.)
 
* Author: Thomas B. McVey, Chair of the International Practice Group of Williams Mullen,
tmcmcvey@williamsmullen.com
.
 
A recently announced enforcement case involving a supplier of military spare parts sends a valuable message to small- and mid-sized defense contractors regarding compliance with the International Traffic in Arms Regulations.
 
ITAR are the State Department controls that regulate defense products, technical data and services. This case involves Bright Lights USA Inc., a small New Jersey defense manufacturer. According to a State Department charging letter, the company’s business primarily consists of manufacturing minor spare parts – including rubber stoppers, seals assemblies and grommets – for both private- and public-sector customers. Many of these parts transitioned off of the more restrictive U.S. Munitions List beginning in October 2013 as a result of the Obama administration’s efforts to reform the export control regime.
 
When supplying military parts, the company periodically sought to obtain components from foreign suppliers. According to the charging letter, when ordering foreign-made parts the company sent drawings of export-controlled components to foreign suppliers to obtain quotations without obtaining the requisite export licenses.
 
The State Department also said the company posted drawings of controlled items online to solicit quotations, including posting on a manufacturing sourcing website where the drawings could be accessed by foreign persons. State also claimed that the company misclassified certain components.
 
The directorate of defense trade controls concluded that Bright Lights had “significant training and compliance program deficiencies” and charged the company with a number of violations including: the exporting of ITAR-controlled technical data to foreign suppliers without a license – including to China and India; exporting defense articles without a license to persons in the United Kingdom, Spain, Portugal, Turkey and the United Arab Emirates; and violating the recordkeeping requirements of ITAR-related activities for a five-year period.
 
While the government can pursue criminal, civil and administrative enforcement for ITAR violations, in the current case Bright Lights was only required to pay a $400,000 civil penalty.
 
Government contracting firms frequently ask questions about the application of ITAR requirements, including how it is applied to small- and mid-sized companies. The Bright Lights case squarely addresses many of these questions.
 
For example, does the State Department expect small companies to comply with the regulations, and will it actually pursue enforcement cases against them?
 
Absolutely yes. Being a small- or mid-sized company does not exempt a contractor from the requirements. These obligations apply to companies large and small, and small contractors do not get a “free pass” due to their size. In fact, some of the most sophisticated U.S. defense technologies are developed by small- and mid-sized firms. This case clearly confirms that the State Department will initiate enforcement actions against small- and mid-sized companies.
 
Another question is whether or not the State Department is really interested in complex defense systems and end items and not incidental “spare parts.”
 
State is extremely interested in not just large end items but also in subsystems, parts, components, accessories and attachments for defense products. These comprise an important part of the defense supply chain and the government is extremely interested in compliance at all levels, including by prime contractors, subcontractors, second- and third-tier suppliers and service providers. As the Bright Lights case demonstrates, the State Department will definitely prosecute companies for ITAR violations involving spare parts.
 
Another common question: If a product was removed from the Munitions List under the reform efforts, doesn’t the government lose interest in the item?
 
No. As set forth in the Bright Lights case, the State Department will pursue enforcement actions even for products that were removed from ITAR jurisdiction. The government is very interested in the integrity of the regulatory system – it will pursue enforcement actions even if particular items are decontrolled or transferred to another agency for regulation.
 
And are the ITAR recordkeeping requirements really that important? Do these warrant diverting valuable compliance resources from other high-priority uses?
 
The ITAR recordkeeping requirements are extremely important and exporters should treat these seriously. They are an important law enforcement tool for government agencies in conducting export investigations. In addition, if government investigators discover shoddy recordkeeping practices in an investigation, this may suggest that the company has lax compliance procedures and possibly other violations as well. It is imperative for contractors to follow these requirements carefully in their compliance practices. The Bright Lights case clearly confirms that the State Department will prosecute companies for ITAR recordkeeping violations.
 
Finally, the government wishes to control the export of physical products, but is it also interested in the transfer of ITAR-controlled technical data?
 
Absolutely yes. In fact, the export of technical data without a license is often considered as egregious as the export of physical products and possibly worse. It should be noted that the regulations also prohibit the disclosure of controlled technical data to foreign nationals in the United States, including to company employees.
 
If a company illegally exports one physical product, the bad guys get one product – but if it illegally exports the technical data related to the product the bad guys can manufacture a thousand of them.
 
The illegal export of controlled technical data – including disclosure to foreign persons in the U.S. and to a company’s own employees – is raised in many compliance cases and is considered among the most serious export violations.
 
The Bright Lights case sends an important message: export compliance is important for small- and mid-sized contractors. Some of the most sensitive products and services are supplied by small- and mid-sized companies, and the integrity of the defense supply chain is critical for even the smallest of replacement parts and components. The stakes are high in light of the potential civil and criminal penalties, including fines of up to $1 million and 20 years imprisonment.
 
A first step that small- and mid-sized companies can take to come into compliance with ITAR includes reviewing the jurisdiction and classification of their products and services to determine if they are controlled under ITAR and the Export Administration Regulations.
 
Based upon these classifications, they can determine the licensing and other requirements that apply, and adopt ITAR compliance programs and conduct employee compliance training. Additional details regarding the requirements can be found in “ITAR For Government Contractors,” which is available upon request from the author.

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

COMM_a3
10. Gary Stanley’s ECR Tip of the Day

(Source: Defense and Export-Import Update, 2 Dec 2017. Available by subscription via 
gstanley@glstrade.com.
)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, +1 202-352-3059,
gstanley@glstrade.com
.
 
ITAR Part 122 and 129 registrants whose fees are greater than $3,500 may appeal to the Department for consideration of an alternate payment schedule. To be considered, registrants must provide proof that the registration fee is greater than 1 percent of the total sales in the given year. “Total sales” includes domestic and international sales and is not limited to sales of items controlled on the USML. 
 
A
pplicants must submit a request for special consideration to DDTC not less than 30 days prior to registration expiration. Any request received within the 30 day window will be automatically disapproved.

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

MSEX/IM MOVERS & SHAKERS

MS_a111. Indialantic Rotary Club Presents “Global Challenges: A Conversation with James Clapper”

The Rotary Club of Indialantic is honored to present Director of National Intelligence, General James R. Clapper, Jr. (Ret.) with Rotary International’s highest honor, a Paul Harris Fellowship Award, for lifelong outstanding public service at a special program. 
 General Clapper has agreed to give a presentation and to take Q & A.
 
This event is a fundraiser for Rotary’s charities, including veterans organizations. We invite Rotarians and the general public to join us for this exceptional program.

When: January 17th, 2018 at 6:00 p.m. 
Where:
King Center for the Performing Arts, 
3865 N. Wickham Road, 
Melbourne, FL  32935. 

Link: See the event link
here.

Details/clarifications contact: Call 321-952-2978 or email us at 
info@partneringforcompliance.org.

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

MS_a212. Monday List of Ex/Im Job Openings; 116 Jobs Posted This Week, Including 6 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 (
6 New Jobs)

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

# Alcon Laboratories, Inc.; Fort Worth, TX;
Manager, Customs Compliance; Requisition ID: 227402BR

*
Arconic; Torrance, CA; Global Trade Compliance Manager – Import
*
ASM; Phoenix, AZ; Senior Manager Global Trade Compliance; Requisition ID: 7421
# Avaya; Washington, D.C.; Senior Trade Compliance Manager II;

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

* BAE Systems; Nashua, NH;
Director of International Trade Compliance; Requisition ID: 31739BR
* BAE Systems; Manassas, VA;
Director of International Trade Compliance; Requisition ID: 31789BR
* BAE Systems; Radford, VA;
DoD Subcontracts Manager; Requisition ID: 33463BR
* BAE Systems; Nashua, NH;
Import Export Analyst II; Requisition ID: 26285BR
* BAE Systems; Washington, D.C.;
Mid-Level Compliance Support; Requisition ID: 25634BR

* Baylor University; Waco, TX;
Manager/Director of Export Compliance; Vacancy ID S030428

* Boecore; Colorado Springs; 
Export Compliance/Contracts Support
; Julie Perkins, 719-465-5341; Requisition ID: 8289



Boeing; Multiple Locations;
Trade Control Specialist
; Requisition ID: 
1700011280

# Compass Forwarding Co., Inc.; New York, NY;
Assistant Import Manager

* DroneShield; Warrenton, VA;
Export Compliance Manager
(through CyberCoders staffing agency)

* DynCorp International; San Juan, Puerto Rico

Contracts Manager Senior
;
 Requisition ID:
 
1704462

*
 DynCorp International; Tampa, FL; Foreign Disclosure Officer; Requisition ID: PR1701977

*
 DynCorp International; Fort Worth, TX; Contracts Manager Senior; Requisition ID: 1704797

* EoTech Technologies; Ann Arbor, MI;
Trade Compliance Manager; Requisition ID: 092335

* Expeditors; Sunnyvale, CA;
Customs Compliance Supervisor;

* Expeditors; Atlanta, GA; 
Customs Brokerage Agent

* 
Expeditors; Minneapolis, MN; 
Global Logistics-Customs Brokerage Specialist
;


* Expeditors; Aalsmeerderbrug
, NH – Netherlands; 
Import en Export Control Medewerker

* Expeditors; Krefeld, Germany; 
Sachbearbeiter Import/ Export;
* Expeditors; Bedfont, United Kingdom;
Customs Brokerage Clerk;
* Expeditors; Birmingham, UK;
Customs Brokerage Agent;

* Expeditors; Düsseldorf, Germany;
Sachbearbeiter Luftfracht Import;
* Expeditors; Samutprakarn, Thailand; 
Customs Brokerage Agent;


* Export Solutions Inc.; Melbourne FL; 
Trade Compliance Specialist;
info@exportsolutionsinc.com

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

* FD Associates; Tysons Corner, VA; 
Senior Export Compliance Associate;
 Send 
resume to and salary requirements to 
jobs@fdassociates.net 

* FLIR; Billerica, MA;
International Export/Import Analyst;

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

* 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

* Geokinetics; Houston, TX;
Global Trade Compliance & Logistics Manager;

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

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

* 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;

* Honeywell; Bucharest, Hungary; 
Import and Export Compliance Manager; HRD12868
* JCB North America; Pooler, GA;
Compliance Manager;
* JCB North America; Pooler, GA;
Government and Defense Product Manager;
* Johnson and Johnson; Skillman, NJ;
Export Trade Compliance Lead;

* Livingston International; El Segundo, CA;
Research Consultant – ECCN Classification;
* 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; 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 Compliance 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

*
LORD Corporation; Cary, NC; Global Trade Compliance Specialist; Requisition ID: REQ-17-528

* Lutron; Coopersburg, PA;
Trade Manager-Export; Requisition ID: 2926
* L-3 LINK Division; Tulsa, OK; 
Contracts Administrator 1; Requisition ID: 091686
* L-3 LINK Division; Arlington, TX;
Trade Compliance Practitioner / Empowered Official; Requisition ID: 089915
* L-3 ALST; Orlando, FL;
Contracts Manager / Empowered Official; Requisition ID: 093069
* L-3 Warrior Sensor Systems; Middle East;
International Business Development Manager – Middle East Region; Requisition ID: 093343
* L-3 Technologies; Cincinnati, OH;
Trade Compliance Operations Associate and Contracts Administrator; Requisition ID: 092129
* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst; Requisition ID: 16000DYY
* Medtronic; Minneapolis, MN; 
Global Trade Supply Chain Director; Requisition ID: 17000FU4

* 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

* Nortek Security & Control; Carlsbad, CA;
Global Logistics & Trade Compliance Analyst; Requisition ID: GLOBA01150

* 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
* Oracle; Portland, OR; 
Senior Customs Compliance Specialist;

* Orbital ATK; Mesa, AZ; 
International Trade Compliance Sr. Analyst
; Jonathan Yeomans; Requisition ID: 41622

* Orbital ATK; Mesa, AZ; 
International Trade Compliance Analyst;
Jonathan Yeomans; Requisition ID 42250

* OSI Optoelectronics; Hawthorne, CA;
Manager, Global Trade Compliance; Requisition ID: 12235; or contact 
Kim Butcher, Senior Talent Acquisition Partner;
# Planet Pharma; Thousand Oaks, CA;
Senior Import/Export Associate

* 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

* SABIC; Houston TX; 
Senior Analyst, Trade Compliance
;  
Danielle.Cannata@sabic.com
; Requisition ID: 8411BR

* 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

* Teledyne Relays, Inc.; Hawthorne, CA; 
Trade Compliance Specialist
; Req. ID 2017-5259
 

* Thermo Fisher Scientific; Minneapolis, MN; 
Global Trade Compliance Manager;
* Thermo Fisher Scientific; Waltham, MA;
Director, Global Trade Compliance;
* Thermo Fisher Scientific; Oakwood, OH;
Import/Export Coordinator;

* Thermo Fisher Scientific; Tokyo, Japan;
Import/Export Manager;

* Thermo Fisher Scientific; Shanghai, China; 
Compliance Director — China/APAC;


T
hermo Fisher Scientific; Yokohama, Japan; Compliance Specialist;

* Thermo Fisher Scientific; Waltham, MA; 
Government Contracts Specialist;
* Thermo Fisher Scientific; West Pam Beach, FL;
Government Contracts Specialist;
* Thermo Fisher Scientific; Bannockburn, IL;
Government Contracts Specialist;


Thermo Fisher Scientific; Sunnyvale, CA;
Government Contracts Specialist
;

*
 T
hermo Fisher Scientific; Madison, WI;
Government Contracts Specialist
;

* Tradewin; Portland, OR;
U.S. Export Compliance Consultant

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

# United Technologies Corporation, UTC Aerospace Systems; Chula Vista, CA; 
ITC Specialist
; Requisition ID: 51240BR

*
United Technologies Corporation, UTC Aerospace Systems; Cheshire, CT; Senior Analyst, International Trade Compliance;
Requisition ID: 54662BR


#
United Technologies Corporation, UTC Aerospace Systems; Westford, MA;
International Trade Compliance Specialist
; Requisition ID: 54366BR


* United Technologies Corporation, UTC Aerospace Systems; Pheonix, AZ;


Senior Manager, International Trade Compliance;
Requisition ID: 54860BR

* 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

* 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
* Vista Outdoor; Olathe, KS;
Global Logistics Manager

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

*
Xilinx, Inc.; San Jose, CA; 
Global Trade Compliance Manager; Requisition ID: 154441
*
Xilinx, Inc.; San Jose, CA; 
Global Trade Compliance Program Manager; Requisition ID: 154442


* Xylem, Inc.; Any Location, United States;
Manager, Global Ethics & Compliance

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ENEDITOR’S NOTES

 


Joseph Conrad
(
born Józef Teodor Konrad Korzeniowski; 3 Dec 1857 – 3 Aug 1924; was a 
Polish

British
 writer, regarded as one of the greatest novelists to write in the English language. Though he did not speak English until his twenties, he was a master prose stylist who brought a non-English sensibility into English literature. He wrote stories and novels, many with a 
nautical
 setting, that depict trials of the human spirit in the midst of an impassive, inscrutable universe. His 25 novels included
Almayer’s Folly,
 The Nigger of the ‘Narcissus’, Heart of Darkness, Lord Jim, and Typhoon.)
  – “Facing it, always facing it, that’s the way to get through. Face it.”
 
 

*
Thomas Carlyle (4 Dec 1795 – 5 Feb 1881; was a Scottish philosopher, satirical writer, essayist, translator, historian, mathematician, and teacher.  Considered one of the most important social commentators of his time, he presented many lectures during his lifetime. A respected historian, his 1837 book
The French Revolution:
A History was the inspiration for Charles Dickens’ 1859 novel
A Tale of Two Cities, and remains popular today. Carlyle’s 1836
Sartor Resartus is a notable philosophical novel.)
 
– “Nothing stops the man who desires to achieve. Every obstacle is simply a course to develop his achievement muscle. It’s a strengthening of his powers of accomplishment.”
  – “No pressure, no diamonds.”

 
Monday is Pun Day
 
Q. 
What do you get when you take over a vineyard?
A. Conquered grapes.
  – Aoife Barrington-Haber, Newton, MA
 
* So what if I don’t know what apocalypse means.  It’s not the end of the world!
 
* The roundest knight at king Arthur’s round table was Sir Cumference.   
 

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EN_a314
. 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: 9 Nov 2017: 82 FR 51983-51986: Amendments to Implement United States Policy Toward Cuba

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 13 Nov 2017: 82 FR 52209-52210: Removal of Côte d’Ivoire 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: 19 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_a0315
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.

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