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17-1218 Monday “Daily Bugle”

17-1218 Monday “Daily Bugle”

Monday, 18 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 
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[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. Justice: “Canadian-Iranian Citizen Sentenced in White Plains Federal Court To 32 Months in Prison for Conspiring to Violate Iran Sanctions”
  4. Justice: “Staten Island Lawyer and Others Charged in Fraud, Kidnapping, Extortion, and Export Violation Scheme”
  5. State/DDTC: (No new postings.)
  6. UK DIT/ECO Updates 9 OGELs Following Amendments to the EU Dual-Use Regulations, (EC) No. 428/2009
  1. Defense News: “Could the UK Re-Emerge as a Defense Export Giant? The Government’s Has a Plan”
  2. The Guardian: “Australian Police Charge Man with Acting as Economic Agent for North Korea”
  3. The Hill: “Serious Progress Made on the Wassenaar Arrangement for Global Cybersecurity”
  1. The Export Compliance Journal: “Become the Master of Your Export Compliance Mountain”
  2. M. Volkov: “Ethics and Mitigating Reputation Risks”
  3. Gary Stanley’s ECR Tip of the Day
  1. Monday List of Ex/Im Job Openings: 148 Jobs Posted, Including 18 New Jobs
  1. Full Circle Compliance and the Netherlands Defense Academy will present “Winter School at the Castle”, 5-9 Feb 2018 in Breda, the Netherlands
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (8 Dec 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

* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 19 December 2017.]

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

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

(Source:
Justice, 15 Dec 2017.) [Excerpts.]
 
The Acting United States Attorney for the Southern District of New York, and the Assistant Director-in-Charge of the Federal Bureau of Investigation in New York (“FBI”), announced that ALI SOOFI, a Canadian-Iranian dual citizen, was sentenced to 32 months in prison for his participation in a conspiracy to violate the International Emergency Economic Powers Act (“IEEPA”). SOOFI was charged and arrested by special agents of the Federal Bureau of Investigation (“FBI”) following a federal investigation. SOOFI pled guilty to one count of conspiracy to violate IEEPA on September 7, 2017, before U.S. District Judge Nelson S. Román, who imposed today’s sentence.
          
According to the Indictment filed against SOOFI, other court documents publicly filed in this case, and statements made in court proceedings, including today’s sentencing:
        
Between 2014 and December 2016, SOOFI conspired to export military items from the United States to Iran, both directly and through transshipment to intermediary countries, without a license. In particular, SOOFI acted as a broker on behalf of Iranian clients, including a high-ranking official in the Iranian Revolutionary Guard Corps (“IRGC”), who sought American military technology. Over the course of the conspiracy, SOOFI sought to purchase and ship numerous items, including helicopters, high-tech machine gun parts, tank parts, and military vehicles, from the United States to Iran, all without a license and while knowing that such shipments were illegal under U.S. law. During the multi-year conspiracy, SOOFI worked to fill specific orders for the IRGC by contacting other individuals with access to the requested military items through email, phone, and in-person meetings.
          
In addition to the prison term, SOOFI, 63, of Canada, was sentenced to one year of supervised release. …
* * * * * * * * * * * * * * * * * * * * 

OGS_a44. Justice: “Staten Island Lawyer and Others Charged in Fraud, Kidnapping, Extortion, and Export Violation Scheme” 

 
An 11-count indictment was unsealed today in federal court in Brooklyn charging Richard Luthmann, George Padula III, and Michael Beck with kidnapping and kidnapping conspiracy, extortionate collection of credit, extortionate collection of credit and brandishing a firearm during the commission of those crimes.  Luthmann and Padula were also charged with conspiracy to commit export violations, conspiracy to commit wire fraud, money laundering, money laundering conspiracy and aggravated identity theft, and Luthmann was additionally charged with access device fraud and a second count of aggravated identity theft.  …
 
  “As alleged, Richard Luthmann crossed the line from attorney to violent criminal and fraudster,” stated Acting United States Attorney Rohde.  “Luthmann and his coconspirators cheated scrap metal customers in order to make easy money for themselves, took advantage of a disabled man to conceal their fraud, and used gunpoint extortion to collect a purported debt.  Whether such crimes are committed on the street or in a law office, this Office and our law enforcement partners will investigate and prosecute them to the fullest extent of the law.”  Ms. Rohde expressed her grateful appreciation to the FBI and Department of Commerce Office of Export Enforcement, who are responsible for leading the investigation, and thanked the Department of Homeland Security, Homeland Security Investigations, the New York City Police Department and the Social Security Administration for their assistance.
 
The Fraud Scheme
 
According to court documents, beginning in the summer of 2015, Luthmann, who is a practicing lawyer on Staten Island, New York, along with Padula and another co-conspirator (“Co-Conspirator 1”) agreed to defraud companies seeking to purchase scrap metal.  In part, the scheme involved contracting with victims to ship them containers declared for export to contain valuable scrap metal, but then filling the shipping containers primarily with cheap filler material [filing false export reports required by U.S. export Foreign Trade Regulations]. . . .  If convicted of the charges, defendants Luthmann, Padula, and Beck each face up to life imprisonment. Cotogno faces up to 20 years’ imprisonment if convicted of wire fraud conspiracy. …

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

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OGS_a66
. UK DIT/ECO Updates 9 OGELs Following Amendments to the EU Dual-Use Regulations, (EC) No. 428/2009

(Source:
UK DIT/ECO
, 16 Dec 2017.)
 
The Export Control Organisation (ECO) of the UK Department of International Trade (DIT) has updated
the following 9 licenses to reflect amendments to the EU dual-use export control list in Annex I to Regulation (EC) No 428/2009:   
 

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

NWSNEWS

NWS_a1
7. Defense News: “Could the UK Re-Emerge as a Defense Export Giant? The Government’s Has a Plan”

(Source: Defense News, 18 Dec 2017.)
 
The British government department responsible for international trade is reviewing how it can boost the effectiveness of its defense and security exports arm.
 
Industry executives said the focus of the work appears to be an effort to increase overseas sales in the cyber and security sector. Companies, leading trade bodies like ADS and others have already been consulted in a review of operations at the Defence and Security Organisation. A report is likely to be completed in the next few weeks, they said.
 
DSO was formerly part of the government’s business department but moved to become an arm of the Department for International Trade when it was formed last year following Britain’s decision to exit the European Union. A spokesman for DSO confirmed the review was underway but declined to go into details.
 
  “A nonexecutive director has been asked to have a look at DSO to ensure that it, and the wider department, are able to provide the best possible support to our security, cyber and defense sectors. He is consulting a wide range of stakeholders and has not yet reached any conclusions. It would be premature to speculate about the potential outcome,” the spokesman said.
 
The nonexecutive in question is Simon Walker, a well-known business figure in England, and the lead nonexecutive director at the Department for International Trade. …
 
The Ministry of Defence leads the British Typhoon and complex weapons export effort, although DSO does much of the leg work.
 
Everitt said he sees no reason why “security exports could not continue to grow to the point where they were equivalent to the figures achieved by defense.”
 
Prospects for the local defense and security sectors overall are likely to be influenced by a national security capability review due to be completed by the Cabinet Office in the next few weeks.
 
Additional spending on cyber could be one of the items on the agenda, maybe at the expense of extra funds to stave off defense capability cuts caused by budget problems.
 
Mark Sedwell, the national security adviser leading the review, is said to believe that boosting cyber spending is more important than increasing the armed forces budget to stave off possible capability and program cuts. …
 

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NWS_a2
8. The Guardian: “Australian Police Charge Man with Acting as Economic Agent for North Korea”

(Source: The Guardian, 17 Dec 2017.) [Excerpts.]
 
The 59-year-old man is alleged to have breached sanctions and is accused of dealing with weapons of mass destruction.
 
The Australian federal police have arrested a man in Sydney over allegedly acting as an economic agent for North Korea, attempting to sell missile components and coal on the international black market.
 
Choi Han Chan, a 59-year-old man from Sydney’s Eastwood, allegedly breached United Nations sanctions and Australian federal law, and has been charged with brokering sales and discussing the supply of weapons of mass destruction.
 
The alleged deals involved entities in Indonesia, Vietnam and other undisclosed countries. …
 
Gaughan stressed there was no threat to Australians and that the man was not considered a “spy”. ….
 
The AFP alleges Choi acted as a broker for the North Korean regime, unsuccessfully attempting to sell missile components – namely software for a guidance system – and technical expertise to unnamed international entities. …

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NWS_a3
9. The Hill: “Serious Progress Made on the Wassenaar Arrangement for Global Cybersecurity”
(Source: The Hill, 17 Dec 2017.) [Excerpts.]
 
A group of 41 nations gathered this month to officially update the language of the Wassenaar Arrangement, a voluntary agreement governing certain export controls for classified dual-use software and technology, otherwise known as “cyberweapons.”
 
Along with one other representative, Iain Mulholland, I participated as a technical expert in security vulnerability disclosure and cyber incident response. (As a disclaimer, we did not represent any department of the U.S. government.) Our responsibilities at each technical expert’s working group meeting, from June 2016 leading up to last week’s plenary vote, included helping to clarify the arrangement’s language. We did so to prevent unintended consequences, especially any that would disrupt internet defenses.
 
The progress our group made was substantial and important, both to America and for countries around the world, now also including India as the 42nd country newly added to the group. We were able to work as a team to add some important new clarifications affecting vulnerability disclosure and cyber incident response. …

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COMMCOMMENTARY

COMM_a01
10. The Export Compliance Journal: “Become the Master of Your Export Compliance Mountain”

(Source: The Export Compliance Journal, 12 Dec 2017.)
 

Export compliance professionals, and others involved with ensuing their organizations remain on the right side of export, trade, and financial compliance laws, may sometimes feel as though they are staring up from the base of some grand peak; a monolithic wall, if you will, of tasks that may seem insurmountable.

 
At the base of that mountain is the first leg towards maintaining compliance with the multitude of mandatory government export, trade and financial (OFAC) laws and requirements: restricted party screening. Also known as “denied party screening,” it’s the process of ensuring you are not doing business with those on Export, Restricted, Denied, and Blocked Persons lists, or Specially Designated Nationals (SDN), Politically Exposed Persons (PEP), or Sectoral Sanctions Identifications (SSI) lists-to name a few of the hundreds of U.S. and International government lists against which organizations must screen. At times both tedious and time-consuming, it’s a responsibility export compliance officers, and others tasked with ensuring screening gets done, face every day.
 
But what if, you could turn a process that is “tedious and time-consuming” into one that was “easy and automated?” A short cut that could turn Mt. Everest into a lowly foothill-a painstaking process fraught with the potential for concern into a figurative walk in the park.
 
Integrating restricted party screening into your business systems (ERPs, MRPs, CRMs, etc.), databases, eCommerce sites, or visitor systems is one of the most effective ways to achieve just that. Here are just a few of the reasons why organizations large and small should consider automating the restricted party screening process.
 
Time is Money          
 
Or so the old adage goes. Each hour wasted on data entry, such as the case with inputting data into a manual screening system, is money that you are spending to have a potentially highly skilled professional duplicating work already done somewhere by someone else. You’d be surprised at the time saved by integrating restricted party screening into business systems such as Oracle®, SAP®, Salesforce®, NetSuite® and others, including legacy and custom-built systems-where screening can take place automatically at the point of data entry (or elsewhere in the business process).
 
Let the Machine do the Work
 
One great advantage of integrating a workflow into a system is that said system will always follow instructions to the letter. Tell it what to do once, and it will continue to do so until told otherwise. In other words, by configuring screening to occur at one or more points in the business process-screening will happen automatically at those designated points in the process, with the potential for human error removed altogether. From there, staff hours can be better spent vetting and clearing matches so that transactions can be completed, and orders sent out the door, much more efficiently, with increased confidence that you’re in compliance to boot.
 
Investing is Not Gambling
 
We all worry about investments paying off, but an organization investing in a solution that can improve productivity-and ultimately help increase the bottom line-is likely to reap dividends over the long-term. If that solution is cost-effective and requires little-to-no internal resources to implement, the benefits can be realized even in the short-term!
 
No Pain? No Gain. Perfect!
 
There’s rarely any “gain” from having to repeatedly enter restricted party screening details manually-humans can inadvertently make errors, or forget to screen-and in order for screening to be most effective, individuals and entities should be rescreened throughout the duration of the business relationship. One of the greatest advantages of integration comes from taking the burden off internal staff resources and letting the machines do the work. After all, it’s why they were put there in the first place. It also gives internal resources the freedom to focus on other matters, such as growing the business, or improving other internal processes.
 
The Moral of the Story
 
Back to our initial analogy, whereby manual screening is the “mountain.” Consider automating the screening process by integrating it into the systems used every day the ski lift, chair lift, gondola-even better, the helicopter-that can get you to the summit in next-to-no time at all, with as little effort as possible. That way, you can spend more time on other activities, such as leisurely making your way to the bottom of the hill, where you can enjoy a nice cup of hot cocoa in the chalet.

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(Source:
Volkov Law Group Blog, 17 Dec 2017. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
 
A basic truism is – ethics and compliance reinforce each other. An ethical culture is an effective control against violations of law and a company’s code of conduct. Conversely, legal compliance promotes a company’s commitment to an ethical culture.
 
Larger global companies are more likely to identify reputational risks as its greatest threat. (Go Here for the NAVEX Global Third Party Benchmark Report).
 
My favorite Warren Buffet quote on the value of a company’s reputation makes the point:
 
It takes 20 years to build a reputation and five minutes to ruin it. If you think about that, you’ll do things differently.
 
A company faces a myriad of risks, some within its control and some outside of its control. Assuming a company’s reputation is a very valuable intangible asset, everyone should understand the importance of protecting and promoting the company’s reputation.
 
A company’s commitment to an ethical culture is the most effective way to embed and promote its reputational value. Maintaining an effective legal compliance program is not as effective as an ethical culture in protecting a company’s reputation. What do I mean by that?
 
We all encounter situations in which a legal solution may differ from the ethical solution to a business decision. In some cases, even though the company can choose a course of action because the legal risks are relatively low, the ethical principles applicable to the situation may be more appropriate, especially when the company considers its reputational risks.
 
For example, assume that a company is considering whether to pay its vendors in 60 days after invoice in accordance with its contracts or change its policy unilaterally to make all payments 75 days after invoice. The legal analysis of such a change in policy, assuming there is no change in written contracts, may conclude that the risk of litigation from its vendors for the 15-day extension of payments is very low.
 
On the other hand, if the same issue is analyzed in accordance with the company’s ethical principles, such as fair dealing and honesty, the company is likely to reach a different conclusion and retain the 60-day policy. Why?
 
The company could easily conclude that a unilateral change in payment policy from 60 to 75 days, while raising low legal risks, would send the wrong message to its vendors, and threaten the value of the company’s word, or its commitment to negotiated business deals. While the legal risk is low, the damage to the company’s relationships with its vendors, and even other stakeholders, including its customers, may suffer real and significant harm.
 
This is a perfect example of the value of a company’s ethical culture, which is tied to protecting and promoting its reputational. It is too “easy” to restrict corporate decision-making to legal principles – decisions that may have negative consequences on a company are not co-extensive with the legal v. illegal dichotomy, much less considering only litigation risks.
 
A company’s reputation is its bond with key stakeholders – vendors/suppliers, shareholders, customers, government and community interests. Once a company’s reputation is broken, as Warren Buffet so eloquently stated, the company has lost an intangible asset of considerable value. A company’s commitment to ethics is the most effective means to preserve and protect the company’s reputation. Frankly, they go hand in hand and mutually reinforce each other.

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

(Source: Defense and Export-Import Update. Available by subscription via 
gstanley@glstrade.com.
)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, +1 202-352-3059,
gstanley@glstrade.com
.
 

Under ITAR § 120.18, the term “temporary import” includes withdrawal of a defense article from a customs bonded warehouse or foreign trade zone for the purpose of returning it to the country of origin or country from which it was shipped or for shipment to another foreign destination. it also includes defense articles that are in transit to another foreign destination.  

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MSEX/IM MOVERS & SHAKERS

MS_a213. Monday List of Ex/Im Job Openings; 134 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

# AeroVironment; Simi Valley, CA; Trade Compliance Administrator; Requisition ID: 17-177
* 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; 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

# CLASQUIN; Chicago, IL; Export Specialist
# Crane ChemPharma & Energy; Long Beach, CA; Import Export Compliance Specialist
* DroneShield; W
arrenton, 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;
* FLIR; Goleta, CA;
Senior Analyst, Licensing;
* FLIR; Meer, Belgium;
Global Trade Compliance Administrator;
* FLIR; Arlington, VA;
Senior Analyst, Licensing
* FLIR; Billerica, MA;
Senior Analyst, Licensing
;

*
 
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

# GEODIS; Elk Grove Village, IL; Air Export Coordinator;
* 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
# Infineon Technologies; El Segundo, CA; Senior Export Compliance Specialist; Requisition ID: 23173
# Infineon Technologies; Milpitas, CA; Senior Export Compliance Specialist; Requisition ID: 21326
# Infineon Technologies; Shanghai, China; Senior Import and Export Specialist; Requisition ID: 22067

# Infineon Technologies; Munich, Germany;
Experte Export Control (w/m); Requisition ID: 22825

# Intellitrade, Inc.; Toronto, CA; Customs/Trade Analyst;
* 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 2; Requisition ID: 17022805
* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 3; Requisition ID: 17020346
* Northrop Grumman; Huntsville, AL;
International Trade Compliance 3; Requisition ID: 17026172
* Northrop Grumman; Rolling Meadows, IL; 
International Trade Compliance Analyst 3; Requisition ID: 
17015695
* Northrop Grumman; San Diego, CA;
Import Export Administrator 3; Requisition ID: 17026003

* 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
# Pratt & Whitney; East Hartford, CT; International Trade Compliance (ITC) Specialist; Requisition ID:
 49375BR
# Pratt & Whitney; West Palm Beach, FL; International Trade Compliance (ITC) Specialist; Requisition ID: 
55088BR
# Pratt & Whitney; East Hartford, CT; International Trade Compliance Technology Manager; Requisition ID: 
51863BR
# Pratt & Whitney; East Hartford, CT; Manager, International Trade Compliance Military Engines
Requisition ID: 57613BR

* 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

#
RUAG Space USA; Huntsville AL; 
Global Trade Control Manager
; Requisition ID: 1748547

* 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 Imaging; Waterloo, Ontario, Canada; Director of International Trade Compliance; Requisition ID: TC0617
# Teledyne Geophysical; Houston, TX; Trade Compliance Specialist/Administrator; Requisition ID: 2017-5459
* 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; Tokyo, Japan;
Import/Export Manager;

* 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; Chula Vista, CA; 
Supply Chain International Trade and Compliance Focal; Requisition ID: 53794BR
# United Technologies Corporation, UTC Aerospace Systems; Everett, WA; 
International Trade Compliance (ITC) Specialist; Requisition ID: 52787BR
* United Technologies Corporation, UTC Aerospace Systems; Foley, AL; 
ITC Site Lead
; Requisition ID: 54820BR


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


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

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

* 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

*
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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TEEX/IM TRAINING EVENTS & CONFERENCES

(Source: Editor)
 
* What: Winter Seminar “Compliance and Integrity in International Military Trade”, including the following topics:
  – Day 1: International Trade in Defense Markets and Relevance of Trade Compliance
  – Day 2: U.S. Export Control Regulations (International Traffic in Arms Regulations), and the EU Perspective
  – Day 3: U.S. Export Control Regulations (Export Administration Regulations), and EU Export Control Regulations (Military and Dual-Use)
  – Day 4: Compliance & Integrity / Ethics, and Setting up an Internal Compliance Program
  – Day 5: Setting up an Internal Compliance Program (continued)
* When: 5-9 February 2018.
* Where: the Netherlands Defense Academy (“The Castle”), Breda, the Netherlands.
* Event Sponsors: Full Circle Compliance & the Netherlands Defense Academy, Faculty of Military Sciences
* Speakers include: Prof. dr. J.M. Beeres; Col. Dr. Robert M.M. Bertrand RA RC RO; Drs. Ghislaine C.Y. Gillessen RA; James E. Bartlett III, LLM; Michael E. Farrell; and Drs. Alexander P. Bosch.

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

ENEDITOR’S NOTES

 

* Ludwig van Beethoven (17 Dec 1770- 26 Mar 1827; was a German composer and pianist. A crucial figure in the transition between the Classical and Romantic eras in Western music, he remains one of the most famous and influential of all composers. His best-known compositions include 9 symphonies, 5 piano concertos, 1 violin concerto, 32 piano sonatas, 16 string quartets, his great Mass the Missa Solemnis, and one opera, Fidelio.
  – “Only the pure in heart can make a good soup.”
 
* Lyman Abbott (18 Dec 1835 – 22 Oct 1922; was an American Congregationalist theologian, editor, and author.)
  – “Every life is a march from innocence, through temptation, to virtue or vice.”
 
Monday is pun day:
 
Q. Why do mermaids wear seashells?
A. Because B shells are too small and D shells are too big.
– Janet Campbell, Clarksville, TN
 
* Past, Present, and Future walked into a bar together.  It was tense!

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

EN_a316
. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  Changes to applicable regulations are listed below.
 
*
ATF ARMS IMPORT REGULATIONS
: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War
  – Last Amendment: 15 Jan 2016: 81 FR 2657-2723: Machineguns, Destructive Devices and Certain Other Firearms; Background Checks for Responsible Persons of a Trust or Legal Entity With Respect To Making or Transferring a Firearm. 
 
*
CUSTOMS REGULATIONS
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment: 8 Dec 2017: 82 FR 57821-57825: Civil Monetary Penalty Adjustments for Inflation
 
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_a0317
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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