17-1226 Tuesday “Daily Bugle”

17-1226 Tuesday “Daily Bugle”

Tuesday, 26 December 2017

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. Justice/ATF Seeks Comments on Application of the Definition of Machinegun to “Bump Fire” Stocks and Other Similar Devices 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Posts Harmonized System Update 1709
  4. DHS/CBP Updates ACE Statement CATAIRS
  5. DHS/ICE: “Italian National Pleads Guilty to Illegally Exporting and Attempting to Export Military Technology”
  6. DoD/DSS Deploys Defense Information System for Security to MILDEPS on 8 Jan
  7. State/DDTC: (No new postings.)
  8. Australia DEC Updates Permit Application Forms, Mandatory Value Field
  1. Reuters: “U.S. Experts Resign from Monitoring China’s ZTE Corp: Sources”
  1. University of Liège and King’s College London Debate Implications of Brexit on Strategic Trade Controls
  1. Monday List of Ex/Im Job Openings: 148 Jobs Posted, Including 15 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
  2. ECTI Presents “Export Control Recordkeeping and Compliance Automation,” 24 Jan
  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 (20 Dec 2017), FACR/OFAC (21 Dec 2017), FTR (20 Sep 2017), HTSUS (26 Dec 2017), ITAR (30 Aug 2017) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



1. Justice/ATF Seeks Comments on Application of the Definition of Machinegun to “Bump Fire” Stocks and Other Similar Devices
(Source: Federal Register, 26 Dec 2017.) [Excerpts.] 
82 FR 60929-60932: Application of the Definition of Machinegun to “Bump Fire” Stocks and Other Similar Devices
* AGENCY: Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF).
* ACTION: Advance notice of proposed rulemaking; request for comments.
* SUMMARY: The Department of Justice anticipates issuing a Notice of Proposed Rulemaking (ANPRM) that would interpret the statutory definition of “machinegun” in the National Firearms Act of 1934 and Gun Control Act of 1968 to clarify whether certain devices, commonly known as “bump fire” stocks, fall within that definition. Before doing so, the Department and ATF need to gather information and comments from the public and industry regarding the nature and scope of the market for these devices.
* DATES: Written comments must be postmarked and electronic comments must be submitted on or before January 25, 2018. Commenters should be aware that the electronic Federal Docket Management System will not accept comments after Midnight Eastern Standard Time on the last day of the comment period. …
* FOR FURTHER INFORMATION CONTACT: Vivian Chu, Office of Regulatory Affairs, Enforcement Programs Services, Bureau of Alcohol, Tobacco, Firearms, and Explosives, U.S. Department of Justice, 99 New York Ave. NE, Washington DC 20226; telephone: (202) 648-7070.
  “Bump fire” stocks (bump stocks) are devices used with a semiautomatic firearm to increase the firearm’s cyclic firing rate to mimic nearly continuous automatic fire. Since 2008, ATF has issued a total of 10 private letters in which it classified various bump stock devices to be unregulated parts or accessories, and not machineguns or machinegun conversion devices as defined in section 5845(b) of the NFA or section 921(a)(23) of the GCA.
  On October 1, 2017, 58 people were killed and several hundred were wounded in Las Vegas, Nevada, by a shooter firing one or more AR-type rifles affixed with a particular bump stock device. In 2010, the manufacturer of this particular device had supplied ATF with a sample of the bump stock, and ATF had examined and classified it as an unregulated firearm part, not subject to either the GCA or NFA.
  Following the Las Vegas shooting, a significant amount of public attention has been focused on bump stock-type devices. ATF has received correspondence from the general public and from members of both houses of Congress requesting that ATF re-examine its past classification decisions concerning bump stock devices to determine whether they should be classified as machineguns within the meaning of section 5845(b). This ANPRM is the initial step in a regulatory process to interpret the definition of machinegun to clarify whether certain bump stock devices fall within that definition. If, in a subsequent rulemaking, the definition of machinegun under section 5845(b) is interpreted to include certain bump stock devices, ATF would then have a basis to re-examine its prior classification and rulings. See Encino Motorcars v. Navarro, 136 S. Ct. 2117, 2125 (2016); FCC v. Fox Television Stations, 556 U.S. 502, 515 (2009).
  This ANPRM is intended to gather relevant information that is otherwise not readily available to ATF regarding the scope and nature of the market for bump stock type devices. Because ATF does not have the authority to regulate firearm parts and accessories, ATF does not know, with the exception of one well-known manufacturer, how many of the individuals or companies that received classification letters from ATF ever engaged in commercial production and distribution of these devices. Similarly, ATF does not know how many companies or individuals who did not submit bump stock type devices to ATF for voluntary classification determinations are now engaging or have previously been engaged in this business. Further, the individuals and companies who submitted bump stock type devices to ATF for voluntary classification determinations identified some specific target markets for such devices, such as individuals with disabilities, but ATF does not have any information about whether those markets or other markets ultimately materialized for the devices. Consequently, ATF seeks the following information: …
   Dated: December 19, 2017.
Thomas E. Brandon, Deputy Director.

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OGS_a12. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register

* Commerce/BIS; RULES; Revisions, Clarifications, and Technical Corrections to Export Administration Regulations [Publication Date: 27 December 2017.]
* Justice/ATF; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Importation, Receipt, Storage, and Disposition by Explosives Importers, Manufacturers, Dealers, and Users [Publication Date: 27 December 2017.]
* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 27 December 2017.] 

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CSMS #17-000803, 26 Dec 2017.)
Harmonized System Update (HSU) 1709 was created on December 25, 2017 and contains 2,415 ABI records and 489 harmonized tariff records.
This update contains modifications mandated by the Presidential Proclamation, To Take Certain Action under the African Growth and Opportunity Act, And for Other Purposes, issued December 22, 2017. Many, but not all, of the adjustments are effective on January 1, 2018. The changes will be published within the change record, and chapters, of the 2018 USHTS. In the meantime, the proclamation can be accessed here.
Modifications required by the verification of the 2017 Harmonized Tariff Schedule (HTS) are included also.
The modified records are currently available to all ABI participants and can be retrieved electronically via the procedures indicated in the CATAIR. For further information about this process, please contact your client representative. For all other questions regarding this message, please contact Jennifer Keeling via email at Jennifer.L.Keeling@cbp.dhs.gov.
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CSMS #17-000804, 26 Dec 2017.)
In preparation for ACE Deployment G, Release 3B on January 6, 2018, updated versions of the draft CATAIRS for statement processing have been posted to CBP/gov. The CATAIRs were updated to clarify that the Q3, Q4, QE records contain the original, preliminary amounts on both the preliminary and final statement and the Q5, Q6, QJ records contain the final, paid amounts. Also, valid delete source codes for Q7 record were updated.
The Daily Statements CATAIR is available via this link.
The Periodic Monthly Statement CATAIR is available via this link.
Testing and Validating BETA Statement ACE Reports:
To ensure data is synced while in parallel mode for statements, CBP performed a data refresh on Thursday, December 21, 2017. The refresh also required data for the BETA Statements ACE reports to be reset. As you continue to test and validate data in the BETA Statements ACE reports, please be aware that these reports will reflect ACS statements up to Thursday, December 21, 2017, and ACE statements from Friday, December 22, 2017, onwards.
Deployment Reminder:
As a reminder, CBP split ACE Deployment G, Release 3, into two separate components – 3A and 3B (CSMS# 17-000751). Release 3A was successfully deployed on December 9, 2017, which included the availability of new ACE Statement reports in the ACE Production environment for testing. Deployment G, Release 3B will occur on January 6, 2018, at which point ACE will become the system of record for all Statements, with the exception of Reconciliation statements. No later than January 13, 2018, CBP will deploy ACE Statement reports with ACE statement data.
For more information and a full statements cutover plan, please review the Deployment G information notice at this link.

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DHS/ICE, 21 Dec 2017.) [Excerpts.] 
An Italian national pled guilty Thursday to illegally exporting controlled military technology from the United States to Italy following a joint investigation by U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI) in New York and the Department of Defense, Defense Criminal Investigative Service, Northeast Field Office (DCIS).
Giovanni Zannoni, 35, of Gavorrano, Italy, has pleaded guilty to illegally exporting and attempting to export night vision equipment and assault rifle components. As part of his plea, Zannoni agreed to forfeit $436,673.73, in addition to the dozens of gun parts and night vision and thermal imaging devices recovered by the government in connection with this prosecution.
“Over a period of four years, Zannoni illegally moved military equipment half way around the globe for a profit, with no concern of the buying agent,” said HSI NY Special Agent in Charge, Angel M. Melendez. …
According to court filings and admissions made in court at the time he entered the guilty plea, between June 2013 and May 2017, Zannoni illegally exported and attempted to export night vision goggles and assault rifle components designated as defense articles on the United States Munitions List. The export of sensitive night vision equipment and assault rifle components requires a license from the United States Department of State. The Department of State has placed restrictions on the export of items that it has determined could make a significant contribution to the military potential and weapons proliferation of other nations and that could be detrimental to the foreign policy and national security of the United States. On May 14, 2017, the defendant was arrested after entering the United States at Miami International Airport.
When sentenced, Zannoni faces a maximum sentence of 20 years in prison and a $1 million fine.

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. DoD/DSS Deploys Defense Information System for Security to MILDEPS on 8 Jan

(Source: DoD/DSS, 22 Dec 2017.) 
The January 8, 2017 deployment of Deploys Defense Information System for Security (DISS) to the Military Departments (MILDEPS) will begin Phase I of the deployment schedule and major activities in Phase I include migration to a single adjudicative system and interfaces with the Joint Personnel Adjudication System (JPAS), National Background Investigation Bureau (NBIB) systems, Clearance Verification system (CVS), Personnel Data Repository (PDR) and Defense Central Index of Investigations (DCII).
Beginning on 8 January completed investigations will be adjudicated in DISS while investigations completed prior to Phase I deployment are worked in legacy systems. You can view the DISS deployment phases here.
Deployment to Industry is scheduled for May 2018. The DMDC Contact Centeris available for DISS user support at 1-800-467-5526, option #1.

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OGS_a78. State/DDTC: (No new postings.)
(Source: State/DDTC)

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OGS_a89. Australia DEC Updates Permit Application Forms, Mandatory Value Field
(Source: Australia DEC, 21 Dec 2017.)
As of 22 December, Defence Export Controls (DEC) will update the “Application to Export Controlled Goods and Technology” form. The update will make it mandatory for applicants to include the value (or an estimated value) of the goods or technology being exported as part of the item description. DEC may contact applicants for further details on the value of the goods or technology to be exported, if this information is not included in the application. The updated forms will be available on the DEC website. DEC recommends applicants always check the website before completing their permit applications to ensure they are using the most recent version of the form as DEC is unable to accept old versions of application forms.

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10. Reuters: “U.S. Experts Resign from Monitoring China’s ZTE Corp: Sources”
(Source: Reuters, 22 Dec 2017.) [Excerpts.]
Two consulting firms hired to help the United States police ZTE Corp’s compliance with trade sanctions have resigned, according to four people familiar with the matter.
China’s second-largest telecommunications company agreed earlier this year to pay a nearly $900 million penalty – the largest in a U.S. export controls case – and open its books to a U.S. monitor as part of a guilty plea for illegally shipping goods to Iran and North Korea. …
Guidepost Solutions and Larkin Trade International were hired in June by the U.S. monitor in charge of the oversight regime – Texas lawyer James Stanton – to help assess the company’s compliance with U.S. export control and sanctions laws, and reduce its risk of future misconduct, said the people, who wished to remain unnamed because the matter is not public.
In late August, the two firms parted ways with the monitor after clashing over his approach to the job, the people said. Although Reuters was unable to determine the exact reasons for the departure, Stanton initially restricted the consultants’ access to ZTE documents and officials, hindering their ability to help monitor the company, one of the people said. …
A lawyer for ZTE declined to discuss the departure of the consulting firms, or the company’s relationship with the monitor.
  “We’re looking to be cooperative and have a successful monitorship,” said Matthew Bell, the head of compliance for ZTE in the United States.
The problems with efforts to monitor ZTE, unreported to date, are rooted in how a U.S. judge set up the policing program in March, according to interviews with more than half a dozen people familiar with the matter and a review of court documents related to the plea deal between ZTE and the U.S. government. …
Both Washington and Beijing have a lot riding on the reports and the success of the monitorship, which is set to last three years. The agreement allows the company continued access to the U.S. market, which provides 25 to 30 percent of the components used in its networking gear and smart phones. It is also part of a wider push by the United States to get China’s cooperation in combating nuclear proliferation and marks the first time that a Chinese company has submitted to such scrutiny.
Kevin Wolf, a former Commerce Department official who worked on the ZTE case, said the first few months of a monitorship do not always determine success or failure.
  “With any monitorship involving a complex situation, inevitably there will be start-up problems but in my experience the issues work out in the long run,” said Wolf, who is now a lawyer in Washington D.C. …

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11. University of Liège and King’s College London Debate Implications of Brexit on Strategic Trade Controls

(Source: University of Liège, 20 Dec 2017.)
On 24-25 April, a small group of government officials, academics, and industry practitioners were invited by the University of Liège and King’s College London to debate the implications of Brexit on strategic trade controls. The workshop was conducted under Chatham House rules with participation in private capacities.
During the course of the workshop, six areas of implications have been identified that will be analyzed separately in this report, written by Prof. dr. Quintin Michel.
  – The legal basis;
  – The Norway issue;
  – Harmonization of controls and competition;
  – Information sharing;
  – Licensing conditions; and
  – Technical capacities.

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MS_a212. Monday List of Ex/Im Job Openings; 148 Jobs Posted This Week, Including 15 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.

” New or amended listing this week (
15 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

ASM; Phoenix, AZ; Senior Manager Global Trade Compliance; Requisition ID: 7421

# BAE Systems; Nashua, NH; Director, International Trade Compliance; Requisition ID: 31739BR
# BAE Systems; Manassas, VA; Director, International Trade Compliance; Requisition ID: 31789BR

# BAE Systems; Los Angeles, CA; 
Program Manager, International and Offset; Requisition ID: 33778BR

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: 

CLASQUIN; Chicago, IL; Export Specialist

* Crane ChemPharma & Energy; Long Beach, CA;
Import Export Compliance Specialist;
# Customs and Border Protection; Charleston, SC;
Entry Specialist

* DroneShield; W
arrenton, VA;
Export Compliance Manager

(through CyberCoders staffing agency)

* DynCorp International; San Juan, Puerto Rico

Contracts Manager Senior
 Requisition ID:

 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;

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

* FD Associates; Tysons Corner, VA; 
Senior Export Compliance Associate;
resume to and salary requirements to 

# FLIR; Billerica, MA;
Global Trade Compliance Analyst,Traffic;
 FLIR; Wilsonville, OR; 
Global Trade Compliance Analyst,Traffic

# FLIR; Nashua, NH; 
Global Trade Compliance Analyst,Traffic;
 FLIR; Elkridge, MD; 
Global Trade Compliance Analyst,Traffic

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; San Diego, CA;
Contract Administrator / International

Requisition ID: 13449BR
# General Atomics; San Diego, CA;
Import/Export Compliance Manager / Licensing; Requisition ID: 15444BR
# General Atomics; San Diego, CA;
Import/Export Compliance Manager / Operations; Requisition ID: 15371BR
# General Atomics; San Diego, CA;
Internship, Import/Export, Summer 2018; Requisition ID: 15729BR
 General Atomics; San Diego, CA; 
Internship, Import/Export, Summer 2018
; Requisition ID: 15731BR
# General Atomics; San Diego, CA;
Experienced Contract Administrator / International; Requisition ID: 13449BR
# General Atomics; San Diego, CA; 
Senior Import/Export Administrator;
Requisition ID: 14438BR
# General Dynamics Ordinance and Tactical Systems; Lincoln, NE; Contracts Administrator; Requisition ID: j29241586

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

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

* 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

JCB North America; Pooler, GA;
Compliance Manager

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

* 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: 

* Lockheed Martin; Ft Worth, Texas;
International Trade Compliance Engineer; Requisition ID: 

* Lockheed Martin; Orlando, FL;
International Trade Compliance Engineer; Requisition ID: 

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: 
* 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:

* Pratt & Whitney; West Palm Beach, FL;
International Trade Compliance (ITC) Specialist; Requisition ID: 

* Pratt & Whitney; East Hartford, CT;
International Trade Compliance Technology Manager; Requisition ID: 

* 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: 
* 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
; Requisition ID: 8411BR

* Science and Engineering Services, LLC (SES); Huntsville, AL; 
Trade Compliance Administrator; OR: Contact 
* Science and Engineering Services, LLC (SES); Huntsville, AL; 
Technical Writer II/ Trade Compliance
OR: Contact  

* 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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(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.

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TE_a214. ECTI Presents “Export Control Recordkeeping and Compliance Automation,” 24 Jan 

(Source: Danielle Hatch:
* What: Export Control Recordkeeping and Compliance Automation
* When: January 24, 2018; 1:00 p.m. (EST)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Felice Laird
* Register:
Here or Danielle Hatch, 540-433-3977,
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* Isaac Newton (25 Dec 1642 – 20 Mar 1726; was an English mathematician, astronomer, theologian, and physicist (described in his own day as a “natural philosopher”) who is widely recognized as one of the most influential scientists of all time and a key figure in the scientific revolution. His book Philosophiæ Naturalis Principia Mathematica (“Mathematical Principles of Natural Philosophy”), first published in 1687, laid the foundations of classical mechanics. Newton also made pathbreaking contributions to optics, and he shares credit with Gottfried Wilhelm Leibniz for developing the infinitesimal calculus.)

  – “Genius is patience.”
  – “My powers are ordinary. Only my application brings me success.”    

Henry Miller (
Henry Valentine Miller; 26 Dec 1891 – 7 Jun 1980; was an American writer, expatriated in Paris. He was known for breaking with existing literary forms, developing a new type of semi-autobiographical novel that blended character study, social criticism, philosophical reflection, explicit language, sex, surrealist free association, and mysticism. His most characteristic works of this kind are Tropic of CancerBlack SpringTropic of Capricorn and The Rosy Crucifixion trilogy, all of which were banned in the United States until 1961).

  – “The moment one gives close attention to any one thing, even a blade of grass, it becomes a mysterious, awesome, indescribably magnificent world in itself.”
Monday was pun day:
Q. How did the elves clean Santa’s sleigh the day after Christmas?
A. They used Santa-tizer!
Q. What do you call someone who can’t stop thinking about past Christmases?
A. Santa-mental!
Q. Why did Santa arrange for a performance of the Nutcracker at the North Pole this year?
A. He wanted to see some pole dancers!

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. 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.
: 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. 
: 19 CFR, Ch. 1, Pts. 0-199
  – Last Amendment: 8 Dec 2017: 82 FR 57821-57825: Civil Monetary Penalty Adjustments for Inflation

  – 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 

: 15 CFR Subtit. B, Ch. VII, Pts. 730-774

  – Last Amendment: 20 Dec 2017: 82 FR 60304-60306: Addition of Certain Entities to the Entity List

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 21 Dec 2017: 82 FR 60507-60517: Magnitsky Act Sanctions Regulations

: 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
  – 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.
, 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: 26 Dec 2017: Harmonized System Update 1709, containing 2,415 ABI records and 489 harmonized tariff records. 

  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

  – 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 

, 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
. BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please
contact us
to receive your discount code.

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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 

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* 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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