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18-0102 Tuesday “Daily Bugle”

18-0102 Tuesday “Daily Bugle”

Tuesday, 2 January 2018

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
.
(
The Daily Bugle was not published yesterday, New Year’s Day. We wish you a healthy and successful 2018!
)

[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DoD/DSCA Releases Policy Memo 17-47
  4. State/DDTC: (No new postings.)
  5. Hong Kong Releases Circular Concerning Air Transshipment Cargo Exemption Scheme for Specified Strategic Commodities
  1. Inside Trade: “Revisions to Wassenaar Cyber Export Control Agreement Gain Industry Support”
  2. Reuters: “South Korea Seizes Second Ship Suspected of Providing Oil to North Korea”
  1. CISTEC Releases Opinion Brief on China’s Draft Export Control Act
  2. M.A. Goldstein: “Export Controls by the Numbers: CSL Data Analytics”
  3. R.C. Thomsen II, A.D. Paytas & M.M. Shomali: “U.S. Export Controls Past, Present and Future (2017 Edition)”
  4. The Trade Practitioner: “Commission Updates to EU Control List of Dual-Use Items Enter into Force”
  5. Gary Stanley’s ECR Tip of the Day
  1. Teresa Ficaretta Moves to Ficaretta Legal Services, LLC
  2. Monday List of Ex/Im Job Openings: 162 Jobs Posted, Including 35 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 (27 Dec 2017), FACR/OFAC (28 Dec 2017), FTR (20 Sep 2017), HTSUS (26 Dec 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

* State; RULES; 2018 Civil Monetary Penalties Inflationary Adjustment [Publication Date: 3 Jan 2018.] 
* * * * * * * * * * * * * * * * * * * *

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

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

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OGS_a55.

Hong Kong Releases Circular Concerning Air Transshipment Cargo Exemption Scheme for Specified Strategic Commodities

(Source:
Hong Kong TID, 2 Jan 2017.)
 
Hong Kong’s Trade and Industry Department (TID) has released Strategic Trade Controls Circular No. 1/2018: “Air Transshipment Cargo Exemption Scheme for Specified Strategic Commodities (SCTREX): List of Valid Registrants (as at 1 January 2018)”.
 
The circular is available here

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

NWSNEWS

NWS_a1
6. Inside Trade: “Revisions to Wassenaar Cyber Export Control Agreement Gain Industry Support”

(Source: Inside Trade, 2 Jan 2018.) [Excerpts. Subscription required.]
 
International negotiators last month made changes to an arms-control agreement that for years has troubled U.S. tech companies – which have argued the export controls could undermine cybersecurity improvements – with the latest revisions drawing industry applause as well as calls for additional moves. At issue is the so-called Wassenaar Arrangement for restricting access to conventional arms and “dual-use goods,” which was expanded several years ago to include “intrusion” software. … 

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

NWS_a2
7Reuters: “South Korea Seizes Second Ship Suspected of Providing Oil to North Korea”

(Source: Reuters, 31 Dec 2017.) [Excerpts.]
 
South Korean authorities have seized a Panama-flagged vessel suspected of transferring oil products to North Korea in violation of international sanctions, a customs official said on Sunday.
 
The seizure was the second to be revealed by South Korea within a few days, as the United Nations steps up efforts to squeeze essential oil supplies to the reclusive North following its nuclear or ballistic missile tests. …
 
The U.N. Security Council last month unanimously imposed new sanctions on North Korea for a recent intercontinental ballistic missile test, seeking to limit its access to refined petroleum products and crude oil.
 
The United States has also proposed that the United Nations Security Council blacklist 10 ships for transporting banned items from North Korea, according to documents seen by Reuters on Tuesday. … 

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COMMCOMMENTARY

COMM_a01
8. CISTEC Releases Opinion Brief on China’s Draft Export Control Act

(Source: CISTEC, 1 Dec 2017.)
 
The Center for Information on Security Trade Control (CISTEC) has released an opinion brief from members of Japan’s industrial sector on China’s draft Export Control Act. The opinion brief includes, among others, comments concerning China’s proposed deemed export rules and re-export rules and their potential impact on Japan.
 
China’s export control bill was announced on 16 June 2017. CISTEC examined the bill and submitted comments to the Treaty Lawyers of the Chinese Ministry of Commerce (MOFCOM).
 
N.B.
CISTEC is a Tokyo based non-profit and non-governmental organization that supports for Japanese industry activities by research and analysis on numerous peace and security issues related to export controls.

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

COMM_a2
9. M.A. Goldstein: “Export Controls by the Numbers: CSL Data Analytics

(Source:
Defense Trade Law Blog
, 1 Jan 2018. Reprinted by permission.)
 
* Author: Matthew A. Goldstein, Esq.,
matthew@goldsteinpllc.com
, +1 202-550-0040.
 
The agencies that administer U.S. export control and sanctions laws maintain various prohibited party lists. These lists contain names and other information on drug traffickers, weapons proliferators, terrorists, members of oppressive regimes, and other parties with whom exports and other transactions are restricted and, in many cases, altogether prohibited.
 
The Departments of Commerce, State, and Treasury have combined multiple prohibited party lists into the Consolidated Screening List (“CSL”), available here.
 
Awareness of the scope and volume of designations on the CSL is important to assessing respective risks. Relevant here, analysis of December 26, 2017 CSL data shows:
 
  – there are a total of 8,794 designation targets;
  – 49% of all targets are individuals;
  – 75% of all designations are under Treasury Department programs;
  – 6% of all Treasury targets are designated under more than one Treasury program; and
  – at 18% of all CSL designations, the Specially Designated Narcotics Kingpin Sanctions Regulations have the greatest number of targets.
 
Companies involved in international trade often encounter parties to a transaction with names that potentially match a designation target. Properly validating a potential match is critical because each presents the real chance of a violation.
 
As explained on the CSL website:
 
In the event that a company, entity or person on the list appears to match a party potentially involved in your export transaction, additional due diligence should be conducted before proceeding.
 
Such due diligence ordinarily entails validating the date of birth, place of birth, nationality, and address information known about parties to a transaction with potential CSL matches. However, this information is not available for every match. More specifically, the CSL data shows that, overall, 84% of individual target designations contain date of birth information, 54% contain place of birth information, 18% contain citizenship information, and only 60% contain address information. These percentages vary substantially between agencies, especially for date of birth and address information on individual targets:
 
  – State Department designations do not contain date of birth or address information.
  – All Commerce Department designations contain addresses, but no date of birth information.
  – 95% of Treasury Department designations contain date of birth information and 56% contain address information. Of these, several hundred only provide the year of birth and/or country of residence.
 
The poor quality of CSL information often presents an obstacle to due diligence that adds substantial time and cost to the prohibited party screening process. As a further result, many companies must work directly with cognizant government agencies to validate potential matches, especially in cases involving an exact name match or multiple similarities to a designation target.
 
An interactive CSL data analytics tool, based on the December 26, 2017 version of the CSL, is available here.

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COMM_a3
10. R.C. Thomsen II, A.D. Paytas, &
 M.M. Shomali: “U.S. Export Controls Past, Present and Future (2017 Edition)”

(Source: alerts@t-b.com, 30 Dec 2017.) [Excerpts.]
 
* Authors: Roszel C. Thomsen II, Esq., roz@t-b.com; Antoinette D. Paytas, Esq., toni@t-b.com; and Maher M. Shomali, Esq., maher@t-b.com. All of Thomsen & Burke LLP.
 
As is our custom, at the end of each year, we reflect on developments in the field of U.S. and multilateral export controls, gaze into our crystal balls, and offer some recommendations for 2018 in the End of Year Summary. …
 
Highlights for 2017 include:
 
There were a number of important changes to the export control laws and regulations in 2017 implemented by the U.S. Government, including the Commerce Department’s Bureau of Industry and Security (BIS), Treasury Department’s Office of Foreign Assets Control (OFAC) and the State Department’s Directorate of Defense Trade Controls (DDTC):
 
  – BIS, OFAC and the State Department updated their Cuban sanctions regulations. BIS loosened some restrictions under License Exception SCP (Support for the Cuban People) and now authorizes additional types of items going to private sector entities. However, OFAC limited the travel authorizations that are currently implemented by OFAC in the form of general licenses. For example, individual people-to-people travel will no longer be authorized. The State Department also published a List of Restricted Entities and Subentities Associated with Cuba (Cuba Restricted List) with which direct financial transactions will generally be prohibited. BIS and OFAC amended their regulations to address the State Department’s Cuba Restricted List.
 
  – The U.S. Government resolved the enforcement action against ZTE Corporation and its affiliated companies, which were placed on the BIS Entity List last year. In total, ZTE agreed to pay the U.S. Government $892,360,064 and agreed to a significant conduct remedy, in the various plea and settlement agreements. In return, ZTE Corporation and ZTE Kangxun were removed from the Entity List, but ZTE Corporation and ZTE Kangxun, along with a new addition, former ZTE CEO Shi Lirong.
 
  – The U.S. Government also implemented changes to the Ukraine-Related Sanctions Program against Russia and the Crimea Region of Ukraine, including the addition of the Russian FSB to the BIS Entity and OFAC SDN Lists, modifications to Directives under the Sectoral Sanctions Identifications List. In addition, the State Department published the list of parties identified under Section 231.d of the Countering America’s Adversaries Through Sanctions Act of 2017 and published guidance related to Russia’s Defense and Intelligence Sectors Under Section 231. Unlike other sanctions programs, the State Department will be the enforcement agency for Section 231/235.
 
  – OFAC issued a general license this year that suspends the comprehensive sanctions restrictions on Sudan, in connection with ongoing U.S.-Sudan bilateral engagement. However, the BIS sanctions program against Sudan still remains in place, with minor changes to its license review policy for certain civil aviation and railroad applications.
 
  – BIS published new documentation requirements for transactions involving Hong Kong, which became effective this year. This rule covers any item with an Export Control Classification Number subject to controls based on various reasons, including encryption items controlled under ECCN 5×002. The new provision requires that an exporter or re-exporter of a covered item to Hong Kong under a US license exception must now obtain a copy of the matching Hong Kong import license that authorizes import into Hong Kong.
 
  – BIS continued to streamline the export of Encryption Items, including the reorganization of the Note 4 decontrol note as a more positive list and a definition of the uses of encryption that are decontrolled.
 
  – BIS also implemented the Wassenaar Arrangement 2016 Plenary meeting export controls of items, including changes to Categories 3, 4, and 5, Parts 1 and 2 of the Export Administration Regulations.
 
Recommendations for 2018 include:
 
We anticipate the following actions in 2018, which you can begin preparing for now:
 
  – There have been continued developments in the export/import control regulations of various foreign governments, including France, Israel, Hong Kong, India Russia and China, related to the control of cryptographic products and provision of cloud-related services. These requirements have presented challenges to U.S. exporters/importers of cryptographic products as foreign governments continue to implement these regulations. One significant change that already occurred is BIS’s implementation of a reporting requirements for compliance with the Hong Kong TID import regulations. We also anticipate a more formal implementation of India’s import and export regulations pursuant to its admission into various international organizations, including the Wassenaar Arrangement. We will keep you posted on updates to these requirements, but we recommend contacting resellers and distributors with a presence in these countries to ensure that your products are handled in compliance with these foreign regulations.
 
  – We will also discuss these foreign encryption changes at the annual American Conference Institute’s Advanced Industry Forum on Global Encryption, Cloud & Cyber Export Controls. The 8th year of the conference will be held on March 26 – 28 in San Francisco, California, and will once again be co-chaired by Roz Thomsen. In addition to foreign importers and exporters and importers, this conference will be of interest to companies that are facing obstacles are the use and provision of cloud-based services becomes more widespread. Please let us know if you are interested in attending so you can take advantage of our registration discount code. Additional information can be found on the conference website.
 
  – Participants of 23rd Plenary Meeting of the Wassenaar Arrangement agreed on several changes to the lists of dual-use goods, technologies, and munitions. One significant agreement that U.S. industry should keep an eye on is the clarifications related to the “cybersecurity” controls. The control on “intrusion software,” for example, does not apply to vulnerability disclosure or cyber incident response, which was a concern of exporters in the prior controls. It will be interesting to see how the U.S. responds to these changes, and if they will pursue further clarification of the controls, draft a new export control rule.
 
  – Another emerging technology, and potential area of export control, to keep an eye on in 2018 is “Artificial Intelligence.” Both the U.S. President’s National Security Advisor and Head of Secretariat at the Wassenaar Arrangement published statements on this topic in December, noting that “Artificial Intelligence,” including self-driving cards to autonomous weapons, and the integration of advanced sensors, are emerging technologies of concern that the U.S. and Wassenaar Arrangement will continue to address.
 
  – The major announcements this year related to the sanctions programs include State Department enforcement against certain entities in Cuba and Russia, and corresponding implementations into the BIS and OFAC sanctions programs regulations. We will update you on any changes, but you can begin to ensure that your export practices are consistent with the current BIS, OFAC and State Department sanctions program regulations.
 
  – Exporters of encryption products should be aware that the end of the year marks the close of the reporting period for semi-annual ENC reports. With the elimination of the Encryption Registration Number and the streamlining changes made to Encryption items, many items no longer require reporting or the requirements have changed. This is a good time to prepare required reports, which are due no later than February 1, 2018 and to analyze current products to determine if reporting is no longer required. … 

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COMM_a4
11. The Trade Practitioner: “Commission Updates to EU Control List of Dual-Use Items Enter into Force”

(Source: The Trade Practitioner, 29 Dec 2017.)
 
On 16 December, the European Commission’s updates to the EU dual-use export control list entered into force.
 
On 26 September 2017, the commission adopted the annual Delegated Regulation (2017/2268), which was published in the Official Journal on 15 December, updating the EU dual-use export control list in Annex I to Regulation (EC) No 428/2009. The update aligns the list with the decisions taken within the framework of the international non-proliferation regimes and export control arrangements in 2016.
 

The changes include updated acronyms and abbreviations, new definitions for certain terms such as “biological agents” and “authentication”, and new sub-entry controls. The most significant changes relate to dual-use information security items contained in Category 5 Part 2, a new sub-entry for integrated circuits with analogue-to-digital converters.

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

COMM_a5
12. Gary Stanley’s ECR Tip of the Day

(Source: Defense and Export-Import Update, 29 Dec 2017. Available by subscription from
gstanley@glstrade.com
.)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
.
 
DDTC’s Blue Lantern end-use monitoring includes pre-license, post-license, and post-shipment checks to verify the bona fides of foreign consignees and end-users, confirm the legitimacy of proposed transactions, and provide reasonable assurance that 1) the recipient is complying with the requirements imposed by the United States Government with respect to use, transfers, and security of defense articles and defense services; and 2) such articles and services are being used for the purposes for which they are provided.

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MSEX/IM MOVERS & SHAKERS

MS_a1
13. Teresa Ficaretta Moves to Ficaretta Legal Services, LLC

(Source: Teresa Ficaretta, teresa@ficarettalegal.com)
 
Teresa Ficaretta, previously Deputy Chief Counsel and Deputy Assistant Director of Enforcement Programs and Services, ATF, and a partner at a DC law firm, has opened her own practice of law at Ficaretta Legal Services, LLC. The firm specializes in federal firearms and explosives law and firearms and ammunition excise tax. Contact Teresa at 301-358-3553 or teresa@ficarettalegal.com.

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

MS_a214. Monday List of Ex/Im Job Openings; 162 Jobs Posted This Week, Including 35 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 (
35 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

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

# Bell Helicopter; Fort Worth, Texas;
Trade Compliance Specialist III;

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



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

# BMW North America; Woodcliff Lake, NJ; Senior Analyst, Trade Compliance; Requisition ID: 170004RD
*
CLASQUIN; Chicago, IL; Export Specialist

* Crane ChemPharma & Energy; Long Beach, CA;
Import Export Compliance Specialist;
# CSRA; San Diego, CA; Mid-Level FMS Case Analyst; Requisition ID: RQ 3035
# CSRA; San Diego, CA; Mid-level Case Analyst for MIDS FMS Program; Requisition ID: RQ6975 

#
 CSRA; San Diego, CA; 
Senior Case Analyst for MIDS FMS Program
; RQ6763 

# CSRA; San Diego, CA; Senior FMS Case Analyst; Requisition ID: 3004
# CSRA; San Diego, CA; Senior FMS Financial Analyst; Requisition ID: RQ3010
# CSRA; Aberdeen Proving Ground, MD; Foreign Military Sales Logistician (Logistics/Fielding) – Active Secret Required; Requisition ID: RQ8374

* 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:
 
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; Portland, OR; US Export Compliance Consultant;
* 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;
Global Trade Compliance Analyst,Traffic;
*
 FLIR; Wilsonville, OR; 
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

# Georgia-Pacific; Atlanta, GA; 
Sr. Analyst, International Trade
; Requisition ID: 052010 

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

# Harris Corporation; Rochester, NY; Trade Compliance Specialist; Job Code: CS20172308-20510
* 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

# InteliTrac Global Solutions; Herndon, VA; 
ITAR Compliance Official / Deputy Facility Security Officer;

# InteliTrac Global Solutions; Herndon, VA; ITAR Compliance Official
*
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; Sunnyvale, CA; Licensing Analyst (Early Career); Requisition ID: 415037BR_1
# Lockheed Martin; Littleton, CO; Licensing Analyst (Early Career); Requisition ID: 415037BR 
# Lockheed Martin; Littleton, CO; International Licensing Analyst; Requisition ID: 412863BR
* Lockheed Martin; Manassas, VA;
International Licensing Analyst; Requisition ID: 399617BR
* Lockheed Martin; Shelton, CT;
International Trade Compliance Manager; Requisition ID: 403295BR
# Lockheed Martin; Shelton, CT;
Senior International Licensing Analyst; Requisition ID: 415613BR
# Lockheed Martin; Stratford, CT;
International Trade Compliance Technology Specialist; Requisition ID: 415922BR
# Lockheed Martin; Ft Worth, TX;
International Trade Compliance Analyst; Requisition ID: 416747BR
# Lockheed Martin; Ft Worth, TX;
International Trade Compliance Senior Staff; Requisition ID: 416527BR

* Lockheed Martin; Ft Worth, TX; 
Senior Regulatory Compliance Analyst; Requisition ID: 
406664BR

#
 Lockheed Martin; Ft Worth, Texas; 
International Trade Compliance Engineer
; Requisition ID: 
411049BR 

* Lockheed Martin; Ft Worth, Texas;
International Trade Compliance Engineer; Requisition ID: 
411049BR_1

* 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; Orlando, FL;
International Trade Compliance Engineer; Requisition ID: 
411049BR_2

# Lockheed Martin; Orlando, FL;
International Licensing Analyst Staff; Requisition ID: 415383BR
# Lockheed Martin; Oswego, NY;
Licensing Analyst; Requisition ID: 415717BR

*
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

# OneWeb; Arlington, VA;
Export Compliance Specialist

* 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 SAS; McKinney, TX;
Senior Regulatory Compliance Analyst; Requisition ID: 
107180BR
# Raytheon IIS; Orlando, FL;
 
Global Trade Licensing Analyst II; Requisition ID: 104036BR
# Raytheon IIS; Dulles, VA;
Global Trade Licensing Analyst II
Requisition ID: 104036BR
* 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 Imaging; Chestnut Ridge, NY; 
Director of International Trade Compliance; Requisition ID: 2017-5558
#
 Teledyne Imaging; Billerica, MA; Director of International Trade Compliance; Requisition ID: 2017-5558 

# Teledyne Imaging; Tarrytown, NY; 
Director of International Trade Compliance; Requisition ID: 2017-5558
# Teledyne Imaging; Kiln, MS; 
Director of International Trade Compliance; Requisition ID: 2017-5558
#
 Teledyne Imaging; Fredricton, NB; 
Director of International Trade Compliance
; Requisition ID: 2017-5558 

* Teledyne Geophysical; Houston, TX;
Trade Compliance Specialist/Administrator; Requisition ID: 2017-5459

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

# Textron; Hunt Valley, MD; 2018 Intern – Export Import Analyst;

# Textron; Hunt Valley, MD;
Manager – Export Compliance;

# Textron; Hunt Valley, MD;
Senior Manager – Export Compliance;

* 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

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

TEEX/IM TRAINING EVENTS & CONFERENCES

(Source: Editor)
 

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

ENEDITOR’S NOTES


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

EN_a317
. 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: 27 Dec 2017: 
82 FR 61153-61162
: Revisions, Clarifications, and Technical Corrections to the Export Administration Regulations

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders
  – Last Amendment: 28 Dec 2017: 
82 FR 61450-61451: Iraq Stabilization and Insurgency 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 (1 Jan 2018) 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: 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.

 
INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130.
  – Last Amendment: 30 Aug 2017: 82 FR 41172-41173: Temporary Modification of Category XI of the United States Munitions List
  – The only available fully updated copy (latest edition: 1 Jan 2018) 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_a0318
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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