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18-0312 Monday “Daily Bugle”

18-0312 Monday “Daily Bugle”

Monday, 12 March 2018

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The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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  1. State Posts Waiver of Missile Proliferation Sanctions Against Foreign Persons
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Posts FAQ on Reconciliation Entry Summaries Support Call Questions
  4. DHS/CBP Updates Export Manifest Appendices
  5. OMB/OIRA Reviews of Proposed Ex/Im Regulations
  6. State/DDTC: (No new postings.)
  7. EU Amends for the 282nd Time Restrictive Measures Concerning ISIL and Al-Qaida
  8. EU Extends Restrictive Measures Concerning Situation in Ukraine until 15 Sep 2018
  9. Germany BAFA Posts March Export Control Newsletter 
  1. Defense News: “Us Might Tie NATO Contributions to Tariff Exemptions”
  1. J.S. Maberry: “Importers Beware: 10 Things You Must Know About the Emergence of High-Stakes Customs Audits”
  2. J. Williams, J. Helder & J.C. Poling: “UK Jury Verdict Clarifies ‘Adequate Procedures’ Under UK Bribery Act”
  3. Gary Stanley’s EC Tip of the Day
  1. Monday List of Ex/Im Job Openings: 148 Jobs Posted, Including 18 New Jobs
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (22 Feb 2018), DOD/NISPOM (18 May 2016), EAR (16 Feb 2018), FACR/OFAC (5 Mar 2018), FTR (20 Sep 2017), HTSUS (27 Feb 2018), ITAR (14 Feb 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. State Posts Waiver of Missile Proliferation Sanctions Against Foreign Persons

(Source: Federal Register, 12 Mar 2018.)
 
83 FR 10762: Waiver of Missile Proliferation Sanctions Against Foreign Persons
* AGENCY: Department of State.
* ACTION: Notice.
* SUMMARY: A determination has been made pursuant to the Arms Export Control Act and Export Administration Act (as carried out under Executive Order 13222 of August 17, 2001).
* SUPPLEMENTARY INFORMATION: Consistent with section 654(c) of the Foreign Assistance Act of 1961, as amended, notice is hereby given that the Secretary of State has made a determination pursuant to Section 73 of the Arms Export Control Act (22 U.S.C. 2797b) and Section 11B(b) of the Export Administration Act of 1979 (50 U.S.C. app. 2410b(b)), as carried out under Executive Order 13222 of August 17, 2001, and has concluded that publication of the determination would be harmful to the national security of the United States.
 
  Christopher A. Ford, Assistant Secretary of State for International Security and Nonproliferation.

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

OGSOTHER GOVERNMENT SOURCES

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

* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 13 March 2018.]

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

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

(Source:
CSMS #18-000210, 9 Mar 2018.)
 
Providing additional information to frequently asked questions on an ACE Deployment Support Daily Call.
 
ACS Recon Summaries, Extension Request and CBP Control
 
Q: How to request an extension of liquidation for a reconciliation that has been filed?
 
A: The process is the same for all summaries submitted; filers may choose to submit an extension request via paper or electronic format, via Document Imaging System (DIS), the team’s email inbox or other established procedure to their assigned Center.
 
Q: When is a Reconciliation Entry summary in CBP control?
 
A:
  – The reconciliation entry summary moves to CBP status on “statement print date” if reconciliation entry summary is placed on statement; or
  – CBP places the reconciliation entry summary in CBP status when the reconciliation entry summary is transmitted as “single pay” with no monies owed and the batch job performed at end of day processing places the reconciliation entry summary in CBP status.
 
Q: How to complete a Reconciliation Entry summary originally submitted in ACS?
 
A:
  – The Trade may retransmit via ABI the reconciliation entry summary in ACE and be subject to all the ACE validations; or
  – Trade may submit the amended/updated data in paper format without ANY retransmission in ABI.
  – The paper change submission will be sent to the port that rejected the reconciliation entry summary.
 
For those reconciliation entry summaries that have a request to “withhold liquidation” in ACS, and where transmitted as a No-Change, are subject to a full retransmission in ACE.
 
  – Questions concerning Reconciliation may be sent to: OT-RECONFOLDER@cbp.dhs.gov
* * * * * * * * * * * * * * * * * * * * 

(Source:
CSMS #18-000213, 12 Mar 2018.)
 
CBP Export Multimodal Manifest appendices have been updated so each document is separate from each other. They can be found at the following link under tab labeled “Appendices”.
 
Appendix I – Reference and Exemption Codes – has been updated to include the agreed upon new exemption codes. Please pay close attention to the ‘note’ provided in Appendix I. “Highlighted Exemption Codes will be deactivated on June 2nd 2018. The new exemption codes located at the bottom of the document can be submitted in a new manifest or amended manifest filing starting Feb 27th 2018”.
* * * * * * * * * * * * * * * * * * * * 

(Source:
OMB/OIRA
, 9 Mar 2018)  
 
* Regulatory Reform Revisions to the International Traffic in Arms Regulations
  – AGENCY: State
  – STAGE: Final Rule
  – RECEIVED DATE: 9 March 2018
  – RIN: 1400-AE52
  – STATUS: Pending Review
 
* Application of the Definition of Machinegun to “Bump Fire” Stocks and Other Similar Devices
  – AGENCY: DOJ/ATF
  – STAGE: Proposed Rule
  – RECEIVED DATE: 9 March 2018
  – RIN: 1140-AA52
  – STATUS: Pending Review
* * * * * * * * * * * * * * * * * * * * 

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

 
Regulations:
  – Commission Implementing Regulation (EU) 2018/349 of 8 March 2018 amending for the 282nd time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organisations
* * * * * * * * * * * * * * * * * * * * 

 
On 12 March 2018, the Council prolonged the restrictive measures over actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine for a further six months, until 15 September 2018. The measures consist of asset freezes and travel restrictions. They continue to apply to 150 persons and 38 entities.
 
An assessment of the situation did not justify a change in the sanctions regime. The relevant information and statement of reasons for the listing of these persons and entities were updated as necessary.
 
The legal acts will available in the EU Official Journal of 13 March 2018.
 
Other EU measures in place in response to the Ukraine crisis include: 
 
  – economic sanctions targeting specific sectors of the Russian economy, currently in place until 31 July 2018;
  – restrictive measures in response to the illegal annexation of Crimea and Sevastopol, limited to the territory of Crimea and Sevastopol, currently in place until 23 June 2018.
 
* * * * * * * * * * * * * * * * * * * * 

(Source:
German BAFA, 12 Mar 2018.)
 
European Union Law/Embargo Measures
 
Democratic Republic of Congo
 
With the Council Implementing Regulation (EU) 2018/197 of 9 February 2018 [OJ (EU) No L 38 of 10 February 2018, page 2] implementing Article 9 of Regulation (EC) No. 1183/2005 imposing certain specific restrictive measures directed against persons acting in violation of the arms embargo with regard to the Democratic Republic of Congo, four persons were added to the list of persons designated by the United Nations Sanctions Committee in Annex I to that regulation. Two of these persons were already designated under Annex Ia to that regulation by the Council of the European Union and were removed from Annex Ia to be now designated under Annex I to that Regulation.
 
Democratic People’s Republic of Korea
 
With the Council Implementing Regulation (EU) 2018/87 of 22 January 2018 [OJ (EU) No. L 16 I of 22 January 2018, page 1] implementing Regulation (EU) 2017/1509 concerning restrictive measures against the Democratic People’s Republic of Korea, seventeen persons were added to Annex XVI to that regulation.
 
Libya
 
With the Commission Implementing Regulation (EU) 2018/126 of 24 January 2018 [OJ (EU) No. L 22 of 26 January 2018, page 12] amending Council Regulation (EU) 2016/44 concerning restrictive measures in view of the situation in Libya, the listing of the vessel CAPRICORN was extended in Annex V to that regulation. The listing of the vessel LYNN S was also extended with the Commission Implementing Regulation (EU) 2018/166 of 2 February [OJ (EU) No. L 31 of 3 February 2018, page 82]. The Commission Implementing Regulation (EU) 2018/200 of 9 February 2018 [OJ (EU) No. L 38 of 10 February 2018, page11] replaced the name of the vessel “CAPRICORN” by “NADINE” and modified other information on the vessel.
 
Zimbabwe
 
The Commission Implementing Regulation (EU) 2018/223 of 15 February 2018 [OJ (EU) No. L 43 of 16 February 2018, page 10] amending the Council Regulation (EC) No. 314/2004 concerning restrictive measures in respect of Zimbabwe updated the entry for one person listed under figure 1 in Annex III to that regulation (Mugabe).
 
South Sudan
 
With the Council Implementing Regulation (EU) 2018/164 of 2 February 2018 [OJ (EU) No. L 31 of 3 February 2018, page 1] implementing Article 22 (1) to Regulation (EU)  2015/735 concerning restrictive measures in view of the situation in South Sudan, three persons were added to Annex II to that Regulation.
 
Tunisia
 
With the Council Implementing Regulation (EU) 2018/137 of 29 January 2018 [OJ (EU) No. L 25 of 30 January 2018, page 1] implementing Regulation  (EU) No. 101/2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Tunisia, the reason for the listing of a person (No. 5 Materi) was amended in Annex I to that regulation.
 
Venezuela
 
With the Council Implementing Regulation (EU) 2018/88 of 22 January 2018 [OJ (EU) No. L 16 I of 22 January 2018, page 6] implementing Regulation (EU) 2017/2063 concerning restrictive measures in view of the situation in Venezuela, seven persons were added to Annex IV to that regulation.
 
Al-Qaida and ISIL
 
In accordance with the Commission Implementing Regulation (EU) 2018/256 of 20 February 2018 [OJ (EU) No. L 48 of 21 February 2018, page 39] amending for the 281st time Regulation (EC) No. 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da´esh) and Al-Qaida organisations, one entry was amended in the list of persons subject to the freezing of funds and economic resources (listed in Annex I to Regulation (EC) No. 881/2002).
 
Inside BAFA
 
Notifications on the transport and war weapons register
 
The War Weapons Control Act requires that companies have to report to BAFA stocks of war weapons and any inventory changes on a semi-annual basis. In the future it will be possible to transmit these reports electronically. For this purpose, BAFA initiated the project of the electronic war weapons register and, thus, takes part actively in the federal government’s objective to establish effective electronic ways of communication by the year 2020. In addition to forthcoming information events, BAFA informs about the development of this project on its homepage. As of 6 March 2018 the new version 0.8 of the interface for the submission of electronic notifications on the transport and war weapons register will be published at BAFA’s homepage. In parallel to this, the previous notification procedure and the coming reporting deadlines will continue to apply in accordance with the War Weapons Control Act. It means that the war weapons stocks and any inventory changes have to be supplied to BAFA on the next deadline, 31 March 2018, within two weeks from that date.

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

NWSNEWS

NWS_a1
11. Defense News: “Us Might Tie NATO Contributions to Tariff Exemptions”

(Source: Defense News, 10 Mar 2018.) [Excerpts.]
 
U.S. allies seeking to avoid the steel and aluminum tariffs approved by President Donald Trump might be asked to step up their financial commitments to NATO.
 
Treasury Secretary Steve Mnuchin told CNBC in a Friday interview that the president will consider national security, noting that Trump wants to be sure that NATO gets more funding from European allies who Trump has previously criticized for not contributing enough.
 
“If we’re in NATO, he wants to make sure that NATO gets more money so that NATO can protect all of us and fulfill its goal,” Mnuchin said, underscoring Trump’s push to get NATO allies to pay 2 percent on defense.
 
Trump drew on rarely used national security grounds to place a 25 percent tax on steel imports and 10 percent tax on imported aluminum. Only Canada and Mexico – both partners in the North American Free Trade Agreement being renegotiated – were excluded from the tariffs.
 
The Treasury secretary said he has been speaking with his foreign counterparts and “my expectation is there may be some other countries that he considers in the next two weeks.” …

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

COMMCOMMENTARY

COMM_a01
12. J.S. Maberry: “Importers Beware: 10 Things You Must Know About the Emergence of High-Stakes Customs Audits”
(Source: Mondaq, 9 Mar 2018.)
 
* Author: J. Scott Maberry, Esq., Sheppard, Mullin, Richter & Hampton LLP, smaberry@sheppardmullin.com.
 
U.S. importers are seeing an increase in enforcement activity by U.S. Customs and Border Protection. Here are the ten things you must know about this trend.
 
  (1) Increased enforcement is mandated from the top
. New legislation in 2016 created the first comprehensive reauthorization of CBP since the creation of the Department of Homeland Security in 2003. The overall goal of the new law is to protect the economic security of the United States. In CBP’s strategic plan implementing the new law, the following actions are mandated:

– Increase the number of exams and targeted audits
– Use predictive analytics to identify audit targets; and
– Leverage whistleblowers, intelligence sources, and industry collaboration to identify high-risk trade.
 
  (2) The increasing enforcement trend is real.
The numbers are in for the last two years of enforcement activity under the new law. Seizures for trade remedies violations alone increased 31%; audits increased by a similar factor; and total collectable fines and penalties were $100 million in 2016 (the last year for which data are available) compared to $59.3 million in Fiscal Year 2015. That is a 68% increase in fines and penalties over a single year.
 
  (3) CBP has big data on your imports
. The new Automated Commercial Environment (ACE) is now nearly fully implemented. Virtually all U.S. import filings are conducted electronically through ACE, which is great because it eliminates tons of paperwork. It’s also great for enforcement because it allows all import data to be collected in a single place and analyzed by CBP (see point 4).
 
  (4) CBP is crunching your import data.
CBP’s import data analysis is increasing daily. It uses very sophisticated algorithms to spot anomalies in import data, which helps it target specific importers for further scrutiny. Audits that used to be almost all random are now a sophisticated mix of random and highly targeted.
 
  (5) The agency has lots of help
. CBP chairs a body known as the Commercial Targeting and Analysis Center (CTAC), composed of 12 U.S. government agencies working together to target commercial shipments that pose a threat.
 
  (6) Big importers are increasingly targeted; all importers are at risk
. One important factor in the CBP auditing algorithms is the size of your import account. Typically, if you import $100 million or more in goods into the United States in a year you should consider yourself a very likely candidate for an audit. But audits can target any importer and any issue, including NAFTA compliance, tariff classification errors, compliance with antidumping and countervailing duties orders, and the whole range of import compliance.
 
  (7) You may be informed of enforcement actions in multiple ways. CBP can issue written requests for information, written “informed compliance notification letters,” or even a telephone notification that the company has been chosen for an audit. Be sure you have a system in place to escalate any CBP communication to the right person in your organization.
 
  (8) Penalties can be very significant.
Penalties for customs violations can range from double the import duty loss for mere negligence (or 20% of the value of the goods if the violation did not affect the assessment of duties) up to the entire value of the imported merchandise in cases of fraud.
 
  (9) Consider a Prior Disclosure.
Under customs law, fully disclosing a violation to CBP before a formal CBP or Immigration and Customs Enforcement (ICE) investigation of the violation can result in penalties being substantially reduced or eliminated.
 
  (10) You can mitigate penalty risk by conducting an internal risk assessment.
It is best to know your risks before Customs comes calling. If you haven’t conducted a thorough Customs risk assessment, consider conducting one. New methods of statistical sampling have been authorized in customs cases, which can substantially streamline your risk assessment activity. Once you know your risk areas, you can make an informed decision about whether to file a prior disclosure.

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

 
* Authors: Justin Williams, Esq., williamsj@akingump.com, +44 20-7012-9660; Jasper Helder, Esq., jasper.helder@akingump.com, +44 20-7661-5308; and Jonathan C. Poling, Esq., jpoling@akingump.com, +1 202-887-4029. All of Akin, Gump, Strauss, Hauer & Feld LLP.
 
In an important decision given on February 21, 2018, a jury in English court proceedings has considered for the first time what “adequate procedures” should be for the purpose of a defense to the corporate offense of failing to prevent bribery under the UK Bribery Act 2010.
 
Skansen Interiors Limited, an office interiors contractor, self-reported to the UK National Crime Agency that its former managing director had paid a bribe to secure a £6 million refurbishment contract. As a result, the company was prosecuted under the Section 7 corporate offense under the Bribery Act for failing to prevent bribery. Given that Skansen had self-reported and that it was now a dormant company, there was some surprise that the Crown Prosecution Service (CPS) had decided to prosecute. It may be that the CPS considered that imposing conditions against a dormant company under a deferred prosecution agreement was not practicable and/or that a prosecution would send out a useful message about the need for compliance.
 
At trial, Skansen had the evidential burden of establishing that it had “adequate” antibribery procedures in place. The jury found that the company had failed to discharge that burden and hence was guilty of the offense. The following factors appear to have been relevant to that outcome:
 
  – While Skansen did have policies concerning transparency and integrity, and it had financial controls requiring multiple approvals for transactions, it did not have a policy specifically directed to preventing offenses under the Bribery Act. The fact that it had only around 30 employees who worked in a single open-plan office does not appear to have justified the absence of such a policy.
  – It did not have a dedicated compliance officer. The company’s self-reporting and its cooperation with the authorities does not appear to have made up for that omission:
  – There was no evidence that Skansen had trained its staff or that employees had read or been reminded of the company’s existing policies or had agreed to comply with them.
 
This case is of considerable importance in emphasizing not only the appetite of the U.K. authorities to pursue corporate prosecutions, but also the high hurdle to be satisfied in order to achieve “adequate procedures” and to avoid corporate criminal liability, which can be additional to individual liability in respect of acts of bribery.
 
The jury’s verdict also illustrates the distinctions between the U.K. and U.S. approaches to corporate criminal liability. In the United States, strict liability criminal offenses are virtually unknown. Instead, corporations may be held criminally liable in the United States on a respondeat superior theory based on the unlawful acts of their employees and agents. However, in both the United States and the United Kingdom, it is clear that prosecutors will carefully scrutinize a company’s compliance program and other controls in making discretionary decisions about whether to bring criminal charges against the entity. 

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

COMM_a3
14. Gary Stanley’s EC Tip of the Day
(Source: Defense and Export-Import Update; 9 Mar 2018. Available by subscription from
gstanley@glstrade.com
.)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
.
 
The following five types of facts determine your obligations under the ten general prohibitions in EAR Part 736 and the EAR generally:
 
  (1) Classification of the item. The classification of the item on the Commerce Control List (see part 774 of the EAR);
 
  (2) Destination. The country of ultimate destination for an export or reexport (see parts 738 and 774 of the EAR concerning the Country Chart and the Commerce Control List);
 
  (3) End-user. The ultimate end user (see General Prohibition Four (paragraph (b)(4) of this section) and Supplement No. 1 to part 764 of the EAR for references to persons with whom your transaction may not be permitted; see General Prohibition Five (Paragraph (b)(5) of this section) and part 744 for references to end-users for whom you may need an export or reexport license).
 
  (4) End-use. The ultimate end-use (see General Prohibition Five (paragraph (b)(5) of this section) and part 744 of the EAR for general end-use restrictions); and
 
  (5) Conduct. Conduct such as contracting, financing, and freight forwarding in support of a proliferation project as described in part 744 of the EAR.

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

MSEX/IM MOVERS & SHAKERS

MS_a215. Monday List of Ex/Im Job Openings; 148 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
)

# Aerovironment; Simi Valley, CA; Trade Compliance Specialist II; Job ID: 18-017

# Aerovironment; Simi Valley, CA;
Trade Compliance Director; Job ID: 18-018

*
AJC Logistics; Atlanta, GA; NVOCC Export Specialist;

* Allports Forwarding Inc.; Portland, OR;
Import Entry Specialist

* Arent Fox LLP; Washington, D.C.; International Trade Associate;

* Arent Fox LLP; Los Angeles, CA;
International Trade Associate;

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

* Boeing; St. Louis, MO; Trade Control Specialist – Mid Career; Requisition ID: 1700022214

* BMW North America; Woodcliff Lake, NJ;
Senior Analyst, Trade Compliance; Requisition ID: 170004RD
 * Buehler; Lake Bluff, IL;
Manager, Compliance and Logistics; Requisition ID: 2018-004

* Crown Corporation; New Bremen, Ohio; Trade Compliance Specialist; Requisition ID: 45311

* 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

* Danaher Science and Technology; United States; Senior Global Trade Compliance ManagerJob ID: COR000942
 

* Danaher Science and Technology;
Biberach an der Riß, Germany;
European Trade Compliance Specialist
Job ID: KAV001714 

* Danaher Science and Technology; Nationwide, India; Manager, International Regulatory Affairs
Job ID: CEP000339

# Dorman Products; Colmar, PA; Global Trade Compliance Specialist;
*
 DynCorp International; Tampa, FL; Foreign Disclosure Officer; Requisition ID: PR1701977

* Eaton; Syracuse, NY;
Global Logistics Manager; Requisition ID: 036620

* Eaton; Shanghai Shi, China;
Global Ethics and Compliance Director, APAC; Requisition ID: 039260

 * Elbit Systems of America; Fort Worth, TX;
Trade Compliance Manager; 2018-5916

* Elbit Systems of America; Fort Worth, TX;
Trade Compliance Officer; 2018-5917

* EMD Serono; Milan, Italy;
Trade Compliance Associate Internship
;

* EMD Serono; Shanghai, China; Import Export Supervisor;

# Emerson; Mexico City, Mexico; Export and Trade Compliance Analyst; Requisition ID: 18001203
* Esterline; Xenia, OH; Manager, International Trade Compliance;

* Esterline; Hong Kong;
Regional ITC Manager;
* Esterline; Singapore; Regional ITC Manager; 

* Esterline; Brea, CA; 
Senior Trade Compliance Specialist;

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

* Expeditors; Sunnyvale, CA;
Customs Compliance Supervisor;


* 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;


* 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
;
* Full Circle Compliance; Bruchem, Netherlands;
Legal Analyst, Manager

# FusionStorm; Newark, CA; Trade Compliance Specialist; Requisition ID: 2018-2350
* Garmin; Olathe, Kansas; International Trade Compliance Specialist; Requisition ID: 1800006

*
 General Atomics; San Diego, CA; 
Internship, Import/Export, Summer 2018
; Requisition ID: 15731BR 

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

* GHY International; Manitoba, Canada; Trade Analyst;
* GHY International; Pembina, ND (or remote); Ocean & Air Import Coordinator
# Gilead Sciences; Foster City, CA; Manager, Global Trade Compliance; R0001742
* 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;

# Hubbell, Incorporated; Greenville, SC; Export Compliance Specialist;
# Hubbell, Incorporated; Shelton, CT; Export Compliance Specialist;
# Hubbell, Incorporated; Centralia, MO; Export Compliance Specialist;
* Honda of America Manufacturing; Marysvile, OH;
Import Specialist

* 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;

* JABIL; St. Petersburg, FL;
Trade Compliance Manager
; Requisition ID: 207029
* JABIL; St. Petersburg, FL;
Trade Compliance Specialist; Requisition ID: 206581
* JABIL; Guadalajara, Mexico;
Classification & Export Licensing Analyst; Requisition ID: 207594

* KPMG U.S.; San Francisco, CA; Associate, Trade & Customs;

* 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; Arlington, VA; Export Licensing Staff
Requisition ID 419903BR
* Lockheed Martin; Arlington, VA; International Trade Compliance Staff; Requisition ID 418761BR

* L-3 LINK Division; Tulsa, OK; 
Contracts Administrator 1; Requisition ID: 091686
* 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
* Maersk/DAMCO; Agent de transit IMPORT – EXPORT; Job Ref.: DC-164022
* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst; Requisition ID: 16000DYY
* Medtronic; Wash DC;
Global Trade Lawyer;
stacy.m.johnson@medtronic.com; Requisition ID: 170002ON

# MTS Systems; Eden Prairie, MN;
Global Trade Compliance Manager; Requisition ID: 37841
# NORDHAM; Tulsa, OK;
Global Trade Compliance Manager; Requisition ID: 14080BR
* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2
Requisition ID
:
 
17022803

* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2; Requisition ID: 17022805
*
Northrop Grumman; Huntsville, AL;
International Trade Compliance 3
; Requisition ID: 17026172

# Office of the Director of National Intelligence; McLean, VA;
Associate General Counsel;
* Oracle; United States;
Senior Customs Compliance Specialist; Job ID: 170018FJ

* Oracle; United States;
Customs Compliance Specialist; Job ID: 17001CBG

* Oracle; Bejing, China;
Senior Customs Compliance Specialist – APAC; Job ID: 17001CBI

* Raytheon Company; El Segundo, CA; Senior Analyst, Global Trade Licensing; Requisition ID: 111121BR
* Raytheon Company; El Segundo, CA; Global Trade Manager; Requisition ID: 108227BR

* Raytheon Company; El Segundo, CA;
Principal, Global Trade Licensing; Requisition ID: 
108230BR
 

* Raytheon Company; Tucson, AZ;
Sr. Export Licensing Specialist;
 Requisition ID: 
108970BR;
ryan.murphy@raytheon.com

* Raytheon Company; Tucson, AZ;
Export Licensing Specialist; Requisition 


ID: 108960BR;
 ryan.murphy@raytheon.com

* Raytheon Company; Tucson, AZ;
Export License & Compliance Specialist; Requisition ID: 
108961BR

* Raytheon Company; Tucson, AZ;
Trade Compliance Principal Investigator; Requisition ID: 
110444BR

* Raytheon Company; Tewksbury, MA;
Licensing Manager; Requisition ID: 
110837BR

* Raytheon Company; Waltham, MA; 
Licensing Manager
; Requisition ID: 
110837BR 
* Raytheon Company; El Segundo, CA; Licensing Director; Requisition ID: 110838BR

* Raytheon Company; Richardson, TX;  
Licensing Director
; Requisition ID: 110838BR 

* Rolls-Royce; Indianapolis, IN;
 
Export Control Specialist; Req ID:
 

JR6025484 

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

* SABIC; Houston, TX; Senior Analyst, International Trade Compliance

Requisition ID 8655; OR Contact: Jason Washington
* SABIC; Houston, TX;
Senior Analyst, Trade Compliance; Requisition ID: 8644BR

* SAFRAN Group; United Kingdom;
Trade Compliance Specialist;

* Sig Sauer; Newington, New Hampshire; Trade Compliance Manager
* The Spaceship Company; Mojave, CA; Export Compliance Officer;
* Spirent; San Jose, CA;
Global Trade Compliance Specialist; Requisition ID: 4088

* TE Connectivity; Middletown, PA; Manager II, Global Trade Compliance; Requisition ID: 17361
* Teledyne Geophysical; Houston, TX; Trade Compliance Specialist; Requisition ID: 2017-5459
* Teledyne Microwave Solutions; Mountain View, CA; Trade Compliance Administrator II; Requisition ID: 2018-6089

* 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 

# Tenneco, Inc.; Lake Forest, IL;
Americas Global Trade Compliance Manager; Requisition ID: 178693-846

# Tenneco, Inc.; Lake Forest, IL; Customs & Trade Compliance Coordinator; Requisition ID: 178353-846
* Textron; Hunt Valley, MD;
Senior Manager – Export Compliance;

*
Thermo Fisher Scientific; Waltham, MA;
Director, Global Trade Compliance
;

* Thermo Fisher Scientific; Shanghai, China; 
Trade Compliance Specialist
; Job ID: 57953BR 

* Thermo Fisher Scientific; Franklin, MA; 
Trade Compliance Specialist; Job ID: 
61435BR

* Thermo Fisher Scientific; Carlsbad, CA; 
Compliance Specialist II; Job ID: 
60951BR

* Thermo Fisher Scientific; Suwanee, GA;
Export Compliance Specialist III; Job ID:
60224BR

* TLR; San Fransisco, CA;
Import CSR; Requisition ID: 1040

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

* Trek; Waterloo, WI; Global Trade & Logistics Specialist;
* Ultra Electronics; Loudwater, United Kingdom;
International Trade Manager;

* United Technologies Corporation, UTC Aerospace Systems; Birmingham, UK; 
International Trade Compliance Manager;
Requisition ID: 39257
* 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; Chula Vista, CA; 
Sr. Associate, ITC Digital Solutions
; Requisition ID: 59662BR
* United Technologies Corporation, UTC Aerospace Systems; Chula Vista, CA

Supply Chain Specialist- ITC/Regulatory
; Requisition ID: 53794BR
* United Technologies Corporation, UTC Aerospace Systems; Hood River, OR;
International Trade Compliance Specialist
; Requisition ID: 60584BR
* United Technologies Corporation, UTC Aerospace Systems; Phoenix, AZ;

* 
University of Colorado, LASP; Boulder CO; 
Export Compliance Administrator

hrads@lasp.colorado.edu
; Requisition ID: 12298
* Varian; Belgium, Switzerland, Netherlands, or UK; EMEIA Trade Lead – Senior Manager Trade Compliance; Requisition ID: 12301BR; Contact 
Gavin Tickner at 
Gavin.Tickner@varian.com
 
* Varian; Paolo Alto, CA; Senior Trade Compliance Analyst; Requisition ID: 12735BR; Contact 
Uyen Tran at
Uyen.Tran@varian.com
* Varian; Beijing, China;
Trade Compliance Analyst; Requisition ID: 
12297BR; Contact 
Susan Lin at
 WeiZhen.Lin@varian.com
* Vigilant; Negotiable Location, USA;
Global Trade Compliance Analyst;

* Virgin Galactic; Mojave, CA; Export Compliance Officer; Requisition ID: 2018-3440
* Virgin Galactic; Las Cruces, NM; Export Compliance Officer; Requisition ID: 2018-3558
* Virgin Galactic; Las Cruces, NM; Director of Trade Compliance; Requisition ID: 2018-3349
* Virgin Galactic; Washington, D.C.; Director of Trade Compliance; Requisition ID: 2018-3349
# Williams International; Pontiac, MI; Trade Compliance Specialist; Requisition ID: 17-0275

# World Wide Technology; Hong Kong;
Trade Compliance Specialist; Requisition ID: 005

# World Wide Technology; Edwardsville, IL; International Trade Compliance Specialist; Requisition ID: 6110
*
Xylem, Inc.; Remote, United States;
Manager, Global Ethics & Compliance
;

# Zeiss Group; Thornwood, NY;
Trade Compliance Specialist;

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

ENEDITOR’S NOTES

 
Torquato Tasso (11 Mar 1544 – 25 Apr 1595; was an Italian poet of the 16th century, best known for his poem Gerusalemme Liberata (Jerusalem Delivered, 1581), in which he depicts a highly imaginative version of the combats between Christians and Muslims at the end of the First Crusade, during the Siege of Jerusalem.)
  – “Love is when he gives you a piece of your soul that you never knew was missing.”
 
* Earl Nightingale (12 Mar 1921 – 25 Mar 1989; was an American radio speaker and author, dealing mostly with the subjects of human character development, motivation, and meaningful existence. He was also, during the 1950s, the voice of Sky King, the hero of a radio adventure series.  Nightingale was the author of The Strangest Secret, which economist Terry Savage has termed “…one of the great motivational books of all time.”)
  – “All you need is the plan, the road map, and the courage to press on to your destination.”
  – “We are at our very best, and we are happiest, when we are fully engaged in work we enjoy on the journey toward the goal we’ve established for ourselves. It gives meaning to our time off and comfort to our sleep. It makes everything else in life so wonderful, so worthwhile.”
 
* George Berkeley (12 Mar 1685 – 14 Jan 1753; was an Irish philosopher whose primary achievement was the advancement of a theory he called “immaterialism” (later referred to as “subjective idealism” by others). This theory denies the existence of material substance and instead contends that familiar objects like tables and chairs are only ideas in the minds of perceivers and, as a result, cannot exist without being perceived.)
  – “He who says there is no such thing as an honest man, you may be sure is himself a knave.”
 
Monday is Punday:
 
* As a scarecrow, people say I’m outstanding in my field.  But hay, it’s in my jeans.
 
* I couldn’t believe that the highway department said they were charging my teenage son with theft! 
But when I got home, all the signs were there.
 
* Thanks for explaining the word “many” to me, it means a lot.

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

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.  The latest amendments 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: 22 Feb 2018: 83 FR 7608-7610: Technical Amendment to List of User Fee Airports: Name Changes of Several Airports and the Addition of Five Airports
 
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: 
16 Feb 2018:
83 FR 6949-6956
: Russian Sanctions: Addition of Certain Entities to the Entity List [Addition of 21 Entities to Entity List.]

  
*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders

  – Last Amendment: 5 Mar 2018:
83 FR 9182-9204: North Korea 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 2018: 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: 27 Feb 2018:
Harmonized System Update 1802
, containing 164 ABI records and 38 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: 14 Feb 2018: 83 FR 6457-6458: Amendment to the International Traffic in Arms Regulations: Addition of South Sudan [Amends ITAR Part 126.] 

  – The only available fully updated copy (latest edition: 14 Feb 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, DOE/NRC, DOJ/ATF, DoD/DSS, DoD/DTSA, FAR/DFARS, 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, provided attribution is given to “The Export/Import Daily Bugle of (date)”. 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

* BACK ISSUES: An archive of Daily Bugle publications from 2005 to present is available
HERE.

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