;

18-0326 Monday “Daily Bugle”

18-0326 Monday “Daily Bugle”

Monday, 26 March 2018

TOP
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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.

[No items interested noted today.]

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. Commerce/Census: “Useful Acronyms”
  4. Justice: “Pennsylvania Man Charged with Illegally Exporting Firearm Parts to Iraq”
  5. Justice: “Russian Citizen Sentenced to 18 Months in Federal Prison for Attempting to Illegally Export More Than $100,000 in Firearm Parts and Accessories”
  6. State/DDTC Posts Name Changes for Two Entities
  1. J. Reeves: “ATF’s Proposed Rulemaking Will Classify Bump-Stocks as ‘Machineguns'”
  2. M.V. Miller, S.T. Murray & B.J. Murphy: “Steel/Aluminum Additional Tariffs -3/23 Current Considerations”
  3. S.G. Alfonso: “GDPR for the E.U. is Coming 25 May 2018”
  4. Gary Stanley’s EC Tip of the Day
  1. Monday List of Ex/Im Job Openings: 158 Jobs Posted, Including 10 New Jobs
  1. ECTI Presents “United States Export Control (ITAR/EAR/OFAC)” Seminar Series, 4-7 Jun in San Diego, CA
  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 (22 Mar 2018), FACR/OFAC (19 Mar 2018), FTR (20 Sep 2017), HTSUS (14 Mar 2018), ITAR (14 Feb 2018) 
  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)

* Defense; Defense Acquisition Regulations System; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Defense Federal Acquisition Regulation Supplement (DFARS), Independent Research and Development Technical Descriptions [Publication Date: 27 March 2018.]

* President; ADMINISTRATIVE ORDERS; China; Policies, Practices, or Actions Related to Technology Transfer, Intellectual Property, and Innovation (Memorandum of March 22, 2018) [Publication Date: 27 March 2018.]


[Editor’s Note: The Administrative Order was already included in the 22 March Daily Bugle, item #10.]

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

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

 
Have you shipped a package overseas that is valued over $2,500 per Schedule B classification number or licensed? Were you told to file Electronic Export Information (EEI) in the Automated Export System (AES) to receive an Internal Transaction Number (ITN)? Are you confused, lost or feel like a contestant on Wheel of Fortune with the abundance of letter combinations presented to you? Rest assured that we are here to help you.
 
When filing for the first time you are likely to encounter various acronyms that are unfamiliar to you. To assist you with the filing process, here are the most commonly used acronyms:
 
AES
– The Automated Export System is where your reported EEI goes when you file it. This system gathers, processes and stores the export information. AES filers can transmit EEI to the AES via Automated Commercial Environment (ACE) AESDirect, approved self-programming software, approved vendor software, or an approved service center. Government agencies use the data that you report to the system to provide the public with vital statistics about our country’s economy. For a detailed look at these statistics, please visit our webpage.
 
EEI
– Quite simply this means Electronic Export Information. Think of this as an electronic declaration of merchandise leaving the United States and being exported to a foreign country.  This will include information about the sender and the receiver of the goods, along with information about the goods being exported.
 
EIN
– The Employer Identification Number is a unique nine-digit number issued by the Internal Revenue Service (IRS). Whether you are a business, or an individual exporting goods, you must obtain this number from the IRS in order to register for an account to gain access to the AES. Individuals wanting to export are advised to apply for an EIN as sole proprietors. See instructions on how to apply.
 
HTS
– The Harmonized Tariff Schedule is a 10-digit number used to classify goods for import. In Step 3 of your filing, you may classify your product with either an HTS code, or a Schedule B number. The choice is yours. Please note that there are HTS numbers that are invalid for export.
 
IATA
– The International Air Transport Association code is how carriers for air exports are identified. You will encounter this field in Step 4 of your filing. Please contact your air carrier for the correct reporting of their IATA.
 
ITN
– The Internal Transaction Number is the confirmation number you receive once your electronic export information is submitted to and accepted by the AES. This number serves as proof of filing in the AES.
 
SCAC
– The Standard Carrier Alpha Code, issued by the National Motor Freight Transit Association, is how carriers for vessel, rail and truck exports are identified. You will encounter this field in Step 4 of your filing. Please contact your carrier for the correct reporting of their SCAC.
 
Schedule B
– This 10-digit number is used to classify the goods that you are exporting. You will encounter this required field in Step 3 of your filing in the ACE AESDirect portal. To classify your goods correctly, please visit our Schedule B Search Engine webpage.
 
SRN
– This refers to the Shipment Reference Number, which is a unique number that you create for each individual shipment. This can be any combination of letters and numbers up to 17 characters. Since this number cannot be reused, you must create a new and unique number for each shipment. You will encounter this required field in Step 1 of your filing in the ACE AESDirect portal.
 
USPPI
– The U.S. Principal Party in Interest refers to the person in the United States that receives the primary benefit, monetary or otherwise, of the export transaction. You will encounter this required filed in Step 2 of your filing in the ACE AESDirect portal.

Here is a full list of AES acronyms and definitions. For additional definitions, visit the census.gov glossary.
* * * * * * * * * * * * * * * * * * * * 

(Source:
Justice, 23 Mar 2018.) [Excerpts.]
 
An indictment was unsealed today charging Ross Roggio, 49, of Stroudsburg, Pennsylvania, and Roggio Consulting Company, LLC, a firm with which Ross Roggio was associated, for alleged involvement in a conspiracy to illegally export firearm parts, firearm manufacturing tools, and “defense services,” including items used to manufacture M4 rifles, from the United States to Iraq, in violation of the Arms Export Control Act and the International Emergency Economic Powers Act. …
 
The indictment charges Ross Roggio and Roggio Consulting Company, LLC with criminal conspiracy, illegal export of goods, wire fraud and money laundering. Pursuant to regulations of the U.S. Department of Commerce, a license is required to export certain goods and services from the United States to Iraq for reasons of regional stability and national security. Similarly, defense services and defense articles may not be exported to Iraq without a license from the U.S. Department of State.
 
The indictment alleges that, beginning in January of 2013 until the date of the indictment, Ross Roggio conspired to export both items and services from the United States to Iraq, without the required U.S. Commerce Department and U.S. State Department licenses. The conspirators allegedly purchased firearms parts and manufacturing tools from the United States, illegally exported the items to Iraq where the items were utilized and incorporated in the manufacture and assembly of complete firearms in a firearms manufacturing plant constructed and operated in part by Ross Roggio. It is alleged that the items illegally exported included: M4 Bolt Gas Rings MIL; Firing Pin Retainers; Rifling Combo Buttons, and “defense services.” The defense services allegedly provided by Ross Roggio and his firm include the furnishing of assistance to foreign persons in the manufacture of firearms.
 
In addition to the charges relating to export controls violations, the indictment also alleges that Ross Roggio and his firm committed wire fraud on at least three occasions by purchasing items from a United States company and providing said company with false information about the end-user of the items. Finally, the indictment charges Ross Roggio and his firm with 27 counts of money laundering in the form of bank transfers from Iraq to two accounts within the Middle District of Pennsylvania, in furtherance of their unlawful export conspiracy. …
* * * * * * * * * * * * * * * * * * * * 

(Source:
Justice, 22 Mar 2018.) [Excerpts.]
 
A Russian citizen was sentenced today to 18 months in federal prison for attempting to illegally export from the United States more than $100,000 in firearm parts, ammunition and accessories, including parts designed for assault rifles.
 
KONSTANTIN CHEKHOVSKOI was apprehended by Homeland Security Investigations (HSI) Special Agents at O’Hare International Airport in Chicago on April 26, 2017, as he attempted to board a flight for Stockholm, Sweden. In Chekhovskoi’s eleven checked bags were the firearm parts, ammunition and accessories, including bullets, rifle magazines, triggers, stocks, muzzle brakes and scopes, many of which were designed for assault rifles such as AK-47s and M4s. Chekhovskoi lacked the required license for the export-controlled items.
 
Chekhovskoi, 44, of St. Petersburg, Russia, pleaded guilty last year to one count of attempting to fraudulently and knowingly export firearm parts. U.S. District Judge Sara L. Ellis imposed the 18-month prison term and fined Chekhovskoi $100,000. …
* * * * * * * * * * * * * * * * * * * * 

(Source:
State/DDTC, 26 Mar 2018.)
 
  – Discovery Air Defence Services Inc. Changes Name to Top Aces Inc.
  – Andøya Rakettskytefelt AS Changes Name to Andøya Space Center AS (ASC)
* * * * * * * * * * * * * * * * * * * * 

COMMCOMMENTARY

COMM_a01
7. J. Reeves: “ATF’s Proposed Rulemaking Will Classify Bump-Stocks as ‘Machineguns'”
(Source: Reeves & Dola LLP, 26 Mar 2018.)
 
* Author: Johanna Reeves, Esq., Reeves & Dola LLP, jreeves@reevesdola.com, 202-715-9941.
 
On Friday, March 23, 2018, Attorney General Sessions announced that the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) is set to publish proposed rulemaking to classify bump-stocks as machineguns. The Notice of Proposed Rulemaking (NPRM) has not yet been published in the Federal Register, but it is available on DOJ’s website.
 
If adopted, the proposed rule will amend ATF’s regulations in 27 C.F.R. Part 479 to “clarify” ATF’s interpretations of the statutory terms “single function of the trigger,” “automatically,” and “machinegun” as follows:
 
  – “Single function of the trigger” will mean “single pull of the trigger.”
  – “Automatically” will mean “as the result of a self-acting or self-regulating mechanism that allows the firing of multiple rounds through a single pull of the trigger.”
  – The term “machinegun” will include a device that allows semiautomatic firearms to shoot more than one shot with a single pull of the trigger by harnessing the recoil energy of the semiautomatic firearm to which it is affixed so that the trigger resets and continues firing without additional physical manipulation of the trigger by the shooter (commonly known as bump-stock-type devices.
 
This proposed rulemaking is in response to the shootings that occurred on October 1, 2017 in Las Vegas, in which the shooter used a bump-fire stock that ATF had classified previously as NOT being a machinegun. Consequently, this rulemaking, if adopted, will supplant any and all prior letter rulings that are inconsistent so that any bump-stock device that allows continuous firing without additional physical manipulation of the trigger by the shooter will qualify as a machinegun. Further, if the final rule is adopted as proposed, current possessors of bump-stock devices will be obligated to dispose of those devices. This is because of the strict prohibitions the Gun Control Act imposes on the possession and transfer of machineguns manufactured after May 19, 1986 (see 18 U.S.C. Sec. 922(o)). However, it is important to remember the NPRM is only a proposed rule, and ATF is requesting comments from the public on how to address bump-stock-type devices that private parties currently possess (see below). Parties potentially affected by this rule should review the NPRM and provide comments by the deadline, which will be 90 days after the NPRM is published in the Federal Register. At this date, we do not know what the deadline will be for comments because the NPRM has not yet been posted officially on the Federal Register’s website for public inspection. We will follow up with another alert once the NPRM is officially published.
 
Past ATF Classifications of Bump-Stock-Type Devices
 
In 2002, the Akins Group submitted to ATF for classification its newest product, the Akins Accelorator, a rifle stock designed to be used with a semiautomatic rifle that allowed the continuous firing with a single pull of the trigger. When the shooter pulled the trigger, springs in the Akins Accelorator caused the firearm to cycle back and forth with each shot so that the trigger finger remains in a constant pull, allowing continuous firing without further action by the shooter until the shooter takes his or her finger off the trigger or the magazine is emptied. ATF initially classified the Akins Accelerator as not a machinegun because the agency interpreted “single function of the trigger” to mean a single movement of the trigger itself as opposed to a single pull by the shooter.
 
In 2006, ATF reviewed the Akins Accelerator again, but this time determined the device to be a machinegun because “the best interpretation of the phrase “single function of the trigger” was a “single pull of the trigger.” NPRM at 10. Subsequently, ATF issued Rul. 2006-2, “Classification of Devices Exclusively Designed to Increase the Rate of Fire of a Semiautomatic Firearm.” In it, ATF determined the definition of “machinegun” “includes a part or parts designed and intended for use in converting a weapon into a machinegun, and includes a device that, when activated by a single pull of the trigger, initiates an automatic firing cycle that continues until the finger is released or the ammunition supply is exhausted.”
 
However, between 2008 and 2017, ATF issued ten private letter rulings that classified bump-stock devices as NOT machineguns. Why? According to ATF, these bump-stock devices were distinguished from the Akins Accelerator, either because they did not initiate automatic firing that continued until the finger is released, or because they lacked automatically functioning mechanical parts or springs and performed no mechanical function when installed. In all cases, according to ATF, the agency applied a different understanding of the term “automatically.”
 
In response to the Las Vegas mass shooting and the political demand for ATF to ban bump stocks, ATF reviewed these classification determinations “to reconsider and rectify potential classification errors.” (NPRM at 16). Now, in the wake of the Advance Notice ATF published on December 26, 2017 (please refer to our alert of December 21, 2017) and a memorandum from President Trump to Attorney General Sessions, dated February 20, 2018, concerning bump fire stocks and similar devices, ATF will publish in the coming days an the NPRM to clarify that bump-stock-type devices are machineguns subject to all prohibitions of the National Firearms Act and Gun Control Act.
 
ATF Request for Comments
 
The NPRM lists the following topics on which ATF is requesting comments:
  (1) the scope of the proposed rule and the definition of “machinegun;”
  (2) the costs and benefits of the proposed rule and the appropriate methodology and data for calculating those costs;
  (3) the reasonableness of the assumption that retailers of bum-stock-type devices are likely to be businesses with an online presence;
  (4) how ATF should address bump-stock-type devices that private parties currently possess; and
  (5) the appropriate means of implementing a final rule.
 
Please note that ATF will not accept comments on the NPRM until it is officially posted on the Federal Register website for public inspection. In fact, DOJ has added the following cautionary language regarding the posted NPRM: “This is the text of the Bump Stock Notice of Proposed Rulemaking (NPRM) as signed by the Attorney General, but the official version of the NPRM will be as it is published in the Federal Register.”
 
We will follow up with another alert once an official version of this NPRM is published.

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

(Source: Authors, 23 Mar 2018.)
 

* Authors: Marshall V. Miller, Esq.,
mmiller@millerco.com; Sean T. Murray, Esq.,
smurray@millerco.com; and Brian J. Murphy, Esq.,
bmurphy@millerco.com.  All of Miller & Company P.C.
 
Late Thursday night the White House issued two new Presidential Proclamations and a Briefings statement significantly changing the previous White House documentation that we provided to you on this subject.  Additionally, just before midnight, CBP Headquarters issued a CSMS message providing details for the Customs entry process.  Below are links to the White House documents.   The full text of CSMS message 18-000240 is included here.
 
GENERAL IMPORTS
 
President Trump authorized the “suspension” of the additional 25%/10% tariffs for steel/aluminum from Canada, Mexico, the European Union (Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the United Kingdom), South Korea, Australia, Argentina, and Brazil.  Also new is a short period for the “suspension” to only May 1, 2018.  The White House documents make it clear that full Customs duties will be imposed when the “suspension” expires, unless it has been extended by the White House.  The Proclamations indicate that the President retains authority to further modify tariffs, remove suspensions for countries, exclude on a long-term basis a particular country, suspend tariffs on countries not included in the original list, or impose quotas on imports from “suspension” countries.  The potential imposition of quotas (either absolute or tariff rate quotas like those imposed in January on washing machines and solar panels) would be based upon the total volume of imports since January 1, 2018.  The wide variety of potential changes to the steel/aluminum additional tariffs and the potential for quota imposition creates an entirely new framework of potential import management concerns and excessive duty rates.
 
VERIFICATION OF HTS CLASSIFICATONS
 
We strongly encourage clients to review their HTS list Item Master against the steel and aluminum Annexes, and also confirm that the HTSs currently being declared are correct.  This review should include steel and aluminum parts currently classified within the Proclamations and Annexes list and in “parts of” tariff classifications to ensure they are correctly classified as such.  CBP will be very carefully checking HTSs on Customs entries for accuracy.
 
FOREIGN-TRADE ZONE MANAGEMENT
 
The Presidential Proclamations provide direction on FTZs that was missing from the original Proclamations.  All merchandise subject to these new Customs duties of 25% on steel and 10% on aluminum must be placed in Privileged Foreign (PF) status upon admission to an FTZ.  This is the exact same language that was used in January for washing machines and solar panels and previously used in 2002 in a similar Presidential Proclamation for steel/aluminum products.
 
What is very different about the Proclamations is additional language concerning on-hand merchandise in zone status with Privileged Foreign status.  It directs application of the additional duties (retroactively) to all such PF merchandise.  To the best of our knowledge, no Presidential Proclamation previously has ever indicated that merchandise that was on hand in Foreign-Trade Zones in PF Status at the time of the imposition of additional duties would be subject to those additional duties on the date that Customs entry is made. This language in the Presidential Proclamations and CBP CSMS message negates the clear terms of the Foreign-Trade Zones Act §81c that indicates that when PF status is secured the entry is liquidated at the rate of duties in effect on the date the Privilege is requested.  Further, the CBP ACE computer system requires a date to be placed by line item so as to validate when PF status is filed on the CBPF e-214 at admission or subsequent election while in the zone prior to any manipulation or manufacture.   Numerous historical CBP Headquarters Rulings support our legal analysis of this question.
 
Any clients with steel or aluminum products in PF status as of the effective time and date of the Proclamations (12:01 am today, March 23) should contact us immediately.
 
EXCLUSION PROCESS
 
As we previously noted this week, there is an exclusion process that is provided for in the Federal Register published Monday. Given the very unusual nature of the circumstances with respect to “suspension,” and the variety of potential changes explained herein, we advise all clients affected to immediately seek exclusions for their product.  We have several clients that have already authorized us to immediately proceed with the exclusions process in light of these Presidential Proclamations and CSMS message.  
 

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COMM_a3
9. S.G. Alfonso: “GDPR for the E.U. is Coming 25 May 2018”
(Source: Author, 26 Mar 2018.)
 
* Author: S. George Alfonso, Esq., Braumiller Law Group, SGeorge@BraumillerLaw.com, +1 214-878-2390.
 
Who’s afraid of the Big Bad GDPR?
 
The General Data Protection Regulation (GDPR) is the new set of voluminous regulations that will become the controlling law for privacy protection of individuals in the European Union (EU) as of May 25, 2018 – No ifs, ands, or buts, and NO Exceptions (No Grace Period).

The GDPR: What you don’t know can hurt you!

If you think this soon to-be instituted voluminous set of confusing and ill-defined EU regulations won’t affect your company’s exposure to massive liability? THINK AGAIN…

To what entities does the GDPR regulate?

GDPR applies to companies – both in and beyond the EU – which meet one or more of the following (“Coverage Definition”):

  – Company offers goods OR services to individuals in the EU;
  – Company monitors individuals’ behavior;
  – Company processes personal data of EU individuals on behalf of other businesses.

What is the extent of the jurisdictional reach of the GDPR? 
 
The GDPR asserts jurisdiction over any company – anywhere in the world which satisfies the above-stated Coverage Definition – whether or not that company has any business presence or representative in the EU whatsoever.
 
What is the potential liability under the GDPR?

The Maximum Fine/Penalty: The GREATER Of €20M OR 4% of the Gross of the annual revenue of the Parent Company – PER VIOLATION.
 
What can our company do to protect ourselves from the extraordinary risks of a potentially massive liability under the GDPR?

You may choose to retain international counsel to provide the representation needed, in order to prepare, assemble, and draft your Company’s unique “GDPR Global Protocol” for Compliance before the deadline of May 25, 2018.
 
See the attached PPT presentation by clicking on the link below – GDPR-Building the Model for Compliance” by S. George Alfonso, which was recently presented at a conference produced and sponsored by the U.S. Department of Commerce, U.S. and Foreign Commercial Service, E.U. Office, and U.S. Commercial Service Dallas-Ft. Worth, TX.
 
  – Presentation
.

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

COMM_a4
10. Gary Stanley’s EC Tip of the Day
(Source: Defense and Export-Import Update; [DATE]. Available by subscription from
gstanley@glstrade.com
.)
 
* Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059,
gstanley@glstrade.com
.
 
There is no 
de minimis level for foreign made items that incorporate U.S.-origin 9×515 or “600 series” items enumerated or otherwise described in paragraphs .a through .x of a 9×515 or “600 series” ECCN when destined for a country listed in Country Group D:5 of Supplement No. 1.

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

MSEX/IM MOVERS & SHAKERS

MS_a211. Monday List of Ex/Im Job Openings; 158 Jobs Posted This Week, Including 10 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 (
10 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

#
Curtiss-Wright Corporation; Los Angeles, CA;
Director, Trade Compliance
;

* 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;
# DSJ Global; Minneapolis, MN; Director of International Logistics;
*
 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
# Eaton; Mississagua, Canada; Global Trade & Compliance Manager;

* 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; 
Clerk import / export
 ;
*
 Expeditors; Bedfont, United Kingdom;
Customs Brokerage Clerk
;
*
 Expeditors; Birmingham, UK;
Customs Brokerage Agent
;

*
 Expeditors; Dusseldorf, Germany;
Clerk airfreight 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; Nashua, NH; 
Global Trade Compliance Analyst,Traffic
;
*
 FLIR; Elkridge, MD; 
Global Trade Compliance Analyst,Traffic
;

*
 FLIR; Billerica, MA;
Global Trade Compliance Analyst, Licensing
;
*
 FLIR; Arlington, VA;
Senior Analyst, Licensing
*
 FLIR; Billerica, MA;
Senior Analyst, Licensing
;
* Floor and Decor; Smyrna, GA; Customs Compliance Manager;
* 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 

* General Dynamics; Fairfax, VA; Export Policy Analyst; Job ID: 2018-36089 
* General Dynamics; Arlington, VA; Analyst, Export Control; Job ID: 2018-36963

#
 General Dynamics; Falls Church, VA;
Director, Trade Control
; Job ID: 2018-1122

* General Motors; Pontiac, MI; 
GM Defense Sub Export Compliance Officer
 (Full Time or Flex time)
; Requisition ID: GPS0003372
*
 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
# H.B. Fuller; St. Paul, MN; Global Trade Compliance Director;
* 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
# Northrop Grumman; El Segundo, CA; Supply Chain Logistics Spec 3; Requisition ID: 18004948

* 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

# PwC; Portland, OR; Compliance Senior Manager;
#
 Raytheon Company; Doha, Qatar;
Global Trade Compliance Consulting Analyst
; Requisition ID: 110234BR

* 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 

* REDCOM Laboratories; Victor NY;  
Director of Trade Compliance
; Contact 
Chad Boehly 

*
 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 Specialist
; 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 

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

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

* T
hermo 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;

* United Technologies Corp, Pratt & Whitney; East Hartford, CT;
International Trade Compliance Technology Manager
; Requisition ID: 51863BR

#
 United Technologies Corp, Pratt & Whitney; East Hartford, CT;
ITC & ACE Compliance Program Manager, ASC
; Requisition ID: 58388BR

* 
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
;

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

TEEX/IM TRAINING EVENTS & CONFERENCES

* What: United States Export Controls (ITAR/EAR/OFAC) Seminar Series in San Diego, CA
* When: ITAR Seminar: June 4-5, 2018; EAR/OFAC Seminar: June 6-7, 2018
* Where: San Diego, CA: Doubletree Hotel San Diego Downtown
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel: John Black, Scott Gearity, Greg Creeser, Marc Binder, and Melissa Proctor
* Register: Here, or Jessica Lemon, 540-433-3977, jessica@learnexportcompliance.com
* * * * * * * * * * * * * * * * * * * *

ENEDITOR’S NOTES

 
Arturo Toscanini (25 Mar 1867 – 16 Jan 1957; was an Italian conductor. He was one of the most acclaimed musicians of the late 19th and of the 20th century, renowned for his intensity, his perfectionism, his ear for orchestral detail and sonority, and his eidetic memory and perfect pitch. He was at various times the music director of La Scala in Milan, the Metropolitan Opera in New York, and the New York Philharmonic.
  – “Can’t you read? The score demands ‘con amore’, and what are you doing? You are playing it like married men!”
 
Robert Frost (26 Mar 1874 – 29 Jan 1963; was an American poet. Known for his realistic depictions of rural life and his command of American colloquial speech, Frost frequently wrote about settings from rural life in New England in the early twentieth century, using them to examine complex social and philosophical themes. Frost was honored frequently during his lifetime, receiving four Pulitzer Prizes for Poetry. He became one of America’s rare “public literary figures, almost an artistic institution.”
  – “By working faithfully eight hours a day you may eventually get to be boss and work twelve hours a day.”
  – “Don’t ever take a fence down until you know why it was put up.”
 
Monday is Punday:
 
* A sign in a shoe repair store in Vancouver reads: 
  “We will heel you; We will save your sole; We will even dye for you.”

* Sign in a Podiatrist’s office:  
  “Time wounds all heels.”
 
* Sign on a Maternity Room door: 
  “Push. Push. Push.”

* Sign at a Car Dealership:
  “The best way to get back on your feet: Miss a car payment.”

* Name of a Hair Solon:
   “Curl Up & Dye”

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

EN_a314
. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  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: 22 Mar 2018: 83 FR 12475-12483: Addition of Certain Persons to the Entity List and Removal of Certain Persons from the Entity List; Correction of License Requirements  

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

  – Last Amendment: 19 Mar 2018:
83 FR 11876-11881: Inflation Adjustment of Civil Monetary Penalties 

 
*
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 (16 March 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 approximately 250 footnotes containing case annotations, practice tips, Census/AES guidance, and explanations of the numerous errors contained in the official text. Subscribers receive revised copies in Microsoft Word every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance websiteBITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR. Government employees (including military) and employees of universities are eligible for a 50% discount on both publications at www.FullCircleCompiance.eu.  
 
*
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: 14 Mar 2018: Harmonized System Update 1803, containing 449 ABI records and 92 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_a0315
Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

Review last week’s top Ex/Im stories in “Weekly Highlights of the Daily Bugle Top Stories” published 
here

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

EPEDITORIAL POLICY

* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, John Bartlett. The Ex/Im Daily Update is emailed every business day to approximately 8,000 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, 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.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

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