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18-0507 Monday “Daily Bugle”

18-0507 Monday “Daily Bugle”

Monday, 7 May 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. President Adjusts Imports of Aluminum into the U.S. 
  2. President Adjusts Imports of Steel into the U.S. 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC Posts Name and Address Change Web Notices
  4. State/DDTC Updates Decision Tools
  5. Dutch Government Posts FAQs Concerning Export Controls
  1. The Hill: “House Defense Bill Would Stop Weapons Sales to Turkey, Pending Report”
  2. South China Morning Post: “ZTE Seeks Stay of U.S. Ban, Asks Employees to ‘Welcome Coming of Dawn'”
  3. The Washington Post: “Behind Erik Prince’s China Venture”
  1. H.C. Choate, L. Muranovic & K.T. Scarlott: “U.S. Sanctions Under the Trump Administration”
  2. International Trade Compliance Update: “New Zealand – New Customs and Excise Act”
  3. T. Murphy: “Section 232 Update”
  1. Monday List of Ex/Im Job Openings: 207 Jobs Posted This Week, Including 21 New Jobs
  1. FCC Presents “Summer Course U.S. Export Controls: An Introduction to the ITAR & EAR”, 12 Jun in Bruchem, the Netherlands
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: ATF (15 Jan 2016), Customs (12 Apr 2018), DOD/NISPOM (18 May 2016), EAR (5 Apr 2018), FACR/OFAC (19 Mar 2018), FTR (24 Apr 2018), HTSUS (4 May 2018), ITAR (14 Feb 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. 
President Adjusts Imports of Aluminum into the U.S.

(Source: 
Federal Register, 7 May 2018.) [Excerpts.]  
 
Adjusting Imports of Aluminum into the United States
 
A Proclamation … 
 
NOW, THEREFORE, I, DONALD J. TRUMP, President of the United States of America, by the authority vested in me by the Constitution and the laws of the United States of America, including section 232 of the Trade Expansion Act of 1962, as amended, section 301 of title 3, United States Code, and section 604 of the Trade Act of 1974, as amended, do hereby proclaim as follows:
 
  (1) Imports of all aluminum articles from Argentina, Australia, and Brazil shall be exempt from the duty established in clause 2 of Proclamation 9704, as amended by clause 1 of Proclamation 9710. Imports of all aluminum articles from Canada, Mexico, and the member countries of the EU shall be exempt from the duty established in clause 2 of Proclamation 9704 until 12:01 a.m. eastern daylight time on June 1, 2018.  . . .
  (2) The exemption afforded to aluminum articles from Canada, Mexico, and the member countries of the EU shall apply only to aluminum articles of such countries entered for consumption, or withdrawn from warehouse for consumption, through the close of May 31, 2018, at which time such countries shall be deleted from the article description of heading 9903.85.01 of the HTSUS.
  (3) Clause 5 of Proclamation 9710 is amended by inserting the phrase “, except those eligible for admission under “domestic status” as defined in 19 CFR 146.43, which is subject to the duty imposed pursuant to Proclamation 9704, as amended by Proclamation 9710,” after the words “Any aluminum article” in the first and second sentences.
  (4) Aluminum articles shall not be subject upon entry for consumption to the duty established in clause 2 of Proclamation 9704, as amended by clause 1 of this proclamation, merely by reason of manufacture in a U.S. foreign trade zone. However, aluminum articles admitted to a U.S. foreign trade zone in “privileged foreign status” pursuant to clause 5 of Proclamation 9710, as amended by clause 3 of this proclamation, shall retain that status consistent with 19 CFR 146.41(e).
  (5) No drawback shall be available with respect to the duties imposed on any aluminum article pursuant to Proclamation 9704, as amended by clause 1 of this proclamation.
  (6) The Secretary, in consultation with U.S. Customs and Border Protection of the Department of Homeland Security and other relevant executive departments and agencies, shall revise the HTSUS so that it conforms to the amendments and effective dates directed in this proclamation. The Secretary shall publish any such modification to the HTSUS in the Federal Register.
  (7) Any provision of previous proclamations and Executive Orders that is inconsistent with the actions taken in this proclamation is superseded to the extent of such inconsistency.
 
IN WITNESS WHEREOF, I have hereunto set my hand this thirtieth day of April, in the year of our Lord two thousand eighteen, and of the Independence of the United States of America the two hundred and forty-second.
 
  [Presidential Signature.]
 
[
Annex to proclamation.]

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EXIM_a2

2. 
President Adjusts Imports of Steel into the U.S.

(Source: 
Federal Register, 7 May 2018.) [Excerpts.] 
 
Adjusting Imports of Steel into the United States
 
A Proclamation … 
 
 NOW, THEREFORE, I, DONALD J. TRUMP, President of the United States of America, by the authority vested in me by the Constitution and the laws of the United States of America, including section 232 of the Trade Expansion Act of 1962, as amended, section 301 of title 3, United States Code, and section 604 of the Trade Act of 1974, as amended, do hereby proclaim as follows:
 
  (1) Imports of all steel articles from Argentina, Australia, Brazil, and South Korea shall be exempt from the duty established in clause 2 of Proclamation 9705, as amended by clause 1 of Proclamation 9711. Imports of all steel articles from Canada, Mexico, and the member countries of the EU shall be exempt from the duty established in clause 2 of Proclamation 9705 until 12:01 a.m. eastern daylight time on June 1, 2018.  . . .
  (2) In order to provide the quota treatment referred to in paragraph 4 of this proclamation to steel articles imports from South Korea, U.S. Note 16 of subchapter III of chapter 99 of the HTSUS is amended as provided for in Part A of the Annex to this proclamation. U.S. Customs and Border Protection (CBP) of the Department of Homeland Security shall implement this quota as soon as practicable, taking into account all steel articles imports from South Korea since January 1, 2018.
  (3) The exemption afforded to steel articles from Canada, Mexico, and the member countries of the EU shall apply only to steel articles of such countries entered for consumption, or withdrawn from warehouse for consumption, through the close of May 31, 2018, at which time such countries shall be deleted from the article description of heading 9903.80.01 of the HTSUS.
  (4) Clause 5 of Proclamation 9711 is amended by inserting the phrase “, except those eligible for admission under “domestic status” as defined in 19 CFR 146.43, which is subject to the duty imposed pursuant to Proclamation 9705, as amended by Proclamation 9711,” after the words “Any steel article” in the first and second sentences.
  (5) Steel articles shall not be subject upon entry for consumption to the duty established in clause 2 of Proclamation 9705, as amended by clause 1 of this proclamation, merely by reason of manufacture in a U.S. foreign trade zone. However, steel articles admitted to a U.S. foreign trade zone in “privileged foreign status” pursuant to clause 5 of Proclamation 9711, as amended by clause 4 of this proclamation, shall retain that status consistent with 19 CFR 146.41(e).
  (6) No drawback shall be available with respect to the duties imposed on any steel article pursuant to Proclamation 9705, as amended by clause 1 of this proclamation. 
  (7) The Secretary, in consultation with CBP and other relevant executive departments and agencies, shall revise the HTSUS so that it conforms to the amendments and effective dates directed in this proclamation. The Secretary shall publish any such modification to the HTSUS in the 
Federal Register.
  (8) Any provision of previous proclamations and Executive Orders that is inconsistent with the actions taken in this proclamation is superseded to the extent of such inconsistency.
 
IN WITNESS WHEREOF, I have hereunto set my hand this thirtieth day of April, in the year of our Lord two thousand eighteen, and of the Independence of the United States of America the two hundred and forty-second.
 
  [Presidential Signature.]
 

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OGSOTHER GOVERNMENT SOURCES

OGS_a13. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* President; ADMINISTRATIVE ORDERS; Defense and National Security: 
  – Matiere d’Armement, Organisation Conjointe de Cooperation en; Eligibility to Receive Defense Articles and Services (Presidential Determination No. 2018-05 of April 20, 2018);
  – Great Britain and Northern Ireland; Proposed Agreement for Cooperation with U.S. for Peaceful Uses of Nuclear Energy (Presidential Determination No. 2018-07 of April 30, 2018); and
  – Mexico; Proposed Agreement for Cooperation with U.S. for Peaceful Uses of Nuclear Energy (Presidential Determination No. 2018-06 of April 30, 2018) [Publication Dates: 8 May 2018.]

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

(Source: 
Commerce/BIS
)

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

(Source: 
State/DDTC, 7 May 2018.)
 
  – Airbus DS Electronics and Border Security SAS name change 
web notice
  – Fokker Engineering Romania address change 
web notice
  – Goodrich Actuation Systems SAS address change 
web notice

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

(Source: 
State/DDTC, 7 May 2018.) 
 
DDTC provides exporters the following updated decision tools:
 
 
N.B. The first two tools are effective for exports on or after October 15, 2013. 

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

 
Ten frequently asked questions and answers on Export controls on strategic goods and services: 
 

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NWSNEWS

NWS_a18

The Hill: “House Defense Bill Would Stop Weapons Sales to Turkey, Pending Report”

(Source: 
The Hill, 4 May 2018.) [Excerpts.] 
 
The House wants to hold off on U.S. weapons sales to NATO ally Turkey until a report is created to analyze worsening tensions between Washington and Ankara.
 
The provision in the House version of the annual defense policy bill would require the Pentagon to provide Congress a report “on the impact that increasing strains on the U.S.-Turkey relationship, caused by provocative actions taken by the Turkish government over the past year, will have on all U.S. military and diplomatic activities currently conducted in Turkey.”
 
The Pentagon would be prohibited from executing “the delivery of a foreign military sale for major defense equipment under Section 36 of the Arms Export Control Act to Turkey, until the report is complete,” according to the language, included in a minority summary of the National Defense Authorization Act (NDAA) released Friday. … 
 
They added that lawmakers are trying to work with the Defense Department to figure out where the countries’ relationship is headed as Washington is poised to hand over more than 100 F-35 Lightning II fighters to Turkey.
 
Under the U.S.-led, multinational Joint Strike Fighter program, Turkey has committed to buy 116 of the F-35A variant.
 
The provision in the House bill is in addition to a 
separate Senate bill introduced last month, which would block Turkey from receiving F-35 fighters over the imprisonment of an American pastor, Andrew Brunson.
 
The committee aid said the House is aware of the Senate bill, but the House NDAA does not specifically target any one purchase.   
“It aims at major defense equipment as it relates to the arms export control act,” they said. … 

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NWS_a29

South China Morning Post: “ZTE Seeks Stay of U.S. Ban, Asks Employees to ‘Welcome the Coming of Dawn'” 

(Source: 
South China Morning Post, 5 May 2018.) 
 
ZTE Corp, facing a seven-year ban on buying crucial American technology, said it has requested a stay of the denial order that forbade U.S. companies from doing business with the Chinese telecommunications equipment provider, asking its employees to be “full of hope to welcome the coming of dawn”.
 
The Shenzhen-based telecommunications equipment provider has been “proactively communicating with relevant departments of the US government”, ZTE said in an internal memo to employees on Friday seen by the South China Morning Post. The company is striving to resolve the matter “as soon as possible” and will continue to maintain close communication with relevant parties, the memo said. 
 
The company has also submitted supplementary documents in according with guidance from the US Department of Commerce’s Bureau of Industry and Security (BIS), according to the memo, which was sent by the Emergency Response Team set up by the company to deal with the fallout from the ban.
 
ZTE declined to comment on the memo.
 
The memo was sent after senior officials from China and the US concluded their first round of trade talks in Beijing on Friday with no breakthrough, agreeing only to have more dialogue to ease tensions. A short statement released by state-run Xinhua said both sides were still “very divided” on some issues and “more work needed to be done”. Trade tensions have been rising between the world’s two biggest economies as US President Donald Trump sought to reduce China’s trade deficit with the US. 
 
The two sides “reached some consensus” and exchanged views on expanding US exports to China, bilateral investment, intellectual property protection and the imposition of tariffs, the statement said, without elaborating. A statement from the White House said the US delegation held “frank discussions” with Chinese officials on rebalancing the bilateral economic relationship. 
 
China’s Ministry of Commerce said in a statement earlier on Friday that Chinese officials had made “solemn representations” over the ZTE case to the US delegation. 
 
In its memo, ZTE said that after learning of the US order on April 16, as a global company growing up in China, it has been acting in line with the government of China, and is taking steps under its guidance to facilitate the resolution of the issue.
 
The company reiterated that it will strive to resolve the export ban through dialogue and safeguard its legal rights and interests.
 
After learning of the denial order, ZTE immediately delivered a compliance code of conduct to all employees, and the company has suspended all business activities with US partners as required under the order, according to the memo.
 
ZTE last month criticized the decision by the US to impose the export order as “extremely unfair”. The US government had banned sales by American hi-tech suppliers to ZTE because the Chinese firm failed to discipline 35 employees involved in the illegal sale of telecommunications equipment to Iran, paid them full bonuses and lied about it to US authorities.
 
ZTE chairman Yin Yimin said last month the US export ban has put the company “in a state of shock” as it would damage the interests of the firms’ employees and shareholders, as well as telecommunications network operators and smartphone users around the world.
 
The company has “reflected on its activities, learned the lesson and strengthened compliance and internal controls,” according to the memo, which ended with an exhortation to the company’s 80,000 employees.
 
  “However long the road, there is an end point, however long the night, there will be a conclusion, let us be steadfast and be full of hope to welcome the coming of dawn,” the memo said.

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NWS_a3
10
The Washington Post: “Behind Erik Prince’s China Venture”

(Source: 
The Washington Post, 4 May 2018.) [Excerpts.] 
 
The Blackwater founder has cut a lucrative security-training deal with Chinese insiders. But is it against U.S. interests?
 
Beijing’s International Security Defense College, which boasts of becoming “the 
largest private security training school in China,” sits behind a 45-foot-high exterior wall and a barricade. Inside the compound, trainers with police and military experience teach classes on tackling detainees, handling hostage situations and thwarting terrorist attacks.
 
The school is overseen by Frontier Services Group, a Hong Kong-based company founded by Erik Prince, a former Navy SEAL who created Blackwater, a security firm that played a major and controversial role in the U.S. wars in Iraq and Afghanistan. … 
 
The school’s promotional materials boast that Frontier has trained more than 5,000 Chinese military personnel, 200 plainclothes police officers, 500 SWAT specialists, 200 railway police officers and 300 overseas military police officers. A slogan painted on the school’s wall reads, “Training ground for warriors.” …
 
According to internal Frontier documents, executives were concerned that the company might be skirting U.S. law – known as International Traffic in Arms Regulations (ITAR) – requiring Americans to obtain special permits before defense-related technology can be transferred to foreign countries. … 

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COMMCOMMENTARY

COMM_a0
11. 
H.C. Choate, L. Muranovic & K.T. Scarlott: “U.S. Sanctions Under the Trump Administration”

(Source: 
Baker & Hostetler LLP, 2 May 2018.)
 
* Authors: Hannah C. Choate, Esq., 
hchoate@bakerlaw.com; Lana Muranovic, Esq., 
lmuranovic@bakerlaw.com; and Kerry T. Scarlott, Esq., 
kscarlott@bakerlaw.com.  All of Baker & Hostetler LLP.
 
The Trump Administration has been active on the sanctions front as a means of asserting U.S. foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late, beyond its typical deference to the executive branch. BakerHostetler’s international trade team is pleased to provide the following report on the current state of sanctions. Please note that U.S. sanction programs are in near-constant flux, particularly given today’s geopolitical environment.
 
The United States currently imposes broad trade sanctions on Cuba, Iran, North Korea, Syria, and Crimea, and has only recently lifted sanctions against Sudan. Sanctions targeting specific sectors or economic activities are also imposed on a number of additional countries, including recently revamped sanctions programs targeting Russia and Venezuela. Sanctions programs administered by the Treasury Department’s Office of Foreign Assets Control (OFAC) apply to U.S. persons wherever located and to non-U.S. persons located in the United States. They also generally prohibit facilitation by a U.S. person of a transaction by a foreign person that would be prohibited if performed by a U.S. person or within the United States.
 
Under the Trump Administration, OFAC has also been active in issuing new Specially Designated Nationals and Blocked Persons (SDN) designations. SDNs are individuals and organizations owned or controlled by, or acting on behalf of, targeted countries, as well as other individuals, groups and entities that are designated under sanctions programs that are not country-specific. The first quarter of 2018 has seen newly designated SDNs in connection with the Russia, Syria, Venezuela, North Korea, Democratic Republic of the Congo and Iran sanctions programs, in addition to a number of designations under sanctions programs that are not country-specific, including those targeting terrorism and drug trafficking. U.S. persons are generally prohibited from dealing with SDNs, and SDNs’ assets are subject to blocking.
 
Cuba
 
In July 2017, the Trump Administration announced the reinstatement of certain restrictions on U.S. travel and financial transactions with Cuba. This followed a significant rollback of Cuba sanctions under the Obama Administration. Financial transactions involving Cuban military, intelligence and security service entities are prohibited. The Trump Administration also imposed a ban on individual people-to-people and educational travel to Cuba. However, regulations enacted by the Obama Administration related to group travel, diplomatic relations, family visits and remittances remain in effect. On Nov. 8, 2017, various U.S. federal agencies, including OFAC, the U.S. Commerce Department’s Bureau of Industry and Security (BIS), and the State Department, took steps to implement these regulatory changes, which formally took effect on Nov. 9, 2017. Apart from some exceptions, including humanitarian donations and certain agricultural commodities, BIS still requires a license for all exports of items subject to the Export Administration Regulations (EAR) to Cuba.
 
Iran
 
Despite equivocations from the Trump Administration, the Joint Comprehensive Plan of Action (JCPOA), which permits a limited number of transactions with Iran that were previously prohibited, remains in effect. Regulations implemented under the JCPOA allow foreign subsidiaries of U.S. companies to conduct transactions with Iran, subject to restrictions. However, the U.S. parent company may not facilitate its foreign subsidiary’s transactions with Iran, and foreign subsidiaries of U.S. companies may not re-export most U.S. items to Iran. 
 
During the summer of 2017, U.S. Congress took its own action to direct the Trump Administration to impose specific sanctions on Iran, North Korea and Russia by passing the Countering America’s Adversaries Through Sanctions Act (commonly referred to as the CAATS Act), which President Trump signed into law on Aug. 2. With respect to Iran, the CAATS Act directs the President to impose sanctions against (1) Iran’s ballistic missile and weapons of mass destruction programs; (2) the sale or transfer to Iran of military equipment or the provision of related technical or financial assistance; and (3) Iran’s Islamic Revolutionary Guard Corps and affiliated foreign persons. In addition, the President is authorized to impose sanctions against persons responsible for gross human rights violations against any individuals supporting internationally recognized human rights and freedoms or any persons exposing illegal activities of the Iranian government. Accordingly, on Jan. 12, OFAC designated individuals and entities in connection with human rights abuses and censorship in Iran and with those who provide support to designated Iranian weapons proliferators.
 
North Korea
 
Nearly all transactions by U.S. persons with North Korea remain prohibited under OFAC regulations. Prohibited transactions include the import of any North Korean goods, export of any goods or services to North Korea, and any new investment in North Korea.
 
The CAATS Act, first noted above in connection with Iran sanctions, modifies and increases the President’s authority to impose sanctions on persons in violation of certain United Nations Security Council resolutions regarding North Korea. It prohibits U.S. financial institutions from establishing or maintaining correspondent accounts used by foreign financial institutions to provide indirect financial services to North Korea. A foreign government that provides to or receives from North Korea a defense article or service is prohibited from receiving certain types of U.S. foreign assistance. In addition, the Act provides sanctions against (1) North Korean cargo and shipping; (2) goods produced in whole or in part by North Korean convicts or forced labor; (3) and foreign persons who employ North Korean forced laborers.
 
On Sept. 20, 2017, President Trump issued Executive Order 13810, which establishes several designation criteria for additional sanctions, including against persons who (1) operate in the North Korean construction, energy, financial services, fishing, information technology, manufacturing, medical, mining, textiles and transportation industries; (2) have engaged in a significant importation from or exportation to North Korea; (3) are a North Korean person; or (4) have materially assisted, sponsored or supported (including financially or technologically) any person whose property is blocked pursuant to the Executive Order. The Executive Order also (1) prohibits vessels and aircraft that have called or landed at a port or place in North Korea in the previous 180 days, and vessels that engaged in ship-to-ship transfer with such a vessel in the previous 180 days, from entering the United States; (2) provides authority to block any funds transiting accounts linked to North Korea that come within the United States or possession of a U.S. person; and (3) authorizes the imposition of sanctions on a foreign financial institution that knowingly conducted or facilitated, on or after the date of the Order, any significant transaction on behalf of certain blocked persons or any transaction in connection with trade with North Korea. OFAC issued General License 10 to provide for limited exceptions to the above prohibitions. Subsequently, OFAC designated a variety of additional North Korean banks, individuals and vessels as sanctioned parties. OFAC also issued an advisory alerting of deceptive shipping practices used by North Korea to evade sanctions, and designated as SDNs a number of companies located in North Korea, China, Singapore and Panama in connection with such practices. On March 1, 2018, OFAC reissued an amended and updated version of the North Korean sanctions regulations.
 
Syria
 
Nearly all transactions by U.S. persons with Syria are prohibited under OFAC regulations. Prohibited transactions include the import of any Syrian goods, export of any goods or services to Syria, dealing in petroleum products of Syrian origin, and any new investment in Syria. Very narrow exceptions to these prohibitions include services incident to internet-based communications, personal remittances, and certain services in support of nongovernmental organizations’ activities.
 
Sudan
 
Effective Oct. 12, 2017, OFAC lifted its remaining economic sanctions against Sudan in response to Sudan’s human rights improvements and progress related to counterterrorism. Although this action effectively suspends the U.S. trade embargo against Sudan, unfreezes Sudanese assets and removes all financial restrictions against Sudan, it does not terminate the national emergency with respect to Sudan and does not affect any sanctions related to the conflict in Darfur. OFAC designations of Sudanese persons on the SDN list are also unaffected. U.S. and non-U.S. persons are required to obtain licenses from BIS in order to export or re-export U.S.-origin items identified on the U.S. Commerce Control List, but they may use the newly issued General License A to export and re-export agricultural commodities, medicine and medical devices to Sudan.
 
Crimea
 
The United States maintains a broad sanctions program that bans new investment in and prohibits the exportation or importation of goods, technology or services to or from Crimea.
 
Russia
 
The sectoral sanctions imposed on specified persons operating in the Russian economy during the Obama Administration remain in effect and have been tightened in some instances, as discussed below. Those sectoral sanctions prohibit U.S. persons from engaging in certain transactions with entities subject to the sanctions, as identified on the Sectoral Sanctions Identification List (SSI List). If an entity is listed on the SSI List, the listing designates the directive to which the entity is subject. The four directives restrict different types of financial transactions, including transacting in debt of the designated entity or exporting certain goods or services to the designated entity.
 
On Sept. 29, 2017, in order to implement the CAATS Act first noted above in connection with Iran sanctions, OFAC amended Directives 1 and 2 of the U.S. sectoral sanctions against Russia, effective Nov. 28, to bar U.S. persons from transacting in debt of more than 14 days’ maturity of designated Russian financial services firms or more than 60 days’ maturity of designated Russian energy firms, respectively. Similarly, on Oct. 31, OFAC expanded the scope of Directive 4 of the U.S. sectoral sanctions against Russia so that the provision, export and re-export by a U.S. person or within the United States, directly or indirectly, of goods, services (except for financial services) or technology in support of exploration or production for deepwater, Arctic offshore or shale projects are prohibited for projects initiated on or after Jan. 29 that have the potential to produce oil in any location in which any person designated under Directive 4 has a 33 percent or greater ownership interest or ownership of a majority of the voting interests.
 
Venezuela
 
In Aug. 2017, President Trump signed Executive Order 13808, which imposes sanctions on Venezuela in response to Venezuelan President Nicolas Maduro’s increasingly authoritarian regime. The new sanctions are aimed at restricting the Maduro regime’s access to financial markets and capital, subject to certain limitations intended to reduce the impact on U.S. businesses and the Venezuelan people. The Executive Order prohibits dealings in new debt and equity issued by the Venezuelan government and its state-run oil company, Petroleos de Venezuela S.A., as well as in some existing bonds owned by the public sector. The Order also bans the payment of dividends and other distribution of profits to the Venezuelan government by entities owned or controlled by the Venezuelan government. OFAC published new general licenses that authorize certain transactions that would otherwise be prohibited under Executive Order 13808, including authorization to conduct certain transactions involving CITGO Holdings Inc., the Venezuelan-owned U.S. petroleum company, and dealings in certain bonds.
 
On March 19, President Trump signed Executive Order 13827 in light of actions by the Maduro regime to attempt to circumvent U.S. sanctions by issuing a digital currency. Executive Order 13827 prohibits all transactions, by a U.S. person or within the United States, related to any digital currency or digital token that was issued by, for or on behalf of the government of Venezuela on or after Jan. 9.

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COMM_a01
12
International Trade Compliance Update: “New Zealand – New Customs and Excise Act”

(Source: 
International Trade Compliance Update, 4 May 2018.) [Excerpts.] 
 
The new Customs and Excise Act is due to take effect from 1 October this year. Most of the changes that will occur from the Act were identified by businesses as having the potential to lower their costs and make their lives easier.
 
The new Act:
 
  – updates Customs’ processes so that they are appropriate for the modern business environment and can be adapted as that environment evolves
  – addresses some of the known pain-points generated under the 1996 Act
  – introduces some new services.
 
Implementation
 
An implementation program is underway to ensure that the New Zealand Customs Service (NZCS) is ready to implement the new Act as soon as it comes into effect.
 
The NZCS is working with stakeholders to inform the guidance and information resources to help customers understand the changes, what they mean, and what they may need to do. Regulations and Rules are also being developed to support the implementation of the Act.
 
NZCS developed a brochure for the Customs Brokers and Freight Forwarders (CBAFF) annual conference held in Nelson 2 – 4 May 2018, that you can read online 
here. … 

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COMM_a2
13. 
T. Murphy: “Section 232 Update” 
(Source: Editor, 6 May 2018.) 
 
* Author: Ted Murphy, Esq., 
ted.murphy@bakermckenzie.com, +1 202 452 7000, Baker & McKenzie LLP. 
 
By now, you have probably seen that the President issued two new proclamations regarding the imposition of additional duties on imports of steel (25%) and aluminum (10%) under Section 232 of the Trade Expansion Act of 1962, as amended.  The proclamations do the following:  (1) extend the temporary exemption applicable to imports of covered articles from Argentina, Australia and Brazil while the details associated with permanent exemptions are finalized; (2) extend the temporary exemption applicable to imports of covered articles from Canada, Mexico and the EU through May 30, 2018; (3) address issues related to the application of the additional duties when foreign trade zones are involved; and (4) clarify that “[n]o drawback shall be available” with respect to section 232 duties.  The steel proclamation also finalizes the permanent exemption afforded imports of covered steel articles from South Korea.  Imports of aluminum covered articles from South Korea are not covered by a permanent exemption and are, therefore, subject to the additional 10% duties as of May 1, 2018.  Copies of the April 30th proclamations are attached here for your reference.
 
Since the issuance of the proclamations, it has been reported that the permanent exemption to be afforded Brazil will only apply to steel imports (in exchange for a limit on Brazilian steel exports to the USA) and that aluminum imports will be subject to the additional 10% duty.  It is also been reported that the permanent exemption to be afforded Argentina will cover both steel and aluminum imports (again, in exchange for a limit on Argentine exports to the USA). 
 
In terms of Canada and Mexico, the permanent exemptions appear to be tied to the on-going NAFTA negotiations.  While those negotiations have reportedly made substantial progress in recent weeks, it is not clear whether a deal will be able to be announced in the next couple of weeks.  The Administration has recently expressed concern that if a deal is not reached by May 21, 2018, then any revised agreement would need to be voted on by the next Congress, due to timing issues associated with applicable legal requirements (e.g., the Administration has to provide notice of any deal to Congress, the U.S. International Trade Commission has to do a study of any new deal, etc.).  This is problematic because the next Congress (which will be sworn in in January 2019) will not have had an opportunity to help direct the negotiations (as the current Congress has) and may have a different composition as a result of the elections in October.  As a result, expect the U.S. Administration to put on a full court press to get a deal done (or at least announced) before May 21st.  If that does not happen, then there is an increased chance that the section 232 duties will go into effect for Canada and Mexico June 1, 2018.
 
In terms of the EU, the Administration has made clear that the key to getting a permanent exemption from the section 232 duties is agreeing to an export quota, or other voluntary-export-restraint-type agreement.  The EU, however, has made it clear that it will not agree to any sort of quota or VRA.  It has, however, reportedly offered to enter into negotiations with the United States for a new ‘trade in goods’ free trade agreement.  It will be an interesting few weeks to be sure as these discussions play out.
 
In the meantime, we recommend that any company which imports covered articles from Canada, Mexico or the EU (or relies on covered articles from these countries imported by other U.S. parties) consider preparing product exclusion petitions now.  While exclusions are not needed currently, there is a meaningful chance that such exclusions will be needed in the near future (i.e., June 1st).  Given the delay in the processing of product exclusion petitions, it is important that companies which are impacted be proactive in protecting their interests (e.g., not languishing at the back of a very long line, etc.).

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

MSEX/IM MOVERS & SHAKERS

MS_a214. Monday List of Ex/Im Job Openings; 207 Jobs Posted This Week, Including 21 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

* Abaco Systems, Inc.; Huntsville, AL; Trade Compliance Manager;
# ACCO Brands; Lake Zurich, IL; Foreign Trade Zone Specialist;
* 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

* BAE Systems; Huntsville, AL; Facility Security Officer, Security Manager; Requisition ID: 36821BR
* BAE Systems; Burlington, MA; Facility Security Officer (“FSO”); Requisition ID: 35499BR
* BAE Systems; Sterling Heights, MI; Procurement Compliance Specialist; Requisition ID: 32016BR
* BAE Systems; Rockville, MD; Compliance Specialist Senior; Requisition ID: 35809 BR
* BAE Systems; Sterling, VA; Compliance Specialist Senior; Requisition ID: 36370BR

# Boeing; Zoushan, China;
Trade Compliance Manager;
# Boeing; Rome, Italy;
Trade Control Specialist;
# Boeing; Seattle, WA;
Trade Control Specialist;
# Boeing; Mesa, AR;
Trade Control Specialist;
# Boeing; Ridley Park, PA;  
Trade Control Specialist
;
# Boeing; St. Louis, MO; Arlington, VA; Joint Base Charleston, SC; Oklahoma City, OK, Ridley Park, PA; El Segundo, CA; Seattle, WA; Mesa, AZ; Trade Control Specialist – Mid Career;

*
 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 or Merrimack, NH;
Trade Compliance Manager
; 2018-5916

* Elbit Systems of America; Fort Worth, TX or Merrimack, NH;
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
* Endeavor Robotics; Chelmsford, MA; Logistics and Compliance Analyst;
* 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; US Customs Analyst
;

# FLIR; Meer, Belgium; GTC EMEA Customs Analyst;
# FLIR; Irving, CA; 
Sr. Manager Export Compliance;

*
 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; 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

* Harris Corporation; Roanoke, VA;
Trade Compliance Intern;
* Harris Corporation; Beaverton, OR;
Manager, International Government Relations;

* 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
;

# Henkel Corp.; Rocky Hill, CT;
Global Trade Defense Information Manager; Requisition ID: 
180002QT

# Henkel Corp.; Rocky Hill, CT; Senior Global Trade ManagerRequisition ID: 18000307
* Hexcel Corporation; Dublin, CA or Salt Lake City, UT
; International Trade Compliance Analyst
Requisition ID: R011590

* 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

* Illumina; San Diego, CA; Export 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

* Johns Hopkins University; Baltimore, MD;
Assistant Director, Export Control and Facility Security;

* KEMET Electronics Corporation; Simpsonville, SC; Corporate Compliance Analyst;
* KPMG U.S.; San Francisco, CA; Associate, Trade & Customs;

* Leonardo DRS; Arlington, VA;
Senior Customs & Trade Compliance Manager
; Requisition ID: 87488

* Leonardo DRS; St. Louis;
Trade Compliance Specialist
; Requisition ID: 88127, or contact 
brandy.mormino@drs.com

*
 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

* Luminar Technologies; Orlando, FL; Import/Export Trade Compliance Specialist;
*
 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
* L-3; Ann Arbor, MI; Trade Compliance Manager; Requisition ID: 092335
* L-3; Greenville, TX; International Trade Compliance Administrator 3; Requisition ID: 095830
* L-3; Greenville, TX; Import/Export Administrator 3; Requisition ID: 095921
* L-3; Arlington, TX; Trade Compliance Practitioner, Empowered Official; Requisition ID: 089915
* Maersk/DAMCO; Agent de transit IMPORT – EXPORT; Job Ref.: DC-164022
* Mattson Technology; Fremont, California; Import/Export Compliance Analyst;
* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst
; Requisition ID: 16000DYY
* Medtronic; Wash DC;
Global Trade Lawyer
;
stacy.m.johnson@medtronic.com
; Requisition ID: 170002ON

* Meggit; Akron, OH; Manager, Trade Compliance;
# Meggit; Los Angeles, CA; Trade Compliance Manager;
* Mitchell Martin, Inc.; Dallas, Texas; Export Regulatory Trade Compliance Specialist; Requisition ID: 104405
* 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

* PerkinElmer, Inc.; Shelton, CT; International Trade Compliance – Export Coordinator;

# PerkinElmer, Inc.; Shelton, CT;
Systems Analyst, Trade Compliance Solutions;

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

# Raytheon Company; McKinney, TX; Global Trade Licensing Analyst;
* 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; 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

* Talascend; Ft Worth, TX; Trade Compliance Classification Analyst;
* TE Connectivity; Middletown, PA; Manager II, Global Trade Compliance; Requisition ID: 17361
* Teledyne Benthos; Falmouth, MA; Export Compliance Manager
* 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
* Terumo Medical Corporation; Somerset, NJ; Senior Global Trade Compliance Specialist;
*
 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

* Toyota North America; Dallas, TX; Export Control Analyst
*
 Tradewin; Portland, OR;
U.S. Export Compliance Consultant

* Trek; Waterloo, WI; Global Trade & Logistics Specialist;

* United Technologies – Pratt & Whitney; East Hartford, CT;
International Trade Compliance (ITC) Specialist; Requisition ID: 49375BR

* United Technologies – Pratt & Whitney; East Hartford, CT;
International Trade Compliance Manager; Requisition ID:  62176BR

* United Technologies – Pratt & Whitney; East Hartford, CT;
International Trade Compliance Authorizations Manager; Requisition ID: 63222BR

* United Technologies – Pratt & Whitney, East Hartford, CT;
International Trade Compliance Technology Senior Manager; Requisition ID: 55944BR

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

* 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
;

# Xylem, Inc; Morton Grove, IL;
Trade Compliance Specialist;

* Zeiss Group; Thornwood, NY;
Trade Compliance Specialist
;
* Zimmer Biomet; Warsaw, IN; Trade Compliance Manager

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

TECEX/IM TRAINING EVENTS & CONFERENCES

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

ENEDITOR’S NOTES


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

EN_a317
. Are Your Copies of Regulations Up to Date?
(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  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: 12 Apr 2018: 83 FR 15736-15740: CBP Decision No. 18-04; Definition of Importer Security Filing Importer (ISF Importer)
 
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: 
5 Apr 2018: 83 FR 14580-14583: Reclassification of Targets for the Production of Tritium and Related Development and Production Technology Initially Classified Under the 0Y521 Series [Imposes License Requirements on Transfers of Specified Target Assemblies and Components for the Production of Tritium, and Related “Development” and “Production” Technology.]

  
*
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: 24 Apr 2018: 3 FR 17749-17751: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates
  – HTS codes that are not valid for AES are available
here.
  – The latest edition (30 Apr 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: 4 May 2018: Harmonized System Update 1807, containing 289 ABI records and 60 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: 25 Apr 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.

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