;

18-0521 Monday “Daily Bugle”

18-0521 Monday “Daily Bugle”

Monday, 21 May 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 of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. Commerce/Census: “Tips on How to Resolve AES Fatal Errors”
  4. DHS/CBP Deploys AES Commodity and Export Manifest Certification
  5. DHS/CBP Posts Notice on Submitting Imports of Products Excluded from Duties on Imports of Steel or Aluminum
  6. State/DDTC Posts Name and Address Changes for Two Entities
  7. President Posts Executive Order Prohibiting Certain Additional Transactions with Respect to Venezuela
  1. CNBC: “Mnuchin Declares US-China Trade War ‘on Hold’ as Talks Progress
  2. Courthouse News: “11th Circuit Asked to Void Sentence in Weapons Conspiracy Case”
  3. Reuters: “U.S. Toughens Stance on Iran, Lists Sweeping Demands”
  1. Export Compliance Journal: “Export Compliance Due Diligence with Corporate Acquisitions”
  2. M. Volkov: “Episode 39: Tom Fox’s New Book – The Complete Compliance Handbook”
  1. Monday List of Ex/Im Job Openings: 133 Jobs Posted This Week, Including 11 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 (17 May 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

 

[No items of interest noted today.]

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

OGSOTHER GOVERNMENT SOURCES

OGS_a11. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* Commerce; Industry and Security Bureau; PROPOSED RULES; Control of Firearms, Guns, Ammunition and Related Articles the President Determines No Longer Warrant Control under the United States Munitions List [Publication Date: 24 May 2018.]
 
* State; PROPOSED RULES; International Traffic in Arms Regulations: U.S. Munitions List Categories I, II, and III [Publication Date: 24 May 2018.]
 
[Editor’s Note: Both item above were already included in the 15 May 2018 Daily Bugle, item 4 and 5.]
 
* Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 22 May 2018.]

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

(Source: 
Commerce/BIS
)

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

OGS_a2
3
. Commerce/Census: “Tips on How to Resolve AES Fatal Errors”
 

(Source: census@subscriptions.census.gov, 21 May 2018.)
 
When a shipment is filed to the AES, a system response message is generated and indicates whether the shipment has been accepted or rejected.  If the shipment is accepted, the AES filer receives an Internal Transaction Number (ITN) as confirmation.  However, if the shipment is rejected, a Fatal Error notification is received. 

To help you resolve AES Fatal Errors, here are some tips on how to correct the most frequent errors that were generated in AES for this month. 

 
Fatal Error Response Code:  643
  – Narrative: Quantity 2 Must Be Greater Than Zero
  – Reason: The Schedule B/HTS number reported requires a second Quantity to be reported and the Quantity 2 is missing or reported as zero.   
  – Resolution: Quantity 2 must be greater than zero.
Verify the Quantity 2, correct the shipment and resubmit.
 
Fatal Error Response Code:  649
  – Narrative: Quantity 1 Cannot Exceed Shipping Weight
  – Reason:  Shipping Weight is reported in kilograms.  When the Unit of Measure 1 requires kilograms, the first net quantity (Quantity 1) cannot exceed the Shipping Weight.  Ensure the Shipping Weight includes the weight of the packaging materials.  
  – Resolution: The first net quantity (Quantity 1) in kilograms cannot exceed the Shipping Weight in kilograms.
Verify the Quantity 1 and Shipping Weight, correct the shipment and resubmit.
 

For a complete list of Fatal Error Response Codes, their reasons, and resolutions, see Appendix A – Commodity Filing Response Messages.

It is important that AES filers correct Fatal Errors as soon as they are received in order to comply with the Foreign Trade Regulations.  These errors must be corrected prior to export for shipments filed predeparture and as soon as possible for shipments filed postdeparture but not later than five calendar days after departure.

For further information or questions, contact the U.S. Census Bureau’s Data Collection Branch.

  – Telephone: (800) 549-0595, select option 1 for AES 

  – Email: askaes@census.gov  
  – Online: www.census.gov/trade

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

(Source:
CSMS #18-000354, 21 May 2018.)
 
CBP has deployed to the certification environment the following changes for AES Commodity and Export Manifest filings.
 
Export Manifest Pilot:
  – Generate 8Z message to house bill issuer when master bill is deleted
  – Generate 69/55/54 messages Export Manifest Air/Ocean
  – Fix response notification service for 1Y messages and RC messages for Ocean
 
AES Commodity Filing:
  – Fix 97H/97R response messages to include severity code
 
If you would like to test please contact your client representative for instructions.
* * * * * * * * * * * * * * * * * * * * 

OGS_a4
5
. DHS/CBP Posts Notice on Submitting Imports of Products Excluded from Duties on Imports of Steel or Aluminum
 

(Source: CSMS #18-000352, 21 May 2018.)
 
On March 19, 2018, the Department of Commerce (DOC) published in the Federal Register (FR) the process for parties to submit requests for exclusions from Presidential Proclamations 9704 and 9705 on Adjusting Imports of Steel and Aluminum into the United States under section 232 of the Trade Expansion Act of 1962. See 83 FR 12106.
 
The functionality described below for the Importer Additional Declaration Field will be available in the Automated Commercial Environment (ACE) as of June 1, 2018. For any exclusions approved by DOC prior to June 1, 2018, importers may submit a Post Summary Correction (PSC) on or after June 1, 2018 to request a refund on applicable previous imports of excluded products, as described in the additional information section below.
 
INSTRUCTIONS FOR FILING PRODUCT EXCLUSION NUMBERS
 
Instructions on submitting entries to CBP of steel and aluminum products granted exclusions by DOC from the Presidential Proclamations are as follows:
 
Importers and filers importing products granted an exclusion should submit the product exclusion number based on the last six digits of the product exclusion docket number at Regulations.gov. The product exclusion number should be submitted in the Importer Additional Declaration Field (54 record) of the entry summary data, based on the following format:
 
  – For excluded steel mill articles = STLXXXXXX
  – For excluded aluminum articles = ALUXXXXXX
 
XXXXXX represent the last six digits of the Regulations.gov docket number; do not include spaces or special characters, such as hyphens.
 
Example: If a steel exclusion is granted under product exclusion docket number BIS-2018-0009-9002, the importer/filer should submit the exclusion number STL099002 (i.e. STL plus the last six digits of the docket number).
 
Please refer to the Importer’s Additional Declaration Detail (Input 54-Record) of the CBP and Trade Automated Interfaces Requirements (CATAIR) Manual for further guidance. The CATAIR document can be found here.
 
Only products from importer(s) designated in the product exclusion approved by the DOC are eligible for the exclusion from the Section 232 measures.
 
Steel importers are reminded to submit mill certificates with their import data as required by 19 CFR 141.89
 
Do not submit the corresponding Chapter 99 HTS number for the Section 232 duties when the product exclusion number is submitted.
 
ADDITIONAL INFORMATION
 
Exclusions granted by DOC are retroactive on imports to the date the request for exclusion was posted for public comment at Regulations.gov.
 
To request an administrative refund for previous imports of excluded products granted by DOC, importers may file a PSC and provide the product exclusion number in the Importer Additional Declaration Field.
 
Once products are excluded from the Section 232 measures, importers may claim Generalized System of Preferences (GSP) or African Growth and Opportunity Act (AGOA) duty preferences on GSP and AGOA-eligible goods. If importers did not receive GSP or AGOA duty preferences on previous imports, and those imports are now covered by a retroactive exclusion, importers may request a refund of the duties subject to GSP or AGOA preferences through a PSC.
 
If the entry has already liquidated, importers may protest the liquidation.
 
For more information about submitting Post Summary Corrections, see Section 11 of the ACE Entry Summary Business Process. The ACE Entry Summary Business Process Document can be found here.
 
For more information, please refer to the March 19, 2018 FR notice on requesting product exclusions. Questions related to Section 232 entry filing requirements should be emailed to traderemedy@cbp.dhs.gov. Questions from the importing community concerning ACE rejections should be referred to their Client Representative.
* * * * * * * * * * * * * * * * * * * * 

 
* Oculus Info Inc. Changes Name to Uncharted Software Inc.
* Quyntess BV Changes Address
* * * * * * * * * * * * * * * * * * * * 

(Source:
The White House, 21 May 2018.)
 
By the authority vested in me as President by the Constitution and the laws of the United States of America, including the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), the National Emergencies Act (50 U.S.C. 1601 et seq.), and section 301 of title 3, United States Code, I, DONALD J. TRUMP, President of the United States of America, in order to take additional steps with respect to the national emergency declared in Executive Order 13692 of March 8, 2015, and relied upon for additional steps taken in Executive Order 13808 of August 24, 2017 and Executive Order 13827 of March 19, 2018, particularly in light of the recent activities of the Maduro regime, including endemic economic mismanagement and public corruption at the expense of the Venezuelan people and their prosperity, and ongoing repression of the political opposition; attempts to undermine democratic order by holding snap elections that are neither free nor fair; and the regime’s responsibility for the deepening humanitarian and public health crisis in Venezuela, hereby order as follows:
 
Section 1.
  (a) All transactions related to, provision of financing for, and other dealings in the following by a United States person or within the United States are prohibited:
  (i) the purchase of any debt owed to the Government of Venezuela, including accounts receivable;
  (ii) any debt owed to the Government of Venezuela that is pledged as collateral after the effective date of this order, including accounts receivable; and
  (iii) the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela of any equity interest in any entity in which the Government of Venezuela has a 50 percent or greater ownership interest.
  (b) The prohibitions in subsection (a) of this section apply except to the extent provided by statutes, or in regulations, orders, directives, or licenses that may be issued pursuant to this order, and notwithstanding any contract entered into or any license or permit granted before the effective date of this order.
 
Sec. 2.
  (a) Any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions set forth in this order is prohibited.
   (b) Any conspiracy formed to violate any of the prohibitions set forth in this order is prohibited.
 
Sec. 3. For the purposes of this order:
  (a) The term “person” means an individual or entity;
   (b) The term “entity” means a partnership, association, trust, joint venture, corporation, group, subgroup, or other organization;
   (c) the term “United States person” means any United States citizen, permanent resident alien, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches of such entities), or any person within the United States; and
   (d) the term “Government of Venezuela” means the Government of Venezuela, any political subdivision, agency, or instrumentality thereof, including the Central Bank of Venezuela and Petroleos de Venezuela, S.A. (PdVSA), and any person owned or controlled by, or acting for or on behalf of, the Government of Venezuela.
 
Sec. 4. The Secretary of the Treasury, in consultation with the Secretary of State, is hereby authorized to take such actions, including promulgating rules and regulations, and to employ all powers granted to the President by IEEPA as may be necessary to implement this order. The Secretary of the Treasury may, consistent with applicable law, re-delegate any of these functions to other officers and executive departments and agencies of the United States Government. All agencies of the United States Government shall take all appropriate measures within their authority to carry out the provisions of this order.
 
Sec. 5. This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.
 
Sec. 6. This order is effective at 12:30 p.m. eastern daylight time on May 21, 2018.
* * * * * * * * * * * * * * * * * * * * 

NWSNEWS

NWS_a28
. CNBC: “Mnuchin Declares US-China Trade War ‘on Hold’ as Talks Progress

(Source:
CNBC, 20 May 2018.) [Excerpts.]
 
The U.S. trade war with China is “on hold” after the world’s largest economies agreed to drop their tariff threats while they work on a wider trade agreement, U.S. Treasury Secretary Steven Mnuchin said on Sunday.
 
Mnuchin and U.S. President Donald Trump’s top economic adviser, Larry Kudlow, said the agreement reached by Chinese and American negotiators on Saturday set up a framework for addressing trade imbalances in the future.
 
“We are putting the trade war on hold. Right now, we have agreed to put the tariffs on hold while we try to execute the framework,” Mnuchin said in a television interview on “Fox News Sunday.”
 
On Saturday, Beijing and Washington
said they would keep talking about measures under which China would import more energy and agricultural commodities from the United States to close the $335 billion annual U.S. goods and services trade deficit with China.
 
During an initial round of talks this month in Beijing, Washington demanded that China reduce its trade surplus by $200 billion. No dollar figure was cited in the countries’ joint statement on Saturday. …

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

(Source:  
Courthouse News, 18 May 2018.)
 
The attorney for a Chinese woman convicted of trying to send a $50 million missile-firing drone and jet fighter engines to China, asked the 11
th Circuit on Friday to overturn her conviction claiming that there is no substantial evidence to incriminate her.
Wenxia Man, a Chinese immigrant who settled in California, was sentenced in 2016 to more than four years in prison after being found guilty of conspiracy and of engaging in illegal brokering activities.
 
The U.S. requires a license for the exportation of arms, munitions, and other implements of war and defense to foreign countries.  In 1989, the U.S. entered an embargo against China that prohibits the export of any defense article and weapons to that nation.
 
According to court documents, Man acted as a broker to negotiate and arrange the sale of defense articles and technical data from March 2011 until about June 2013 without obtaining a license or approval from the U.S. Department of State.
 
Man, a San Diego resident, purportedly worked with Chinese national Xinsheng Zhang, who she referred to as a “technology spy” and was connected to the Chinese military to copy items obtained from other countries.
 
The indictment said that Man and Zhang solicited price quotations for jet fighter engines, drones and technical data for each of the defense articles from persons that they believed were vendors of military equipment in the United States.
 
Man and Zhang discussed with these vendors that the military equipment would be shipped through third countries in order to avoid the arms embargo against China, the indictment says.
On Friday, attorney Kevin Schreiner asked the three-judge panel to revoke the conviction because there is “insufficient evidence” that indicates that his client committed a violation of the Arms Export Control Act.
 
He claimed that Man had no criminal background, and that there was no indication that she was involved in any illegal activity
  “The government did not show sufficient evidence of conspiracy,” Schreiner said.
 
U.S. Attorney Ben Greenberg, who appeared on behalf of the United States, said that there was a clear conspiracy between Man and Zhang.
 
Greenberg argued that the many emails and phone calls that Man had with an undercover agent from the Department of Homeland Security, who was posing as a U.S. arms supplier, clearly show that she was trying to import weapons to China.
 
  “The fact that they kept changing the agreement doesn’t change the fact that it was a conspiracy,” Greenberg said.
 
Schreiner countered by saying that Man and Zhang agreed to negotiate an agreement that never became effective.
 
  “Zhang followed a typical pattern where he would inquire about jet engines and weapons, but there was never an agreement between him and Man,” Schreiner said.
 
But, “they got to an agreement together,” U.S. Circuit Judge William Pryor said. “Man was aware that the proposals were illegal,” he added.
 
Schreiner argued that Zhang was never satisfied with Man’s offers, and that there was never any evidence to show that they got to an agreement.
 
According to South Florida’s Sun Sentinel newspaper, during Man’s trial U.S. District Judge Beth Bloom ordered her to receive mental health treatment during and after her imprisonment of four years and two months.
 
However, even though there was evidence that Man had mental health issues, the judge did not believe that it played an important role in her crime, the SuSentinel reported.
 
The panel did not say when a final decision would be made on the case.

 

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

(Source:
Reuters, 21 May 2018.) [Excerpts.]
 
The United States on Monday demanded Iran make sweeping changes – from dropping its nuclear program to pulling out of the Syrian civil war – or face severe economic sanctions as the Trump administration hardened its approach to Tehran.
 
Iran dismissed Washington’s ultimatum and one senior Iranian official said it showed the United States is seeking “regime change” in Iran.
 
Weeks after President Donald Trump pulled out of an international nuclear deal with Iran, his administration threatened to impose “the strongest sanctions in history,” and vowed to “crush” Iranian operatives abroad, setting Washington and Tehran further on a course of confrontation.
 
U.S. Secretary of State Mike Pompeo demanded sweeping changes that would force Iran effectively to reverse the recent spread of its military and political influence through the Middle East to the shores of the Mediterranean Sea.
 
  “The sting of sanctions will only grow more painful if the regime does not change course from the unacceptable and unproductive path it has chosen for itself and the people of Iran,” Pompeo said in his first major speech since becoming secretary of state.
 
  “These will be the strongest sanctions in history by the time we are done,” he added. …
 
NAMING NAMES
 
Pompeo said if Iran made major changes, the United States was prepared to ease sanctions, re-establish full diplomatic and commercial relations and support the country’s re-integration into the international economic system. …

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

COMMCOMMENTARY

COMM_a0
11. Export Compliance Journal: “Export Compliance Due Diligence with Corporate Acquisitions”

(Source:
ECustoms
, 16 May 2018.
)
 
Whether diversifying or sharpening focus, in the normal course of business companies decide to buy other companies.
 
The emphasis in that decision will have been in the areas of sales performance, product appeal, and market penetration. All well and good, but in defense trade acquisitions there are additional legal responsibilities and liabilities involved-those surrounding export control compliance.
 
The responsibility for compliance with U.S. regulations raises many questions and considerations that need to be answered, both before and after an acquisition is made. As well as its products and infrastructure, any ITAR or EAR violations, settlements, penalties, disclosures, and enforcement actions, such as they might be, are acquired in the purchase.
 
These considerations are not trivial, and are as much a part of the viability of the deal as products and profitability. Many questions are raised. What export controls have been applicable for the company? Has the company been compliant with these controls? Is the company registered with the Department of Defense Trade Controls? If they are not registered, how has its ITAR export compliance been managed?
 
Key question to ask: where does a company fall on the export compliance spectrum?

 

A presentation at SIA Spring 2018 clarified many of the questions and concerns involved. If the company being acquired has been managing an effective compliance program, with a formalized export control policy, sound export control procedures, license management, documentation, and reporting, then all involved will already be seeing eye-to-eye. If the target has not been getting licenses for its USML or CCL exports-or, depending on the rigor of its policies, even if it has-then the process of acquisition can or will include a mass of voluntary self-disclosures and possible penalties for violations. Has the company been screening for restricted parties? Is it already subject to an enforcement action or current monetary penalties?
 
If the company making the purchase is asking these questions, that recommends that it operates a robust compliance regime itself and will be integrating the company being purchased into its own programs to ensure compliance success. Any existing required notices and authorization transfers have to be handled and, on review of the target company’s history, the necessary voluntary self-disclosures have to be filed.
 
Getting to the “root” of potential export violations 

 

Voluntary self-disclosure analysis has to be a ‘root cause’ analysis. In other words, “Get the facts. Calibrate the root cause.” There are guidelines for Voluntary Self-Disclosure in ITAR §127.12-who is involved? What happened and why? How was the violation discovered? What remedial measures will be taken?
 
Root cause analysis means getting down to what really drove the error to occur, rather than only the casual effects seen. The effort is not one of “putting out fires.” It is peeling back the layers of symptoms to reveal the true problem. Examples of root causes for violations are failure to screen parties against restricted lists, poor recordkeeping, lack of training, failure to notify involved parties, failure to comply with license conditions, and so forth. For any violation that is discovered, there will be both mitigating circumstances and aggravating circumstances to detail, corrective actions to document, and sustainment activities to recommend.

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

COMM_a01
12. M. Volkov: “Episode 39: Tom Fox’s New Book – The Complete Compliance Handbook”

(Source: Volkov Law Group Blog, 20 May 2018. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
Tom Fox is a thought leader for the ethics and compliance profession.  He is a prolific writer who has produced a steady body of work – podcasts, books, blogs, articles – to advance the compliance function.  He is knowledgeable, practical and insightful on how to implement and maintain an effective compliance program.
 
Tom has just released a new and important book – 
The Complete Compliance Handbook.  His latest book is the culmination of years of writing, insights and leadership.
 
In this episode, Mike Volkov interviews Tom about his new book, his perspective on the compliance function and the insights he has gained over the years.

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

MSEX/IM MOVERS & SHAKERS

MS_a213. Monday List of Ex/Im Job Openings; 133 Jobs Posted This Week, Including 11 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

* 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;

* AMD; Austin, TX;
Manager, Import/Export;

* 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; 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; Mesa, AR;
Trade Control Specialist;
* Boeing; Ridley Park, PA;  
Trade Control Specialist
; 

*
 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

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

* DHL; Newark, NJ;
Director, Export Control & Compliance – USA
; Requisition ID: ref57592

*
 DynCorp International; Tampa, FL; Foreign Disclosure Officer; Requisition ID: PR1701977

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

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

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

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

* EoTech Technologies; Ann Arbor, MI; Trade Compliance Manager; Requisition ID: 092335 
* Erickson, Inc.; Central Point, OR; Import Specialist; Requisition ID: 756803

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

*
 Expeditors; Sunnyvale, CA;
Customs Compliance Supervisor
;


*
 Expeditors; Krefeld, Germany; 
Clerk Import / Export
 ;
*
 Expeditors; Bedfont, United Kingdom;
Customs Brokerage Clerk
;
*
 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

* 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; Nashua, NH; 
Global Trade Compliance Analyst, Traffic
; 

*
 FLIR; Billerica, MA;
Global Trade Compliance 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

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

* General Dynamics; Falls Church, VA;
Director, Trade Compliance
; Job ID: 2018-1122

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

* Harris Corporation; Beaverton, OR;
Manager, International Government Relations;

* Henderson Group Unlimited; Inc; Washington, DC; 
Process Improvement Mgr

* Henderson Group Unlimited; Inc; Washington, DC; 
Defense Control 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

#
 Huntington Ingalls Industries; Virginia Beach, VA; 
 AMSEC-Import/Export Administrator 2
; Requisition ID: 23979BR

* Hussman; Bridgeton, MO; 
Trade Compliance Specialist;

*
 Infineon Technologies; Munich, Germany;
Experte Export Control (w/m)
; Requisition ID: 22825
* Infineon Technologies; Melaka, Malaysia; Export Control Executive; Requisition ID: 26833
* Infineon Technologies; Porto (Maia) Portugal;  Trade Compliance Administrator; Requisition ID: 25550

* Infineon Technologies; Milpitas, CA;
Export Compliance Specialist; Requisition ID: 26988

* Infineon Technologies; El Segundo, CA;  Export Compliance Specialist; Requisition ID: 26826

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

*
 InteliTrac Global Solutions; Herndon, VA;
ITAR Compliance Official
;

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

* Lam Research Corp.; Singapore;
Foreign Trade Analyst 3;

* Lam Research Corp.; Fremont, CA;  Foreign Trade Intern;

* Lam Research Corp.; Shanghai, China; 
Foreign Trade (FT) Analyst;

* Lam Research Corp.; Fremont, CA; 
Foreign Trade Data Analyst;

* 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; Fort Worth, TX; Import Export Compliance Coordinator; Job ID: 397600BR
# Lockheed Martin; Fort Worth, TX; Export and Import Compliance Investigations Lead; Job ID: 427872BR

# Lockheed Martin; Fort Worth, TX; Licensing Integration and Support; Job ID: 433056BR

#
 Lockheed Martin; Fort Worth, TX; Regulatory Compliance Analyst Senior; Job ID: 433405BR

# Lockheed Martin; Orlando, FL; International Licensing Analyst Sr; Job ID: 424151BR
# Lockheed Martin; Oswego, NY; Licensing Analyst; Job ID: 415717BR
# Lockheed Martin; Oswego, NY; Licensing Analyst; Job ID: 415708BR

* Luminar Technologies; Orlando, FL;
Import/Export Trade Compliance Specialist
;

*
 L-3 ALST; Orlando, FL;
Contracts Manager / Empowered Official
; Requisition ID: 093069
* L-3 Warrior Sensor Systems; Londonderry, NH; Purchasing & Compliance Manager; Requisition ID:096596
*
 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; Grand Rapids, MI;
Sr. Trade Compliance Administrator; Requisition ID: 097197

* L-3; Arlington, TX;
Compliance Manager
; Requisition ID: 098246

* Mattson Technology; Fremont, California;
Import/Export Compliance Analyst;

* 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 Officer;
* Meggit; Miami, FL;
Trade Compliance Officer;
* Meggit; Tucson, AZ; 
Trade Compliance Specialist;
* Mitchell Martin, Inc.; Dallas, Texas; Export Regulatory Trade Compliance Specialist; Requisition ID: 104405

# Moog; East Aurora, NY;
Manager, Group Trade Compliance Manager
 
; Amy Hanavan,   
ahanavan@moog.com
; Requisition ID: 182102

* MTS Systems; Eden Prairie, MN;
Global Trade Compliance Manager
; Requisition ID: 37841
* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2

Requisition ID
:
17022803
 
 

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

* Office of the Director of National Intelligence; McLean, VA;
Associate General Counsel
;

# Oracle; Unspecified, United States; Customs Compliance Specialist; Requisition ID: 18000H0N
# Oracle; Hong Kong;
Compliance Counsel; Requisition ID: 
17001HWJ

* Orbital ATK, Inc.; Dulles, VA; Principal Import/Export Analyst
; Job ID:  JAY20182304-45242.

* Pentair; Illinois, USA; Import/Export Compliance Specialist; Requisition ID: 115774
* Pentair; Illinois, USA; Import/Export Compliance Specialist; Requisition ID: 115926

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

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

* 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

* Spirent; San Jose, CA;
Global Trade Compliance Specialist
; Requisition ID: 4088

* Teledyne Benthos; Falmouth, MA; Export Compliance Manager

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

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

* United Technologies – Pratt & Whitney; East Hartford, CT; 
International Trade Compliance IT Systems & Integration Mgr.
; Requisition ID: 62310BR

* 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
* Vigilant; Negotiable Location, USA;
Global Trade Compliance Analyst
;

* Virgin Galactic; Las Cruces, NM; Export Compliance Officer; Requisition ID: 2018-3558
* Williams International; Pontiac, MI; Trade Compliance Specialist; Requisition ID: 17-0275

*
 Xylem, Inc.; Remote, United States;
Manager, Global Ethics & Compliance
;

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

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

TECEX/IM TRAINING EVENTS & CONFERENCES

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

ENEDITOR’S NOTES

 

Alexander Pope (21 May 1688 – 30 May 1744) was an 18th-century English poet. He is best known for his satirical verse, his translation of Homer and for his use of the heroic couplet. He is the second-most frequently quoted writer in The Oxford Dictionary of Quotations after Shakespeare.)
  – “Be not the first by whom the new are tried, Nor yet the last to lay the old aside.”
  – “Beauties in vain their pretty eyes may roll; charms strike the sight, but merit wins the soul.”
 
Monday is Punday.
 
* My girlfriend told me she was leaving me because I keep pretending to be a Transformer. I said, “No, wait! I can change!”
* Did you hear about the guy whose whole left side was cut off? He’s all right now.
* Yesterday I accidentally swallowed some food coloring. The doctor says I’m OK, but I feel like I’ve dyed a little inside.

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

EN_a316
. 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: 17 May 2018: 83 FR 22842-22846: Revisions to the Unverified List (UVL)

  
*
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_a0317
Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

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

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

EPEDITORIAL POLICY

* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, John Bartlett. The Ex/Im Daily Update is emailed every business day to approximately 8,000 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOE/NRC, DOJ/ATF, DoD/DSS, DoD/DTSA, FAR/DFARS, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

* RIGHTS & RESTRICTIONS: This email contains no proprietary, classified, or export-controlled information. All items are obtained from public sources or are published with permission of private contributors, and may be freely circulated without further permission, provided attribution is given to “The Export/Import Daily Bugle of (date)”. Any further use of contributors’ material, however, must comply with applicable copyright laws.

* CAVEAT: The contents of this newsletter cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.


* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website

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

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