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18-0611 Monday “Daily Bugle”

18-0611 Monday “Daily Bugle”

Monday, 11 June 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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  1. Commerce Announces Spring 2018 Semiannual Agenda of Regulations 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS Publishes Warning Letter Concerning Lockheed Martin Corporation
  3. State/DDTC: (No new postings.)
  4. EU Amends Restrictive Measures Concerning ISIL (Da’esh) and Al-Qaida Organizations
  1. Defense One: “The U.S. Defense Industry Wants an Arms-Export Czar”
  2. Euractiv: “Nine Countries Unite Against EU Export Controls on Surveillance Software”
  3. Reuters: “German Container Line Hapag-Lloyd Scaling Back Iran Business”
  4. Reuters: “U.S. Sanctions Russians Over Military, Intelligence Hacking”
  5. The Wall Street Journal: How a Powerful Spy Camera Invented at Duke Ended Up in China’s Hands”
  1. G. Zack: “Those Are Not Compliance Officers at ZTE”
  2. M. Volkov: “Episode 42 – How to Manage Your CEO on Compliance Issues”
  3. R.C. Burns: “EU Commission Menacingly Threatens Toothless Blocking Regulation”
  1. SIA Announces 2018-2020 Board of Directors
  2. Monday List of Ex/Im Job Openings: 184 Jobs Posted This Week, Including 50 New Jobs
  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 (6 Jun 2018), FACR/OFAC (19 Mar 2018), FTR (24 Apr 2018), HTSUS (8 Jun 2018), ITAR (14 Feb 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. Commerce Announces Spring 2018 Semiannual Agenda of Regulations
(Source:
Federal Register
 
, 11 June 2018.) [Excerpts.]
 
83 FR 27099-27116: Spring 2018 Semiannual Agenda of Regulations
* AGENCY: Office of the Secretary, Commerce.
* ACTION: Semiannual regulatory agenda.
* SUMMARY: In compliance with Executive Order 12866, entitled “Regulatory Planning and Review,” and the Regulatory Flexibility Act, as amended, the Department of Commerce (Commerce), in the spring and fall of each year, publishes in the Federal Register an agenda of regulations under development or review over the next 12 months. Rulemaking actions are grouped according to prerulemaking, proposed rules, final rules, long-term actions, and rulemaking actions completed since the fall 2017 agenda. The purpose of the Agenda is to provide information to the public on regulations that are currently under review, being proposed, or issued by Commerce. The agenda is intended to facilitate comments and views by interested members of the public.
   Commerce’s spring 2018 regulatory agenda includes regulatory activities that are expected to be conducted during the period May 1, 2018, through April 30, 2019.
* FOR FURTHER INFORMATION CONTACT:
   Specific: For additional information about specific regulatory actions listed in the agenda, contact the individual identified as the contact person.
   General: Comments or inquiries of a general nature about the agenda should be directed to Asha Mathew, Chief Counsel for Regulation, Office of the Assistant General Counsel for Legislation and Regulation, U.S. Department of Commerce, Washington, DC 20230, telephone: 202-482-3151.
 
* SUPPLEMENTARY INFORMATION: ….
   Commerce’s spring 2018 regulatory agenda follows.
 
Peter B. Davidson, General Counsel. …
 
DEPARTMENT OF COMMERCE (DOC)
 
Bureau of Industry and Security (BIS)
 
Proposed Rule Stage
 
(23) Expansion of Export, Reexport, and Transfer (In-Country) Controls for Military End Use or Military End Users in the People’s Republic of China (China), Russia, or Venezuela
  – E.O. 13771 Designation: Other. …
  – Abstract: The Bureau of Industry and Security (BIS) proposes to amend the Export Administration Regulations (EAR) to expand license requirements on exports, reexports, and transfers (in-country) of items intended for military end use or military end users in the Peoples Republic of China (China), Russia, or Venezuela. Specifically, this rule would expand the licensing requirements for China to include “military end users,” in addition to “military end use.” It would broaden the items for which the licensing requirements and review policy apply and expand the definition of “military end use.” Next, it would create a new reason for control and associated review policy for regional stability for certain items to China, Russia, or Venezuela, moving existing text related to this policy. Finally, it would add Electronic Export Information filing requirements in the Automated Export System for exports to China, Russia, and Venezuela. …
  – Regulatory Flexibility Analysis Required: Yes.
  – Agency Contact: Hillary Hess, Director, Regulatory Policy Division, Department of Commerce, Bureau of Industry and Security, 14th Street and Pennsylvania Avenue NW, Washington, DC 20230, Phone: 202 482-2440, Fax: 202 482-3355, Email: hillary.hess@bis.doc.gov. …

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

OGSOTHER GOVERNMENT SOURCES

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

* President; ADMINISTRATIVE ORDERS; Administrative Orders
Belarus; Continuation of National Emergency (Notice of 8 Jun 2018) [Publication Date: 12 Jun 2018.]
 
* DHS/CBP; RULES; Air Cargo Advance Screening [Publication Date: 12 Jun 2018.]
 
* State; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals [concerns six DDTC information collections; Publication Date: 12 Jun 2018.]
* * * * * * * * * * * * * * * * * * * *

OGS_abc23. 
Commerce/BIS Publishes Warning Letter Concerning Lockheed Martin Corporation 
(Source: 
Commerce/BIS, 11 Jun 2018.) 
 
BIS has published a 23 May 2018 
warning letter to Lockheed Martin Corporation of Arlington, VA, alleging violations of the Anti-boycott Act provisions of 15 CFR 760.2(d) on or about 22 July 2014, by certifying that goods for export did not contain Israeli parts or components, and by failing to report the receipt of such request for certification to the Department of Commerce.

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

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

OGS_a35. 
EU Amends Restrictive Measures Concerning ISIL (Da’esh) and Al-Qaida Organizations 

(Source: 
Official Journal of the European Union, 11 Jun 2018.)
 

Commission Implementing Regulation (EU) 2018/855 of 8 June 2018 amending for the 286th time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organizations 

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

NWSNEWS

(Source: 
Defense One, 1 Jun 2018.) [Excerpts.] 
 
The two proposals were among 
the recommendations sent to Secretary of State Mike Pompeo this week by the Aerospace Industries Association in hopes that the export-friendly administration will implement lasting changes to speed up arms exports regardless of who occupies the White House. Specifically, AIA wants the U.S. government to decide more quickly whether an ally can buy a specific weapon.
 
  “A number of times, it was my experience that people who didn’t support a sale thought that they were deciding whether or not this partner, ally, or other military got that capability,” said AIA president and CEO Eric Fanning. During the Obama administration, Fanning served as Army secretary, Air Force undersecretary, and a senior position in the Navy.
  

  “When really what [they] were deciding [was] whether it’s an American capability,” he said. “They can turn somewhere else to get that capability if it’s not ours.” … 

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

(Source: 
Euractiv, 8 Jun 2018.) [Excerpts.]
 
An EU proposal to impose export controls on technology products that can be used as spyware is at risk of being delayed as a group of nine countries have pushed back against the overhaul.
 
EU officials are concerned that a bill that to regulate the export of so-called dual use products could be toppled ahead of next year’s European Parliament election. Dual use products can be used for either civilian or military purposes and fall under special export controls.
 
Nine countries, led by Sweden, have united against the proposal’s clampdown on exports of technology products that could be used to harm human rights.
 
Sweden, the Czech Republic, Cyprus, Estonia, Finland, Ireland, Italy, Poland and the United Kingdom drafted a paper criticizing the bill.
 
Diplomats from the nine countries warned that the proposal could lead to “portraying Europe as a technology-averse continent and an unlikely home for any global frontrunners on ICT or other technologies of the future generations” 
in a document that EURACTIV has obtained, which was circulated to all 28 member states on 15 May. … 

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

NWS_38. 
Reuters: “German Container Line Hapag-Lloyd Scaling Back Iran Business”
(Source: 
Reuters, 11 Jun 2018.) 
 
German shipping line Hapag-Lloyd has stopped one of two feeder services to Iran and will decide on the remaining one before a Nov. 4 deadline imposed by the United States, which has reimposed sanctions on Tehran.
 
Hamburg-based Hapag-Lloyd, the world’s fifth largest container company, said it had initiated a process to stop handling products included in the list of commodities hit by U.S. sanctions, within the required wind down timeline.
 
The group said it did not have any direct services handling Iran volumes of its own, saying it used partners.
 
  “One of these two services has been discontinued, with the other under review,” Hapag Lloyd said in a written reply to Reuters questions.
 
It said the company was awaiting further clarification as to what operations would be permitted after the wind-down period in order to take final decisions on whether to serve Iran.
 
MSC, the world’s No. 2 container shipping line, said last month it would stop taking new bookings for Iran but would complete acceptable cargoes such as foodstuffs during the wind-down period.
 
World market leader Maersk Line also said it was reviewing its Iran operations.
 
Hapag-Lloyd, like the two other companies, services Iran via third-party feeder ships from the Jebel Ali hub in the United Arab Emirates.
 
Under a 2015 agreement, the United States and five other world powers agreed to lift sanctions on Iran in exchange for limits to Tehran’s nuclear program. Washington said this year it was withdrawing from the deal and would reimpose sanctions.
 
Iran relies on seaborne trade for imports and to sell oil and other goods. The country had struggled with logistical difficulties before international sanctions were lifted in 2016. 

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

NWS_49. 
Reuters: “U.S. Sanctions Russians Over Military, Intelligence Hacking”
(Source: 
Reuters, 11 Jun 2018.) [Excerpts.] 
 
The U.S. Treasury imposed sanctions on three Russian individuals and five companies on Monday, saying they had worked with Moscow’s military and intelligence services on ways to conduct cyber attacks against the United States and its allies.
 
  “The United States is engaged in an ongoing effort to counter malicious actors working at the behest of the Russian Federation and its military and intelligence units to increase Russia’s offensive cyber capabilities,” Treasury Secretary Steven Mnuchin said in a statement.
 
  “The entities designated today have directly contributed to improving Russia’s cyber and underwater capabilities through their work with the FSB and therefore jeopardize the safety and security of the United States and our allies,” Mnuchin said, using an acronym for Russia’s Federal Security Service.
 
The designation blocks all property of those targeted that is subject to U.S. jurisdiction and prohibits American citizens from engaging in transactions with them. … 
 
The Treasury said Russia’s “malign and destabilizing cyber activities” included the NotPetya attack last year, which spread across Europe, Asia and the Americas. The White House in February blamed Russia for the attack, saying it caused billions of dollars in damage and was part of the Kremlin’s effort to destabilize Ukraine.
 
The attacks also included assaults on the U.S. energy grid and on internet routers and switches, the Treasury said. … 
 
The designated firms are Digital Security, ERPScan, Embedi, Kvant Scientific Research Institute, and Divetechnoservices. … 
 
The individuals named on Monday all had ties to Divetechnoservices: its general director, Aleksandr Lvovich Tribun; its program manager, Oleg Sergeyevich; and Chirikov and Vladimir Yakovlevich Kaganskiy, the company’s owner. … 

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

NWS_510. 
The Wall Street Journal: How a Powerful Spy Camera Invented at Duke Ended Up in China’s Hands”
(Source: 
The Wall Street Journal, 11 Jun 2018.) [Excerpts; subscription required.]
 
High-tech camera, conceived by scientists for the Pentagon, finds light by moving east.
 
Five years ago, a group of Duke University scientists developed a pioneering gigapixel camera to provide long-range surveillance for the U.S. Navy through a sponsorship from the Pentagon.
 
The technology, never picked up by the U.S. government, is now being used by Chinese police to identify people from nearly a football field away, after lead Duke researcher David Brady moved to China in 2016 to kick-start his business. …  

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

COMMCOMMENTARY

COMM_a0
11.
G. Zack: “Those Are Not Compliance Officers at ZTE”

(Source: 
FCPA Blog, 11 June 2018.)
 
* Author: Gerry Zack, incoming CEO of the Society of Corporate Compliance and Ethics and the Health Care Compliance Association, 
 
As 
reported on the FCPA Blog on June 7, in the Commerce Department’s announcement of its settlement with ZTE Corporation, it referred to a requirement for ZTE to “retain a team of special compliance coordinators selected by and answerable to” the Commerce Department for ten years.
Earlier, in a May 24 interview on CNBC, Commerce Secretary Wilbur Ross referred to this requirement as “implanting people of our choosing” as a compliance unit. The CNBC headline and interviewer referred to these individuals as “compliance officers.”
While the placement of these individuals may help to ensure that ZTE does not violate sanctions regimes again, let’s be clear — people implanted by the government are neither “compliance coordinators” nor are they “compliance officers.” They are government enforcement monitors and they should be referred to as such.
 
The action taken by Commerce is dramatically different from the role of the compliance officer as it has evolved in the business world, and also differs from the role of independent monitors often appointed as part of deferred prosecution agreements and other negotiated settlements.
 
Compliance officers are employed by the corporation and are charged with ensuring that the organization and its employees operate lawfully and according to regulations. Compliance officers manage all seven elements of a compliance program that are described in 
Chapter 8 of the U.S. Sentencing Guidelines. These elements cover areas as diverse as hiring and training, policies and procedures, investigations, and remediation. Compliance programs focus on preventing, finding, and remediating compliance problems. Some of the most high-profile recent scandals at our universities and businesses would have been greatly minimized had effective compliance programs been in place.
 
Compliance officers lead the compliance program and are supported by other compliance professionals with a variety of common titles, such as compliance manager, compliance director, and compliance coordinator. A quick check of our own membership of 19,000 compliance professionals found almost 200 people with “compliance coordinator” as their title. And I’d be willing to bet none of them have a role remotely similar to what the Commerce Department has in mind.
 
Compliance programs and compliance officers are not “answerable” to a government agency. They serve the broad interests of the organization and the public, including a compliance interest that is shared with government agencies. With the ZTE action, this highly successful self-regulatory framework, which began in the United States and is now shared in several other parts of the world, is now potentially at risk. This action potentially blurs the lines between enforcement and compliance professionals in the eyes of boards, leadership, and external stakeholders. It is a disservice to the compliance profession and the business community.
 
I sincerely hope that this is simply an inaccurate choice of words and that Commerce corrects this in future communications, because referring to government-implanted enforcement monitors as compliance coordinators is wrong. A government agency implanting its own “compliance” unit violates the very logic behind the Sentencing Guidelines and virtually all of the subsequent interpretations of the Guidelines. Other government agencies have steered clear of providing organization-specific requirements for compliance programs, understanding that every organization is different and its compliance program should be customized accordingly.
 
Wrongdoing certainly needs to be addressed, penalties need to be paid, and internal compliance efforts increased.  And, sometimes enforcement bodies need to act with heavy hands, including ongoing auditing and monitoring of corporate compliance efforts.  The goal of all these efforts is to ensure compliance, but that doesn’t mean everyone involved should be called a compliance officer. Let’s call them what they are – government enforcement monitors.

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

COMM_a01
12. 
M. Volkov: “Episode 42 – How to Manage Your CEO on Compliance Issues”

(Source: 
Volkov Law Group Blog, 10 Jun 2018. Reprinted by permission.) 
 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, 240-505-1992. 
 
An increasing number of chief compliance officers report directly on a monthly basis to the Chief Executive Officer.  As the compliance profession has earned independence and empowerment, CCOs are now part of the C-Suite and need to develop a positive relationship with the CEO to support the company’s ethics and compliance program.
 
In doing so, CCOs need to ask themselves two important questions: 
  (1) what type of CEO does the company have?
  (2) how should the CCO position the ethics and compliance program to gain the maximum support from the CEO?
 
In 
this episode, Michael Volkov discusses strategies for a CCO to maximize the CEO’s support of the company’s ethics and compliance program.

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

COMM_a3
13.
R.C. Burns: “EU Commission Menacingly Threatens Toothless Blocking Regulation”

(Source: 
Export Law Blog, 8 Jun 2018. Reprinted by permission.)
 
* Author: R. Clifton Burns, Esq., Bryan Cave LLP, Wash DC, 
Clif.Burns@bryancave.com, 202-508-6067).
 
On June 6, the European Union Commission adopted a 
delegated regulation amending the Annex to 
Council Regulation (EC) No. 2271/96 of 22 November 1996.  Council Regulation (EC) No. 2271/96 is the notorious EU blocking regulation which forbids individuals and companies in EU member states from complying with the U.S. embargo on Cuba.   The Annex to that Regulation specifies the laws and regulations that are blocked.  The delegated regulation will add U.S. sanctions on Iran to the Annex, and it will 
go into force on August 6 unless, between now and then, the EU Council or Parliament objects.
 
As you might imagine, I think that this is a misguided, if not preposterous, response to the U.S. withdrawal from the Iran nuclear deal.  The blocking regulation, as currently applied to Cuba, has had no effect on the U.S. embargo on Cuba and has instead put businesses in the untenable position of having to decide whether to break U.S. law or EU law.  And, of course, we all know what decision businesses in this position have invariably made in the past and will continue to do so even in the face of the expanded scope of the blocking regulation.
 
And the reason for that is clear:  OFAC has imposed significant penalties for violating the Cuba sanctions even where the Company was required by the EU blocking regulation to violate those sanctions.  OFAC has ignored the existence of the statute and not even considered it a mitigating factor.  In fact, it could be argued that 
in at least one case it has considered it an aggravating factor if the European company was attempting to comply with the blocking regulation.  Companies measure the risk of the wrath of OFAC against the toothless enforcement of the EU blocking regulation and decide to bow down to their OFAC overlords, not their European ones.
 
The U.S. sanctions on Iran can apply to European companies in three situations.  First, the sanctions apply if the European company is a foreign subsidiary of a U.S. company.   Second, they apply if the European company causes the export of goods or services from the United States to Iran.  Third, there are “secondary” sanctions that will apply to certain activities unconnected to the US, like engaging in significant transactions with the Iranian shipping, ship-building and energy sectors.  The laws and regulations added to the blocking regulation would prohibit compliance with the U.S. sanctions in all three instances.
 
On the other hand, the Annex does not reach all instances of U.S. sanctions on Iran.  Many Iranian entities, such as Bank Saderat, Mahan Air and the Islamic Revolutionary Guard Corps are designated under the Global Terrorism Sanctions Regulations which are not mentioned in the amended Annex. Tidewater Middle East, which operates the port at Bandar Abbas, is designated under the Weapons of Mass Destruction Proliferators Sanctions Regulations, also not added to the amended Annex.
 
As with all blocking statutes, enforcing this will be a headache.  Article 5 provides that “no person referred to in Article 11 shall comply, … actively or by deliberate omission, with any requirement or prohibition … based on … the laws specified in the Annex.” So let’s say that an EU company decides not to invest in an Iranian oil field project. Was that because of the sanctions or because the company thought it was a bad investment for reasons unrelated to the sanctions, say fear of corruption or geopolitical risks? Suppose an EU company complies with a request from a US customer to provide a certificate that the goods being sold originate from an EU Member State. Is providing that certificate complying with the US law prohibiting U.S. companies from acquiring goods of Iranian origin or just accommodating a US customer’s desire for EU-origin goods?
 
Of course, the group of companies that the amendment really puts in a pickle are EU subsidiaries of U.S. companies. Article 11 states that the regulation applies to any “legal person incorporated within the Community.” Section 560.215 of the Iranian Transactions and Sanctions Regulations, now added to the Annex, makes it illegal for such EU subsidiary to engage in a transaction with Iran if it would be illegal for a U.S. person to engage in that same transaction.  These two provisions mean that sooner or later these companies will be in the unenviable position of deciding which law to break. And we know which law they will chose to break already, don’t we?
 
So what exactly does the EU think it’s accomplishing here? The blocking regulation has been in effect with respect to Cuba for 22 years with no appreciable effect on the Cuba embargo. Do the wise men and sages of the European Commission expect that Trump, when he hears of their bold amendment of the Annex, will burst into tears and beg to rejoin the Iran nuclear deal? Do they think this Amendment will cause OFAC to tear the Iranian Transactions and Sanctions Regulations into tiny pieces and scatter them over the Potomac River? Because none of these things is going to happen. You know what will happen? Sanctions lawyers will have a lot more work. That’s it.
 
Moral of the story (from Louis XIV):
“C’est toujours l’impatience de gagner qui fait perdre.”

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

MSEX/IM MOVERS & SHAKERS

MS_a214. SIA Announces 2018-2020 Board of Directors

(Source: Society for International Affairs (SIA), 
SIA-web@wildapricot.org
)

The Society for International Affairs has announced its 2018-2020 Board of Directors:
  • President: Marc Binder (ITC Strategies)
  • Vice President: Tom Donovan (Northrop Grumman)
  • Secretary/Treasurer: Blount Stewart (Raytheon)
  • Communications: Suzanne Kao (Deloitte Tax LLP)
  • Planning and Education: 
    • Sandra Cross (Huntington Ingalls Industries Inc.)
    • Carmella Thompson (Knowledge International, LLC)
    • Glenda Bass (Siemens Government Technologies, Inc.)
    • FranMarie Mulla (Moog Inc.)
    • Candace Goforth (Goforth Trade Advisors, LLC)
 
The Board would like to extend a special welcome to our newly elected board members (Glenda Bass, Candace Goforth and FranMarie Mulla) and recognize and thank our outgoing board members (Jennifer Weinel, Jeremy Huffman, and Jean Rosch) for their contributions to the SIA Board throughout the 2016-2018 term.
 

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

MS_a115. Monday List of Ex/Im Job Openings; 184 Jobs Posted This Week, Including 50 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

#
Agility; Atlanta, GA;
Export Compliance Administrator
;

# Agility; Queens, NY;
Air Export Coordinator
;
# Agility; Bensenville, IL;
 
Air Export Coordinator;
# 
Agility; Carson, CA; Ocean Export Coordinator;
# 
Agility; Houston, TX; Air Freight Export Coordinator;
# 
Agility; Houston, TX; Ocean Export Coordinator;
# 
Agility; Doral, FL; Air Export Coordinator;
# 
Agility; Boston, MA; Air Export Coordinator;
# 
Agility; Boston, MA; Ocean Export Coordinator;
# 
Agility; Bensenville, IL; Ocean Export Coordinator;

# Agility; Basel, Switzerland;
International Exhibition Coordinator;

# Agility; Genf, Switzerland; Ocean Freight Coordinator; 
# Agility; Genf, Switzerland; Ocean Freight Coordinator; 
# Agility; Coppel, TX; Air Import Coordinator;

# Agility; Carson, CA;
Air Import Coordinator;
#
 Agility; Bensenville, IL; 
Air Import Coordinator
; 
# Agility; Queens, NY; Air Import Coordinator; 
# Agility; Atlanta, GA; Air Import Coordinator; 
# Agility; Doral, FL; Air Import Coordinator;

# Agility; Burlingame, CA;
 
Ocean Import Coordinator;
# Agility; Carson, CA;  Ocean Import Coordinator;
# Agility; East Boston, MA; Entry Writer/Import Coordinator
;
# Agility; Bensenville, IL; Entry Writer Coordinator; 
# Agility; Carson, CA; Entry Writer Coordinator; 
# Agility; Dallas, TX;  Air Import Supervisor;
# Agility; Montreal, Canada; Customs Manager; 
# Agility; Montreal, Canada;  Customs Manager; 

#
 Agility; Montreal, Canada;  Customs Supervisor; 
* AMD; Austin, TX;
Manager, Import/Export; Requisition ID: 24061

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

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

#
Arm, Ltd.; Cambridge, UK; UK Trade Compliance Manager; Requisition ID: 13650

#
Arrow; Shanghai, China; Compliance Manager;

# Arrow; Shenzhen, Guangdong, China; Junior GTMC Officer;
* AutoNation; Fort Lauderdale, FL; Trade Compliance Manager
*
 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: 35809BR
* BAE Systems; Sterling, VA; Compliance Specialist Senior; Requisition ID: 36370BR

* BAE Systems; Greenlawn, NY;
International Trade Compliance Analyst I; Requisition ID: 
38433BR

* BAE Systems; San Diego, CA; International Trade Compliance Analyst II; Requisition ID: 38548BR  

*
 BMW North America; Woodcliff Lake, NJ;
Senior Analyst, Trade Compliance
; Requisition ID: 170004RD
* Brownells, Inc.; Grinnell, IA; International Trade Compliance Manager II;
* Brownells, Inc.; Grinnell, IA; Product Classification Specialist I;
* Buehler; Lake Bluff, IL;
Manager, Compliance and Logistics
; Requisition ID: 2018-004

* Cree, Inc.; Durham, NC; Export Compliance Specialist
Contact asignorelli@cree.com;
Requisition ID: 2018-6300

# Danaher Science and Technology; Nijmegen, Netherlands;
Import Specialist – Senior Analyst II Supply Chain & Logistics

Job ID: BEC009349

*
 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

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

*
 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

* Flash Global; Mountain Lakes, NJ; 
Import Export Services Manager;

* FLIR; Billerica, MA; US Customs Analyst
; 

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

* FLIR; Nashua, NH; 
Global Trade Compliance Analyst, Traffic
;
 
*
 FLIR; Billerica, MA;
Global Trade Compliance Analyst, Licensing
;
* Full Circle Compliance; Bruchem, Netherlands;
Legal Analyst, Manager

* General Atomics; San Diego, CA;
Director, Compliance
; Requisition ID: 18549BR

* General Atomics; San Diego, CA;
 Government Regulatory Compliance SpecialistRequisition ID: 18686BR

* General Atomics; San Diego, CA; 
Import/Export Trade Compliance Administrator – Licensing
Requisition ID: 17968BR

* General Atomics; San Diego, CA; Senior Director of Import/Export Compliance; Requisition ID: 13892BR
* General Atomics; San Diego, CA; Internal Auditor – Senior; Requisition ID: 17524BR

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

* Harris Corporation; Palm Bay, FL;
Technical Trade Compliance Engineer; Contact
Laura Solomon; Requisition ID: ES20171511-22019
* Harris Corporation; Clifton, NJ;
Technical Trade Compliance Engineer;

* 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

* Intel; Amsterdam, Netherlands;
Trade Specialist
Requisition ID: JR0056336

*
 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;

* Johnson Controls; Milwaukee, WI;
Trade Compliance Analyst; Requisition ID: 
WD30047348124
* Johnson Controls; Lithia Springs;
Trade Compliance Specialist I; Requisition ID: 
WD30047947142
* 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 

* Lincoln Electric; Cleveland, OH; 
Trade Compliance Manager;

* Lockheed Martin; Manassass, VA; International Licensing; Requisition ID: 423306BR
* 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; 
Senior International Licensing Analyst
; Requisition ID: 
434225BR 

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

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

* Raytheon Company; El Segundo, CA;
Global Trade Licensing Analyst; Requisition ID: 
114977BR
* Raytheon Company; El Segundo, CA; 
Global Trade Licensing Analyst
; Requisition ID: 115189BR 

* Raytheon Company; El Segundo, CA; 
Sr. Export Licensing And Compliance Specialist; Requisition ID: 114077BR
* Raytheon Company; Plano, TX; Import Control & Compliance Advisor; Requisition ID: 111596BR

* Raytheon Company; Tucson, AZ; 
Export Licensing And Compliance Specialist; Requisition ID: 
114936BR

*
 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
# The Safariland Group; Jacksonville, FL; Counsel (International Trade Compliance)
# The Safariland Group; Jacksonville, FL; Sr. Export Compliance Specialist 
* Spirent; San Jose, CA;
Global Trade Compliance Specialist
; Requisition ID: 4088

# Tech Data Corporation; Miami, FL; 
Sr. Regulatory Compliance Analyst
;

# Tech Data Corporation; Clearwater, FL; Sr. Regulatory Compliance Analyst;
# Tech Data Corporation; Groveport, OH; Sr. Regulatory Compliance Analyst;
# Tech Data Corporation; Duluth, GA; Sr. Regulatory Compliance Analyst;

# Tech Data Corporation; Miami, FL; Regulatory Compliance Manager;
# Tech Data Corporation; Clearwater, FL;  Regulatory Compliance Manager;
# Tech Data Corporation; Groveport, OH;  Regulatory Compliance Manager;
# Tech Data Corporation; Duluth, GA;  Regulatory Compliance Manager;

* Teledyne Benthos; Falmouth, MA; Export Compliance Manager
* Teledyne Scientific & Imaging; Montgomeryville, PA; Contracts & Trade Compliance Administrator; Requisition ID: 6470

*
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 Manager; Requisition ID:  62176BR

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

* 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

* Wurth Industry of North America; Indianapolis, IN;
International Trade Compliance Officer – Classification;

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

* Xylem, Inc; Morton Grove, IL;
Trade Compliance Specialist;
* YETI; Austin, TX;
Global Trade Compliance Manager
* Zebra Technologies; Bourne End, UK; 
Trade Compliance Manager, NALA; Requisition ID: 46144
* Zebra Technologies; Lincolnshire, IL; Holtsville, NY; Mcallen, TX; Miramar, FL; Agoura Hills, CA; 
Trade Compliance Manager, EMEA; Requisition ID: 46146
 

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

ENEDITOR’S NOTES

 
* Saul Bellow (Solomon Bellows; 10 Jun 1915 – 5 Apr 2005; was a Canadian-American writer. For his literary work, Bellow was awarded the Pulitzer Prize, the Nobel Prize for Literature, and the National Medal of Arts. He is the only writer to win the National Book Award for Fiction three times and he received the National Book Foundation’s lifetime Medal for Distinguished Contribution to American Letters in 1990. His best-known works include The Adventures of Augie March, Henderson the Rain King, Herzog, Mr. Sammler’s Planet, Seize the Day, Humboldt’s Gift, and Ravelstein.)
  – “When we ask for advice, we are usually looking for an accomplice.”
  – “Conquered people tend to be witty.”
 
* Ben Jonson (Benjamin Jonson; 11 Jun 1572 – 6 Aug 1637; was an English playwright, poet, actor, and literary critic, whose artistry exerted a lasting impact upon English poetry and stage comedy. He is generally regarded as the second most important English playwright after William Shakespeare.)
  – “Language most shows a man; speak that I may see thee.”

* Luis XVI (1754 – 1793), born 
Louis-Auguste
, was the last King of France before the fall of the monarchy during the French Revolution
.)
  – “C’est toujours l’impatience de gagner qui fait perdre.” (“It’s always the impatience to win that makes you lose.”)
 
Monday is pun day:
* Yesterday a clown held the door open for me. I thought it was a nice jester.
* It was a very emotional wedding. Even the cake was in tiers.
* There was an explosion at a cheese factory in France. De brie was everywhere!

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

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: 6 June 2018: 83 FR 26204-26205: Unverified List (UVL); Correction

  
*
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:
8 Jun 2018: Harmonized System Update 1809, containing 901 ABI records and 192 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.

* 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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