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18-0709 Monday “Daily Bugle”

18-0709 Monday “Daily Bugle”

Monday, 9 July 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/Census: “Exporting with Import Classification Numbers”
  3. Commerce/BIS: (No new postings.)
  4. State/DDTC: (No new postings.)
  5. EU Extends Restrictive Measures Concerning Russia Until 31 Jan 2019
  6. Hong Kong Releases Circular Concerning Chemical Weapons (Convention) Ordinance, Cap. 578
  1. EU Bulletin: “Remembering Crimea: EU Prolongs Sanctions Against Russia”
  2. Reuters: “As Anti-Money Laundering Reform Kicks In, EU Seeks to Close New Gaps”
  3. ST&R Trade Report: “E-Commerce Framework of Standards Adopted by WCO”
  1. D.M. Edelman: “China Sanctions – What You Can Do Now”
  2. M. Volkov: “Podcast Episode 46: Implementing a Policy Management Program”
  3. Page-Fura PC: “Section 301 Now In Effect: Impacts & Exclusions”
  1. Monday List of Ex/Im Job Openings: 222 Jobs Posted This Week, Including 10 New Jobs
  1. Full Circle Compliance Presents “Awareness Course U.S. Export Controls: ITAR & EAR From a Non-U.S. Perspective “, 2 Oct 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 Jun 2018), DOD/NISPOM (18 May 2016), EAR (6 Jun 2018), FACR/OFAC (29 Jun 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

[No items of interest noted today.]

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

OGSOTHER GOVERNMENT SOURCES

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

* DHS/CBP; NOTICES; Charter Renewals: 
Commercial Customs Operations Advisory Committee [Publication Date: 10 Jul 2018.]
* * * * * * * * * * * * * * * * * * * *

OGS_a2
2. 
Commerce/Census: “Exporting with Import Classification Numbers”

(Source: 
Global Reach Blog, 9 Jul 2018.) 
 
If you focus on U.S. trade compliance, you learn Schedule B numbers are U.S. export classification codes and Harmonized Tariff Schedule (HTS) numbers are U.S. import classification codes. Yet, as you may have discovered, HTS codes can also be used for exporting in most cases. In this blog, we are going to dive into the details of why this is true.
 
The first six digits of an HTS and Schedule B number will always be the same for a particular product. A key difference between the HTS and Schedule B 10-digit classification systems is the number of codes. There are approximately 19,000 HTS codes, compared to about 9,000 Schedule B codes. The additional detail for HTS classifications means multiple HTS numbers can correlate to a single Schedule B number. After you file your export shipment with an HTS number, we convert the HTS number to a Schedule B number for statistical purposes. Allowing dual use of HTS codes can save filers time in completing required forms.
 
Brass-Wind Instruments Example
 
Below are the HTS numbers for brass-wind instruments. As you can see, there are two codes for the instruments based on price.



In the Schedule B, only one code is available for brass-wind instruments.

 
We convert HTS codes 9205.10.0040 and 9205.10.0080 to Schedule B number 9205.10.0000 for statistical purposes.
 
Does it always work?
 
In most cases, HTS numbers have more detail than Schedule B numbers. However, there are goods where additional detail exists on the export side. Let’s look at aircraft turbines.
 
Aircraft Turbine Example
 
HTS numbers for turbojets with a thrust not exceeding 25kN have two options, aircraft turbines and other.



The Schedule B numbers for turbojets with a thrust not exceeding 25kN have more detail under aircraft turbines to differentiate between those used in civil aircraft and those not.
 



We cannot accept the aircraft turbine HTS number for an export shipment because the code does not provide the specific detail required by the Schedule B.

To know which HTS numbers cannot be used for export, see 
HTS codes that are not valid for Automated Export System on the 
Census Bureau’s Foreign Trade website.
 
Alternatively, the 
Notice to Exporters found in the Harmonized Tariff Schedule at the 
U.S. International Trade Commission website lists the Schedule B numbers needed for export in place of HTS numbers.
 
For more information about Schedule B classification, visit 
census.gov/scheduleb or contact the Micro Analysis Branch at 800-549-0595, option 2.

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

OGS_a33
Commerce/BIS: (No new postings.)

(Source: 
Commerce/BIS)

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

OGS_a44
State/DDTC: (No new postings.)

(Source: 
State/DDTC)

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

OGS_a55
EU Extends Restrictive Measures Concerning Russia Until 31 Jan 2019 

(Source: 
Official Journal of the European Union, 9 Jul 2018.)
 
Decisions
 

Council Decision (CFSP) 2018/964 of 5 July 2018 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine
 

[Read the related press release from the European Commission 
here.]

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

OGS_a66
Hong Kong Releases Circular Concerning Chemical Weapons (Convention) Ordinance, Cap. 578
(Source: 
Hong Kong Trade and Industry Department, Strategic Trade Controls Circular No. 7/2018, 9 Jul 2018.) 
 
* PURPOSE: This circular invites facilities which foresee that they would be engaged in specified activities involving Scheduled Chemicals controlled by the Chemical Weapons (Convention) Ordinance (“the Ordinance”) in 2019 to report details of their anticipated activities to the Director-General of Trade and Industry (“the Director”) by completing and returning the reply slip at 
Annex A on or before 23 July 2018.
* BACKGROUND: Strategic Trade Controls Circular No. 
17/2004 
issued by the Trade and Industry Department on 30 April 2004 informed the industry about the commencement of the Ordinance on 18 June 2004. The purpose of the Ordinance is to enable the Chemical Weapons Convention (“the Convention”), an international treaty that aims to prohibit the development, production, acquisition, stockpiling, retention, transfer and use of chemical weapons, to be fully implemented in the Hong Kong Special Administrative Region. Please refer to Strategic Trade Controls Circular No. 
14/2003 of 6 August 2003 for an overview of the requirements under the Ordinance.
* PERMIT AND REPORTING REQUIREMENTS: In accordance with the Ordinance, operators of facilities are required to obtain permits from the Director if the facilities are engaged in specified activities involving Scheduled Chemicals in quantities over the respective thresholds. Permit holders are also required under the Ordinance to lodge annual reports with the Director on their anticipated activities involving Scheduled Chemicals for the coming calendar year before the end of the current year, and their past activities during the previous year at the beginning of the current year. The information so collected will be used to compile annual declarations for submission to the Organization for the Prohibition of Chemical Weapons (OPCW) which was established to implement the Convention. Please refer to 
Annex B for the activities and quantity thresholds that trigger the permit and annual reporting requirements and 
Annex C for the list of Scheduled Chemicals.
* REPLY SLIP AND REPORT ON ANTICIPATED ACTIVITISE FOR 2019: The Department will send this circular to individual operators who may, according to our knowledge, be engaged in specified activities involving Scheduled Chemicals. Accordingly, operators who receive this circular by mail have to complete Parts I and III of the reply slip (at 
Annex A
) to indicate 
whether or not their facilities would be engaged in any specified activities involving Scheduled Chemicals in 2019 as set out in 
Annex B, which need to be reported. Please return the completed reply slip to us by fax (fax no. 2396 3070), by post or in person to Strategic Trade Controls Branch, Room 1619, 16/F, Trade and Industry Tower, 3 Concorde Road, Kowloon City, Hong Kong on or before 
23 July 2018. If operators are uncertain whether they need to report activities which will take place at their facilities in 2019, please provide relevant information by filling in Parts II and III of the reply slip and return it to us by 23 July 2018. We shall then assess and advise whether they are subject to the reporting requirements on the basis of the information provided.

  Any operator who indicates in Part I of the reply slip that the facility will be engaged in specified activities involving Scheduled Chemicals in 2019, or indicates the same in the information provided in Part II of the reply slip, please complete the 
designated report forms on anticipated activities and return them to us by post or in person to the above address or via electronic means by
 30 July 2018. For reports to be sent by electronic means, the operator should possess an organizational “e-Cert” issued by an approved Certification Authority, and send the report via email to 
cwc@tid.gov.hk. The designated forms to report anticipated activities can be downloaded from the Chemical Weapons (Convention) Ordinance 
Website, or obtained from the Strategic Trade Controls Branch of the Department at the above address.

  Operators who do not receive this circular by mail but believe that their facilities may be engaged in specified activities involving Scheduled Chemicals in 2019 are also welcome to provide details of the activities by completing and returning the reply slip at 
Annex A in the same way as mentioned in 
paragraph 4 above.

* IMPORTANT NOTE: Facilities subject to the permit or reporting requirements should comply with checks and inspections by officers of the Customs and Excise Department (“C&ED”). These checks mainly aimed at verifying and ensuring the accuracy of the information related to the permits and the material particulars in any reports lodged with the Director. Facilities are therefore reminded to ensure that the information they provide in their returns is accurate. In addition to checks and inspections by C&ED officers, inspection teams of the OPCW may also conduct inspection of facilities in order to verify any information passed to it about the facilities. Operators of the facilities are required to provide all the requisite records for the checks and inspections and to render necessary assistance and cooperation to the officers concerned.
* WARNING: The Ordinance specifies the acts which contravene the Ordinance and the penalties for such offences. It is an offence under the Ordinance if a person who is required to have a permit to operate his facility operates it without such a permit. The maximum penalty, on conviction, is a fine of $500,000 and imprisonment for 5 years. The Ordinance also provides that the Director may, by notice in writing, require a person to give information or documents relevant to a declaration required to be given to the OPCW. Any person who fails to comply with such a notice issued commits an offence and is liable on conviction to a fine of $100,000 and imprisonment for 1 year.
  In addition to the penalties mentioned above, the Trade and Industry Department may take administrative actions against parties committing the above offences. Such administrative actions may involve, but shall not necessarily be confined to, any or all of the following: refusal to grant permits, suspension or revocation of permits, and refusal to issue licences for imports or exports of chemicals.
* ENQUIRY: If you have any questions on the completion of the reply slip, the designated report forms on anticipated activities, or on the Ordinance itself, please contact Mr Jeff TO of the Department at telephone number 2398 5670 or by email at 
jeffto@tid.gov.hk.

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

NWSNEWS

NWS_a17

EU Bulletin: “Remembering Crimea: EU Prolongs Sanctions Against Russia”

(Source: 
EU Bulletin, 6 Jul 2018.) [Excerpts.] 
 
The European Union has prolonged the economic sanctions against Russia in response to its annexation of Crimea until January 2019. The decision came in response to the remarks by French President Emanuel Macron and German Chancellor Merkel to the European Council on the state of implementation of the Minsk agreements, to which the punitive measures targeting finance, energy and defense sectors are tied. The sanctions were first implemented in July 2014 for one year over Russia’s destabilizing activities in Ukraine.
 

The economic sanctions include curtailing Russian access to certain sensitive technologies and services that can be used for oil exploration and production, imposing an export and import ban on trade in arms, and establishing an export ban for dual-use goods for military end users in Russia. The EU has also limited access to EU primary and secondary capital markets for 5 major Russian majority state-run financial institutions including energy and oil companies. On top of the economic measures, Brussels is also targeting individual restrictive measures including a visa ban and an asset freeze currently against 155 people and 38 entities. Other types of restrictive measures include diplomatic measures, restrictions on economic cooperation and restrictions on economic activities with Crimea and Sevastopol. … 

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

NWS_28
Reuters: “As Anti-Money Laundering Reform Kicks In, EU Seeks to Close New Gaps”
(Source: 
Reuters, 9 Jul 2018.) 
 
New rules to tackle money laundering in the European Union took effect on Monday but the bloc already faces calls for further reforms as new shortcomings emerged after alleged wrongdoing at banks in Baltic states and Malta.
 
The fifth review of the EU anti-money laundering directive became binding on Monday after two years of EU talks to strengthen controls on the real owners of companies and digital payments, including virtual currencies.
 
But despite marking progress in the fight against large-scale fraudsters, the new rules could be born obsolete as they fail to address new gaps exposed by a series of banking scandals this year in Latvia, Estonia and Malta..
 
The adopted overhaul requires states to set up centralized bank account registers to smooth the work of security forces. But the national “financial intelligence units” remain weak and rarely cooperate, making it easier for criminals to get away with illegal proceeds when they transfer them across borders. 
 
A common supervision could be more effective.
 
“The Commission cannot hesitate any longer in bringing forward a legislative proposal for a European anti-money laundering authority,” EU lawmaker Sven Giegold said on Monday.
 
His call echoes demands from the European Central Bank’s top supervisor, Daniele Nouy, who has said EU rules do not give supervisors clear powers to pull banking licenses over alleged money laundering, or force the removal of bank board members if they do not pass a so-called “fit and proper” assessment.
 
The European Parliament has asked the ECB to step up its anti-money laundering checks under current rules before new reforms can be adopted.
 
The European Commission, which is in charge of proposing EU legislation, has responded to the growing pressure by setting up a group of banking watchdogs that is expected to improve “practical coordination of anti-money laundering supervision”.
 
Possible new ideas are expected by the end of the year, but a fresh legislative crackdown is unlikely until a new European Parliament takes office after next spring’s elections.
 
EU officials say in private that although there is a growing political will to act, it would be wiser to first judge the impact of the most recent rules once they are applied.
 
But this could take a while. EU member states have another 18 months to execute the overhaul at national level, and many of them could take much longer given the toothlessness of EU sanction proceedings against late or inadequate implementation.
 
Two-thirds of the EU governments have not yet applied the previous, fourth review of anti-money laundering rules which entered into force in 2015.
 
The new rules could also be late to address rapid changes in crypto currencies, which have been at times used for crime and money laundering.
 
The rules were drafted when Europe accounted for a minimal share of bitcoin and other crypto currency trading, but could be inadequate to handle the skyrocketing rise of this industry in Malta, the EU’s smallest state, where the largest global platforms have been moving since the beginning of the year. 

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

NWS_39

ST&R Trade Report: “E-Commerce Framework of Standards Adopted by WCO” 

(Source: 
Sandler, Travis & Rosenberg Trade Report, 9 Jul 2018.) 
 
At its recent annual session the World Customs Organization Council adopted a framework of standards on cross-border e-commerce designed to help WCO members develop e-commerce strategic and operational frameworks in cooperation with stakeholders. The WCO states that this framework will also be useful for members seeking to enhance existing frameworks to effectively meet the requirements of new and evolving business models.
 
Cross-border e-commerce is characterized by online initiation, cross-border transaction or shipment, physical goods, and destined to consumers (commercial and non-commercial). It offers a significant opportunity for the economic growth and competitiveness of nations by providing new growth engines, developing new trade modes, driving new consumption trends, and creating new jobs. On the other hand, the exponential growth of e-commerce, particularly the emergence of new trade patterns and the increased role of consumers in individual transactions, presents challenges to governments and businesses in terms of trade facilitation, safety and security, and accurate and efficient collection of duties and taxes.
 
The WCO has been active in working to develop a harmonized approach to e-commerce. In December 2017 the group’s Policy Commission adopted a resolution outlining specific principles and encouraging customs administrations to apply them. Earlier this year the WCO Working Group on E-Commerce held a preliminary discussion on data elements needed for effective risk management and speedy clearance of e-commerce shipments and approved an updated version of the Immediate Release Guidelines, which have been adapted to support the expeditious release and clearance of e-commerce shipments and parcels.

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COMMCOMMENTARY

COMM_a0
10. 
D.M. Edelman: “China Sanctions – What You Can Do Now”

(Source: 
Export Compliance Matters, 6 Jul 2018.)
       
* Author: Doreen M. Edelman, Esq., Baker Donelson LLP, 202-508-3460, 
dedelman@bakerdonelson.com.
 
July 6, 2018 will be remembered as China sanctions day.
 
And I hope it is the last China sanctions day although many believe the war has just begun. Here is what I have learned so far working with companies negatively affected by the China tariffs.
 
  – There is no real way to address (you may prefer to substitute the word “avoid’ or “reduce”) the duty for each imported item other than by reviewing the bill of materials and supply chain for each product. Companies undertaking this analysis have found that they may have incorrectly determined the country of origin for the product and or that they may have misclassified certain items.  This is a good reason to review your broker’s analysis for classifications that are on the sanctions list.
  – Some companies have used this time to conduct supply chain audits and have found that there are ways to alter the supply chain to import parts or components differently.
  – Others are taking this as the “push” needed to shift manufacturing out of China to Vietnam, Malaysia etc.  I hear that plane flights out of China to Vietnam are booked solid.
  – Some companies are taking advice regarding how to use bilateral and multilateral trade agreements to reduce duties and shift part of their manufacturing processes. This requires a legal analysis of what constitutes substantial transformation under both the trade agreements and U.S. import laws.
  – Others are challenging HTSUS classifications that do not make sense in today’s global world and in light of the current policy of the U.S. government. CBP values importers taking the role of “importer of record” seriously and reviewing HTSUS classifications. If you can correctly classify an item outside of a number on the sanctions products lists and you can support that classification by prior decisions, Explanatory Notes, HTSUS Notes, and policy, go for it.
  – Companies are REALLY concerned about the proposed second set of sanctions.  These will affect a greater number of companies and consumers so start reviewing the bills of material and supply chain now if you have not.
  – Finally, every company should ensure that its members of Congress understand the full extent the Chinese tariffs will have on your company’s employees and families. Do not be afraid to do this.  It is very important. If you want to work through a trade association or your attorney, they can both help you.  Have your data ready; number of employees at your company, number of families in their district/state; how much these duties will cost your company every month; how long you can sustain the increased costs before you have to raise your prices and/or breach contracts.  To help your members of Congress understand that the China sanctions affect the local economy, take a look at the 
Chamber of Commerce tool.  Trade may be a global issue but trade is ultimately a local concern- jobs and the community.

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COMM_a01
11. 
M. Volkov: “Podcast Episode 46: Implementing a Policy Management Program”

(Source: 
Volkov Law Group Blog, 8 Jul 2018. Reprinted by permission.) 
 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, 240-505-1992. 
 
Companies have to implement a robust policy management program.  In today’s risky environment, companies should automate a robust policy management program that requires regular review, assessment and updating of policies and procedures.  A policy management program should be created consisting of key constituencies to ensure that policies and procedures are current, effective, and appropriately tailored to the company’s risk profile.
 
In 
this episode, Michael Volkov outlines considerations in establishing and implementing a robust policy and procedures management program.

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

COMM_a3
12. 
Page-Fura PC: “Section 301 Now In Effect: Impacts & Exclusions”

(Source: Page-Fura PC, 
pfpcnews@pagefura.com, 9 Jul 2018.)
 
As of 12:01am Eastern on 6 July, punitive tariffs in the amount of 25% were imposed by the Trump Administration on ”
List 1” comprised of 818 distinct tariff line items of Chinese origin.  This decision is the result of a 
Report issued by the U.S. Trade Representative on March 22, 2018, finding that China’s acts, policies and practices with respect to technology transfer, intellectual property and innovation were both unreasonable and discriminatory and a hindrance to U.S. commerce.  A number of puzzle pieces have fallen into place with that decision, a synopsis of which follows below.
 
(1) Import Procedures
 
With the Administration’s determination, and as set forth in 
CSMS #18-000419, these 818 tariff items must now be entered under new HTSUS Tariff Item 9903.88.01 to ensure application of the 25% rate.  As expected, U.S. Customs & Border Protection (“CBP”) has begun to closely scrutinize entry filings of Chinese origin products classified in tariff provisions outside of the identified 818, as well as increased declarations from other countries of the identified 818, to confirm that no circumvention of the tariffs is occurring.  Importers should expect that scrutiny to continue indefinitely and ensure that they retain all supporting documentation to support both classifications and origin in the event their entries are questioned.  Given that microscope, close coordination among trade compliance, product engineering/development and purchasing/sourcing is essential to avoid any unnecessary delays and/or inquiries.
 
(2) China Retaliation
 
As expected, China – after vowing not to “start the trade war” – retaliated in kind upon the Trump Administration’s decision to proceed with the Section 301 action.  Based on 
Taxation Committee Announcement [2018] No. 5 issued by China’s Ministry of Finance (“MOFCOM”) on June 16, 2018, the original list of targeted tariff items identified in MOFCOM’s April 4, 2018 
Announcement 34 was revised into two groups:
 
  – An initial 
545 commodities for which tariffs were imposed as of July 6
th; and
  – A further 
114 commodities for which tariffs will be imposed should the U.S. proceed with further Section 301 action.
 
In all instances, the commodities in China’s initial grouping are now subject to a 25% tariff in addition to all other duties and taxes incurred.  Importantly, MOFCOM’s Notice also states that all “current taxation, tax reduction and exemption policies remain unchanged.”  Finally, besides identifying the impacted tariff provisions, the notice also provides important information as to the formula to be used in determining the ultimate amount owed.
 
(3) Exclusion Requests on the 818
 
Although the Section 301 punitive tariffs have now gone into effect, USTR has simultaneously issued a 
Federal Register Notice announcing the procedures by which “interested persons” (inclusive of trade associations) may seek exclusions from the effects of this action.  Product exclusion requests may be made up to and including October 9, 2018, with the public having 14 days from the date the request is posted within which to submit rebuttal comments.  A final round of additional comments will then be offered for 7 days thereafter.
 
While not mandatory, USTR has stated its preference that any requests that are filed be submitted on the 
form posted on their website as uploaded under docket number USTR-2018-0025 found on 
www.regulations.gov.  Any request that is submitted must address a number of key considerations including:
 
  – Identification of the particular product in terms of the physical characteristics (e.g., dimensions, material composition, or other characteristics) that distinguish it from other products within the covered 8-digit subheading.  This is information that will be shared publicly and cannot be based solely on trademarks, tradenames or use;
  – The 10-digit subheading under which the product is classified;
  – The ability of CBP to administer the exclusion;
  – The annual quantity and value (if known) of the Chinese-origin product that the requester purchased in each of the last three years.  If that information is not available, an estimate (with an explanation of the basis for that estimation) may instead be provided;
  – Whether the particular product is available only from China or may also be obtained from either the United States or a third country;
  – Whether the imposition of additional duties on the product would cause severe economic harm to the requester or other U.S. interests; and
  – Whether the particular product is strategically important or related to ”
Made in China 2025 Plan” or other Chinese industrial programs.
 
Any exclusion request that is accepted will apply retroactively to 6 July.  Exclusions will apply for one year, after which a new request for exclusion would need to be filed.  In addition, as noted on the
Press Release on the USTR website, because exclusions will be made on a product basis, a particular exclusion will apply to all imports of the product, regardless of whether the importer filed a request.
 
(4) Opportunities for Mitigation
 
Besides attempting to secure a product exclusion, several important programs remain in place as a potential means of militating against this additional cost.  Those include:
 
Chapter 98 Declarations. CBP’s CSMS makes it clear that the 25% tariff assessed under Tariff Item 9903.88.01 shall not apply to products that properly qualify under a provision of Chapter 98.  In order to benefit from these provisions, Tariff Item 9903.88.01 must first be reported, followed by the applicable Chapter 98 subheading and the Chapter 1-97 HTSUS classification for the commodity being imported.
 
Duty Drawback. Besides continued eligibility under Chapter 98, commodities subject to Section 301 punitive tariffs remain eligible for duty drawback.  While this will still require an outlay of the 25% tariff at the time of entry and there will obviously be a delay between the time of duty payment and that of duty recovery, for companies with an active import-to-export program, the adverse financial impact of Section 301 may be mitigated.
 
Foreign-Trade Zones. As for zone users, any merchandise that falls within one of the 818 identified tariff provisions and that was admitted into a foreign-trade zone (“FTZ”) on or after 12:01am Eastern on 6 July must now be admitted in “privileged foreign” or “PF” status to ensure applicability of the Section 301 tariff (in addition to any other tariff that might otherwise be imposed) at the time of zone withdrawal for consumption.  Note that it is only withdrawals for consumption that is impacted as any in-bond withdrawal for export remains unaffected by this action.
 
Moreover, while there was apparently some confusion regarding the status of inventory that had been admitted into a FTZ prior to the effective date/time, CBP officials have confirmed that no previously-admitted merchandise that was admitted in PF status is impacted by this action.  As a result, there is no requirement or obligation to re-characterize any existing Chinese origin inventory as PF from a previous non-privilege foreign (“NPF”) designation and any previously-admitted Chinese origin merchandise in PF status should remain exempt from imposition of Section 301 punitive tariffs at the time of zone withdrawal for consumption.  CBP has acknowledged that errors could occur in the processing of zone entries, so zone users must ensure that they have comprehensive records reflecting the date and time any otherwise-impacted merchandise was admitted into the zone, and that their inventory control and recordkeeping system is properly tracking and decrementing all merchandise as it moves through the zone environment.
 
Tariff Review/Engineering. Finally, besides any programs or preferences that importers might try to use, companies should also carefully evaluate both their current tariff classifications as well as their production and sourcing practices to verify whether there is an opportunity to modify any existing classification to remove the underlying product from the scope of the Section 301 action.  As a general principle, merchandise entered into the Commerce of the United States is “classified in its condition as imported.”  Companies should determine, therefore, whether any cost-effective changes may be made in the condition of impacted products prior to importation in order to remove them from these tariffs.  Similarly, companies should also carefully review the current classifications assessed against those same products to determine whether a plausible argument exists to revise those classifications at this time.  Please bear in mind that any changes made from either a production or pure classification perspective could draw additional attention from CBP so any such determination must be adequately supported under the law in order to avoid the risk of a CBP enforcement action.
 
The Remaining 284. As for the remaining 284 tariff items identified on ”
List 2” for the potential future imposition of Section 301 punitive tariffs, as noted previously, USTR is currently accepting comments as to whether those further products of Chinese origin should also be subject to this action.  While the date for filing a request to appear has already passed, the following dates remain pertinent:
 
  – July 23, 2018: Due date for submission of written comments;
  – July 24, 2018: Public Hearing before The Section 301 Committee; and
  – July 31, 2018: Due date for submission of post-hearing rebuttal comments.
 
Comments should be submitted through 
HERE with reference to docket number USTR-2018-0018 and must focus solely on commodities addressed in the supplemental list.  Further details on this process, including the submission of confidential business information, may be found 
HERE.
 
Please let us know if you have any questions regarding this update, as well as any support we might provide in the submission of comments on either the supplemental list or any exclusion requests.

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MSEX/IM MOVERS & SHAKERS

MS_a113. Monday List of Ex/Im Job Openings; 222 Jobs Posted This Week, Including 10 New Jobs

(Source: Editor) 
 

Published every Monday or first business day of the week. Please, send job openings in the following format to 
jobs@fullcirclecompliance.eu
.

 
* COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFORMATION; REQUISITION ID
 

#
” New or amended listing this week

* ACCO Brands; Lake Zurich, IL; Foreign Trade Zone Specialist;
* Aerovironment; Simi Valley, CA; Trade Compliance Specialist II; Job ID: 18-017

# Aerojet Rocketdyne; Huntsville, AL; 
International Trade and Compliance Specialist;

# Aerojet Rocketdyne; Camden, AR;
International Trade and Compliance Specialist;

* 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

# Arconic; Flexible, USA; Trade Compliance Administrator;
# Arconic; Torrance, CA; Global Trade Compliance Manager – Import;
* 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: 2018-630
0

# Curtiss-Wright; Chanhassen, MN;
Logistics & Compliance Specialist; Requisition ID: 2835

* 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

 * Edmonds Enterprise Services, Inc.; Washington, D.C.;
Compliance Specialist
Department of State; tmarshall@edmondses.com; (703) 778-7070
* Edmonds Enterprise Services, Inc.; Washington, D.C.; Commodity Jurisdiction Analyst II; Department of State; tmarshall@edmondses.com; (703) 778-7070 

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

* Eli Lilly and Co.; Indianapolis, IN;
Import/Export Trade Associate;

* Ensign-Bickford Aerospace & Defense Co.; Moorpark, CA;
Import/Export Specialist; Missy Clark;
maclark@eba-d.com 

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

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

* Harris Corporation; Van Nuys, CA; Trade Compliance Senior Specialist; Requisition ID: ES20180706-25145
* 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
# Komatsu; Milwaukee, WI; Senior International Trade Compliance AnalystRequisition ID: 12728
* 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;
# Mercury Systems; Andover, MA; International Trade Compliance Director; Requisition ID: 18-165
* 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

* Muscogee International, LLC; Washington, D.C.;
DDTC Compliance Specialist II; Apply
HERE or contact their
recruiting team.
* Muscogee International, LLC; Washington, D.C.; 
DDTC Registration Analyst III
Apply HERE or contact their recruiting team.

* Muscogee International, LLC; Washington, D.C.;
DDTC Policy Analyst
Apply 
HERE
 or contact their 
recruiting team
.
* Muscogee International, LLC; Washington, D.C.; 
DDTC Records Auditor
Apply HERE or contact their recruiting team.
* Muscogee International, LLC; Washington, D.C.; DDTC Contract AnalystApply HERE or contact their recruiting team.

* Muscogee International, LLC; Washington, D.C.; 
DDTC Service Support Desk Lead
Apply 
HERE
 or contact their 
recruiting team
.
* Muscogee International, LLC; Washington, D.C.; 
DDTC Service Support Desk
Apply HERE or contact their recruiting team.
* Muscogee International, LLC; Washington, D.C.; DDTC Office Support IApply HERE or contact their recruiting team.
* Muscogee International, LLC; Washington, D.C.; DDTC Office Support IIApply HERE or contact their recruiting team.

* Muscogee International, LLC; Washington, D.C.; DDTC Office Support IIIApply HERE or contact their recruiting team.

* MTS Systems; Eden Prairie, MN;
Global Trade Compliance Manager
; Requisition ID: 37841

* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2; Requisition ID: 18010381

* Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2

Requisition ID

17022803
 
 

*
 Northrop Grumman; Herndon, VA;
Manager, International Trade Compliance 2
; Requisition ID: 17022805
* Northrop Grumman; McLean, VA; International Trade Compliance Analyst 3; Requisition ID: 18012973
* Northrop Grumman; Herndon, VA; International Trade Compliance Analyst 3; Requisition ID: 18007859
* Northrop Grumman; San Diego, CA; International Trade Compliance Analyst 2; Requisition ID: 18012561

* Northrop Grumman; Redondo Beach, CA; or Rancho Bernardo, CA; or Melbourne, FL; or Falls Church, VA; 
Sr. Manager, International Trade Compliance; Requisition ID: 18012105; Contact Fred Czarske at 310.332.7606,
fred.czarske@ngc.com.

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

* Oracle; Unspecified, United States; Customs Compliance Specialist; Requisition ID: 18000H0N
* Oshkosh Corporation; Greenville, WI;
Global Trade Compliance Analyst
; Requisition ID: 182405

* PerkinElmer, Inc.; Shelton, CT;
Systems Analyst, Trade Compliance Solutions;
# PerkinElmer, Inc.; Shelton, CT;
International Trade Compliance Analyst – Export Coordinator
Requisition ID: 
JR-001256
#
 PerkinElmer, Inc.; Hopkinton, CT;  
International Trade Compliance Analyst – Export Coordinator
; Requisition ID: JR-001256
# PerkinElmer, Inc.; Singapore; ITC Specialist; Requisition ID: JR-003936

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

* Raytheon; El Segundo, CA; 
Sr. Export Licensing And Compliance Specialist; Requisition ID: 114077BR
* Raytheon; Tucson, AZ; Export Licensing And Compliance Specialist; Requisition ID: 114936BR 
* Raytheon; El Segundo, CA; Senior Principle, Global Trade Licensing; Requisition ID: 117232BR 
* Raytheon; El Segundo, CA; Manager III, Global Trade Licensing; Requisition ID: 117235BR 
* Raytheon; El Segundo, CA; Fullerton, CA; Goleta, CA; Aberdeen, MD; Plano, TX; McKinney, TX; Principal Analyst, Global Trade Licensing; Requisition ID: 117247BR 
* Raytheon; El Segundo, CA; Aberdeen, MD; McKinney, TX; Global Trade Licensing Analyst; Requisition ID: 116976BR 
* Raytheon; El Segundo, CA; Ft. Wayne, IN; Aberdeen, MD; Global Trade Licensing Analyst; Requisition ID: 118159BR

*
 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 
* Stockholm International Peace Research Institute (SIPRI); Solna, Sweden; Senior Researcher on Dual Use and Arms Trade Controls
* 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
* Teva Pharmaceuticals; North Wales, PA; 
Senior Analyst, Customs & Trade Compliance
;

*
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
* 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
;

* Vigilant; Negotiable Location, USA;  
Global Trade Account Manager
;
* Vigilant; Budapest, Hungary; 
Jr. 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

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

TECEX/IM TRAINING EVENTS & CONFERENCES

TEC_a114

Full Circle Compliance Presents “Awareness Course U.S. Export Controls: ITAR & EAR From a Non-U.S. Perspective”, 2 Oct in Bruchem, the Netherlands
(Source: Full Circle Compliance, events@fullcirclecompliance.eu.)
Our next academy course is specifically designed for beginning compliance officers and professionals who want to enhance their knowledge on the latest ITAR/EAR requirements and best practices.  The course will cover multiple topics regarding U.S. export controls that apply to organizations outside the U.S., such as: the regulatory framework, including the latest and anticipated regulatory amendments, key concepts and definitions, classification and licensing requirements, handling (potential) non-compliance issues, and practise tips to ensure compliance with the ITAR and EAR.

* What: Awareness Course U.S. Export Controls: ITAR & EAR From a Non-U.S. Perspective 
* When: Tuesday, 2 Oct 2018, 9 AM – 5 PM (CEST)
* Where: Landgoed Groenhoven, Bruchem, the Netherlands
* Sponsor: Full Circle Compliance (FCC)
* Instructors: Ghislaine Gillessen, Mike Farrell, and Alexander P. Bosch 
* Information & Registration: HERE or via events@fullcirclecompliance.eu

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

ENEDITOR’S NOTES

 

John D. Rockefeller (John Davison Rockefeller Sr.; 8 Jul 1839 – 23 May 1937; was an American oil industry business magnate, industrialist, and philanthropist. He is widely considered to have been the wealthiest American of all time, and the richest person in modern history.)
 – “Don’t be afraid to give up the good to go for the great.”
  – “Charity is injurious unless it helps the recipient to become independent of it.
 

Simone de Beauvoir
 (Simone Lucie Ernestine Marie Bertrand de Beauvoir; 9 Jan 1908 – 14 Apr 1986; was a French writer, intellectual, existentialist philosopher, political activist, feminist, and social theorist. Though she did not consider herself a philosopher, she had a significant influence on both feminist existentialism and feminist theory. De Beauvoir was known for her 1949 treatise, The Second Sex, a detailed analysis of women’s oppression, and a foundational tract of contemporary feminism.)
  – 
Change your life today. Don’t gamble on the future, act now, without delay.
  – “
To catch a husband is an art; to hold him is a job.”

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

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 Jun 2018: 83 FR 27380-27407: Air Cargo Advance Screening (ACAS)
 
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: 29 June 2018: 83 FR 30541-30548: Global Magnitsky Sanctions Regulations; and 83 FR 30539-30541: Removal of the Sudanese Sanctions Regulations and Amendment of the Terrorism List Government Sanctions Regulations 

 
*
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_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.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

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