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18-0730 Monday “Daily Bugle”

18-0730 Monday “Daily Bugle”

Monday, 30 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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  1. NRC Seeks Comments on Form 405F, 10 CFR Part 95, Facility Security Clearance and Safeguarding of National Security Information and Restricted Data 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. GAO: “Foreign Military Sales: Financial Oversight of the Use of Overhead Funds Needs Strengthening”
  4. State/DDTC Temporarily Modifies Category I of the USML
  5. EU Amends Union Customs Code Concerning Definition of Exporter
  6. EU Amends Restrictive Measures Concerning Iraq
  7. Dutch Ministry of Foreign Affairs Posts Factsheet on Export Control in the Cloud
  1. Expeditors News: “WCO Publishes 2018 Edition of Safe Framework of Standards”
  2. ST&R Trade Report: “Guidance on Product Exclusions for Section 232 Steel and Aluminum Tariffs”
  1. M. O’Kane: “Germany Drops Sanctions on Turkey, USA Threatens Turkey Sanctions for Detention of US Pastor”
  2. M. Volkov: “Episode 49 – Data Breach Notification in the GDPR Era”
  1. Monday List of Ex/Im Job Openings: 172 Jobs Posted This Week, Including 17 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

1
. NRC Seeks Comments on Form 405F, 10 CFR Part 95, Facility Security Clearance and Safeguarding of National Security Information and Restricted Data

(Source: Federal Register, 30 July 2018.) [Excerpts.]
 
83 FR 36633: Information Collection: 10 CFR Part 95, Facility Security Clearance and Safeguarding of National Security Information and Restricted Data
* AGENCY: Nuclear Regulatory Commission.
* ACTION: Notice of submission to the Office of Management and Budget; request for comment.
* SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) has recently submitted a request for renewal of an existing collection of information to the Office of Management and Budget (OMB) for review. The information collection is entitled, “10 CFR Part 95, Facility Security Clearance and Safeguarding of National Security Information and Restricted Data.”
* DATES: Submit comments by August 29, 2018.
* ADDRESSES: Submit comments directly to the OMB reviewer at: OMB Office of Information and Regulatory Affairs (3150-0047), Attn: Desk Officer for the Nuclear Regulatory Commission, 725 17th Street NW, Washington, DC 20503; email: oira_submission@omb.eop.gov.
* FOR FURTHER INFORMATION CONTACT: David Cullison, NRC Clearance Officer, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; telephone: 301-415-2084; email: INFOCOLLECTS.Resource@nrc.gov.
* SUPPLEMENTARY INFORMATION: …
   – The title of the information collection: “10 CFR Part 95, Facility Security Clearance and Safeguarding of National Security Information and Restricted Data.”
  – OMB approval number: 3150-0047.
  – Type of submission: Revision.
  – The form number if applicable: NRC Form 405F.
  – Abstract: The NRC-regulated facilities and their contractors who are authorized to access and possess classified matter are required to provide information and maintain records to ensure an adequate level of protection is provided to NRC classified information and material.
 
  Dated at Rockville, Maryland, this 24th day of July 2018.
  For the Nuclear Regulatory Commission.
David C. Cullison, NRC Clearance Officer, Office of the Chief Information Officer.

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

OGSOTHER GOVERNMENT SOURCES

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

* President; ADMINISTRATIVE ORDERS; Lebanon; Continuation of National Emergency (Notice of July 27, 2018) [Publication Date: 31 July 2018.]
 
* U.S. Customs and Border Protection; PROPOSED RULES; Modernized Drawback [Publication Date: 2 August 2018.]

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

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

 
What GAO Found
 
The Defense Security Cooperation Agency (DSCA) has established some policies and procedures for financial oversight of Department of Defense (DOD) components’ use of Foreign Military Sales (FMS) administrative funds for costs related to processing FMS cases, but GAO found certain deficiencies in its oversight. As part of its oversight, DSCA has taken steps such as clarifying guidance on how administrative funds may be used, and developing procedures for reviewing business processes for the use of these funds. DSCA, however, lacks the reliable funding data it needs to ensure proper spending and to inform its budget decisions. DSCA has not conducted regular reconciliations of the data, with its financial service provider, to identify and correct data reliability issues, including gaps and inconsistencies in reported spending for the Army, the Navy, and the Air Force-the primary recipients of this funding. While DSCA conducts reviews of DOD components’ business processes, providing an opportunity for sharing information about positive practices and identifying potential problems, it has not followed its annual minimum requirement for the number of reviews to conduct, or its requirement for tracking corrective action items. For example, DSCA was unable to provide an update on the status of action items from most of its reviews conducted since 2012. Moreover, DSCA does not conduct periodic, targeted financial reviews to verify components’ obligations and disbursements of administrative funds, raising the risk of misuse of funds.
 
DSCA also has not developed adequate processes for financial oversight of the use of contract administration services (CAS) funds for costs such as contract management, in accordance with internal control standards. Specifically, DSCA lacks reliable data on DOD components’ use of CAS funds. GAO identified inconsistencies in DSCA’s data, including no, or low, reported disbursements in some years for three of the four DOD components that received CAS funds in fiscal years 2012 through 2016, which did not align with data that GAO obtained from the components. DSCA has not conducted regular reconciliations of the data, with its financial service provider, to identify and correct data reliability issues. In addition, DSCA does not conduct periodic, targeted financial reviews to verify components’ CAS spending. For example, GAO found that at least $89 million in fiscal year 2016 CAS disbursements were incorrectly processed for the Defense Contract Management Agency- the primary recipient of these funds. DSCA periodically communicates with DOD components about problematic issues, but generally does not take steps to verify spending, including reviewing supporting documentation and any actions taken by components to address such issues. As a result, DSCA raises the risk of unallowable or unapproved payments that could lead to fraud, waste, or abuse of funds.
 
Why GAO Did This Study
 
The U.S. government sells defense equipment and services worth billions of dollars to foreign partners through the FMS program. DSCA has overall management responsibility for the program, and various other DOD components are responsible for implementing and supporting it. DSCA charges purchasers certain overhead fees for FMS operating costs, including the administrative fee and the CAS fee. Overall administrative expenditures were $879 million in fiscal year 2017. Overall CAS expenditures were $182 million in fiscal year 2015-the most recent year available with reliable total balance data. In past audits, GAO and the DOD Office of Inspector General raised questions about DOD’s financial oversight of these funds.
House Report 114-537 and Senate Report 114-255 included provisions that GAO review DSCA’s use of these funds. This report examines DSCA’s financial oversight of DOD components’ use of (1) administrative and (2) CAS funds. GAO assessed the reliability of DSCA data for fiscal years 2012 through 2016 (the most recent available) on DOD components’ use of these funds. GAO reviewed documentation and conducted interviews with agency officials.
 
What GAO Recommends
 
GAO is making 11 recommendations for DSCA to improve its financial oversight of administrative and CAS funds, such as by collecting reliable data on DOD components’ use of these funds, and conducting periodic, targeted financial reviews. DOD concurred with GAO’s 11 recommendations.
 
For more information, contact Thomas Melito at (202) 512-9601 or MelitoT@gao.gov.
 
The entire report can be found here.

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

(Source:
State/DDTC, 27 July 2018.)
 
Consistent with the International Traffic in Arms Regulations (“ITAR”), 22 C.F.R. § 126.2, the Acting Deputy Assistant Secretary for Defense Trade Controls has determined that it is in the interest of the security and foreign policy of the United States to temporarily modify United States Munitions List (“USML”) Category I to exclude the following technical data identified in the Settlement Agreement for the matter of Defense Distributed, et al., v. U.S. Department of State, et al, Case No. 15-cv-372-RP (W.D. Tex.) (hereinafter “Defense Distributed“):
 
  – “Published Files,” i.e., the files described in paragraph 25 of the Second Amended Complaint in Defense Distributed.
  – “Ghost Gunner Files,” i.e., the files described in paragraph 36 of the Second Amended Complaint in Defense Distributed.
  – “CAD Files,” i.e., the files described in paragraph 40 of the Second Amended Complaint in Defense Distributed.
  – “Other Files,” i.e., the files described in paragraphs 44-45 of the Second Amended Complaint in Defense Distributed, insofar as those files regard items exclusively: (a) in Category I(a) of the USML, as well as barrels and receivers covered by Category I(g) of the USML that are components of such items; or (b) items covered by Category I(h) of the USML solely by reference to Category I(a), excluding Military Equipment.  Military Equipment means (1) Drum and other magazines for firearms to .50 caliber (12.7 mm) inclusive with a capacity greater than 50 rounds, regardless of jurisdiction of the firearm, and specially designed parts and components therefor; (2) Parts and components specially designed for conversion of a semi-automatic firearm to a fully automatic firearm; (3) Accessories or attachments specially designed to automatically stabilize aim (other than gun rests) or for automatic targeting, and specially designed parts and components therefor.
 
This temporary modification will remain in effect while the final rule referenced in paragraph 1(a) of the Settlement Agreement is in development.
 
Please see the Settlement Agreement and the Second Amended Compliant for additional information.

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

(Source:
Official Journal of the European Union, 30 July 2018.)
 
Regulations:
* Commission Delegated Regulation (EU) 2018/1063 of 16 May 2018 amending and correcting Delegated Regulation (EU) 2015/2446 supplementing Regulation (EU) No 952/2013 of the European Parliament and of the Council as regards detailed rules concerning certain provisions of the Union Customs Code

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

(Source:
Official Journal of the European Union, 30 July 2018.)
 
Regulations:
* Commission Implementing Regulation (EU) 2018/1066 of 27 July 2018 amending Council Regulation (EC) No 1210/2003 concerning certain specific restrictions on economic and financial relations with Iraq

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

(Source:
Rijksoverheid, 30 July 2018.) [In Dutch.]
 
This factsheet discusses how to handle export-controlled technology in a cloud environment. The factsheet (in Dutch) can be found here.

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

NWSNEWS

(Source:
Expeditors News, 27 July 2018.)
 
On July 26, 2018, the World Customs Organization (“WCO”) published the 2018 edition of the SAFE Framework of Standards, following the June adoption by the WCO’s highest decision-making body.
 
According to the WCO, the Framework provides international standards to secure and facilitate global trade, and is updated every three years to keep it relevant. The 2018 version strengthens the objective of cooperation between Customs administrations through:
 
  – The exchange of information;
  – Mutual recognition of controls;
  – Mutual recognition of Authorized Economic Operators (AEOs);
  – Mutual administrative assistance.
 
Included in the latest version is a comprehensive list of AEO benefits.
 
WCO Secretary General Dr. Kunio Mikuriya said, “All WCO Members and stakeholders should deepen the implementation of the SAFE Framework and its associated tools in an effective and harmonized manner to further strengthen supply chain security and facilitation, by leveraging the collective lessons learned thus far and the new opportunities outlined in the 2018 edition of the Framework.”
 
The WCO press release may be found
here.
 
The 2018 edition of the SAFE Framework of Standards may be found
here.

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

(Source:
Sandler, Travis & Rosenberg Trade Report, 30 July 2018.)
 
The Bureau of Industry and Security and U.S. Customs and Border Protection have made available the following guidance on obtaining and utilizing product exclusions from the 25 percent additional tariff on steel and the 10 percent additional tariff on aluminum being imposed for national security reasons under Section 232 of the Trade Expansion Act of 1962.
 
(Click here for ST&R’s web page providing comprehensive information on all U.S. tariffs imposed under Section 301 and Section 232 as well as the retaliatory tariffs trading partners are levying on U.S. goods.)
 
Exclusion Criteria. A product exclusion will be granted if the article is not produced in the U.S. in a sufficient and reasonably available amount of satisfactory quality or if there is a specific national security consideration warranting an exclusion.
 
Review Process. The Department of Commerce reviews each request for conformance with the submission requirements. Once a request is posted there is a 30-day comment period.
If there are no objections, CBP reviews the HTSUS number cited for accuracy. If CBP determines the number is inaccurate the request is denied and the requester is provided with CBP contact information. If the number is accurate the request is approved if there are no national security concerns and the decision is posted on
www.regulations.gov.
 
If objections are submitted the DOC reviews each objection for conformance with the submission requirements. If an objection is posted the DOC reviews the request and the objection(s) and determines whether the item meets the above exclusion criteria.
 
Exclusion Notifications
. All product exclusion decisions will be posted on www.regulations.gov. For each exclusion request the DOC will post a decision memo identifying whether the request is granted or denied.
 
If the request is denied due to an incorrect HTSUS number the memo provides information how on to obtain a correct classification from CBP. After the correct classification is obtained the requester may resubmit the request, noting that it is a resubmission with a revised classification and attaching the CBP determination.
 
If the request is denied for other reasons the memo will state the reason. If the denial is based on an objection the requester may file a new request and include information documenting the reason the new request should be granted notwithstanding the prior objection(s); e.g., the inability or refusal of the objector(s) to provide the product.
 
Using Exclusions. Granted exclusions will be effective five days after the decision has been posted on
www.regulations.gov. An exclusion is generally granted for one year from the date of signature and will not be revoked unless the DOC has determined that submitted information was falsified. The use of an exclusion by any entity other than the organization that filed the original request is prohibited.
 
CBP will receive a notification from the DOC of any specific company and product to be excluded from the applicable tariff. The approved importer of record’s name, address, and IOR number, as well as the associated product exclusion number, must be
submitted to CBP before the importer of record submits the exclusion number with entries to CBP. The product exclusion number is based on the last six digits of the product exclusion docket number at
www.regulations.gov and should be submitted in the importer additional declaration field (54 record) of the entry summary data based on the following format: STLXXXXXX for steel products and ALUXXXXXX for aluminum products. The corresponding HTSUS Chapter 99 number for the Section 232 duties should not be submitted when the product exclusion number is submitted.
 
Steel importers must also submit mill certificates with their import data as required by 19 CFR 141.89.
 
Refunds. Granted product exclusions are retroactive to the date the request was posted for public comment. For any exclusions approved by DOC prior to June 1, 2018, importers may request a refund by submitting a post-summary correction with the product exclusion number in the importer additional declaration field.
Once products are excluded importers may claim Generalized System of Preferences or African Growth and Opportunity Act duty preferences on GSP and AGOA-eligible goods. If importers did not receive GSP or AGOA duty preferences on previous imports and those imports are now covered by a retroactive exclusion, importers may request a refund of the duties subject to GSP or AGOA preferences through a PSC.
 
If the entry has already liquidated, importers may protest the liquidation.

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

COMMCOMMENTARY

COMM_a0
11. M. O’Kane: “Germany Drops Sanctions on Turkey, USA Threatens Turkey Sanctions for Detention of US Pastor”

(Source: European Sanctions Blog, 30 July 2018.)
 
* Author: Michael O’Kane, Esq., Peters & Peters Solicitors LLP, mokane@petersandpeters.com.
 
Germany has lifted its economic sanctions on Turkey after Ankara ended its two-year state of emergency. Its sanctions consisted of a €1.5 billion ($1.7 billion) limit on export guarantees to Turkey imposed in July 2017 after the detention of a German human rights campaigner and five other activists, including the head of Amnesty International in Turkey.
 
Meanwhile last week (26 July), US President Donald Trump tweeted that the US will impose “large sanctions on Turkey for their long time detainment of Pastor Andrew Brunson”. Andrew Brunson, an evangelical minister, has been detained on charges of involvement in a failed 2016 coup in Turkey. He has recently been moved to house arrest. In response, Turkey’s Ministry of Foreign Affairs issued a press release stating that “[n]o one can give orders to Turkey and threaten our country. The rhetoric of threat against Turkey is unacceptable. … As regards the Brunson case, necessary information has been provided to our U.S. counterparts on various occasions and it has been clearly expressed that this issue is totally within the competence of the independent Turkish judiciary.”
 
On 26 July, the US Senate Foreign Relations Committee approved a Bill committing the US to opposing any international credit offers to Turkey. The Bill will now move to the full chamber of the Senate. A similar Bill was also introduced in the US House of Representatives.

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

COMM_a01
12. M. Volkov: “Episode 49 – Data Breach Notification in the GDPR Era”
(Source: Volkov Law Group Blog, 29 July 2018. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
Global Companies face a complex set of data breach notification requirements.  In the absence of a uniform federal standard, companies have to tailor their data breach notification procedures to meet the requirements of 50 U.S. states.  With respect to European Union residents, global companies have to meet stringent requirements established by the General Data Protection Regulations.
 
In
this episode, Michael Volkov reviews the data breach notification requirements for US person data and for EU residents.
* * * * * * * * * * * * * * * * * * * * 

MSEX/IM MOVERS & SHAKERS

MS_a113. Monday List of Ex/Im Job Openings; 172 Jobs Posted This Week, Including 17 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

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

* Aerojet Rocketdyne; Camden, AR;
International Trade and Compliance Specialist;
*
Agility; Atlanta, GA; 
Air Export Coordinator
;
* Agility; Atlanta, GA; Ocean Import Coordinator

* Agility; Bensenville, IL; Ocean Export Coordinator;

* Agility; Basel, Switzerland;
International Exhibition Coordinator

* Agility; Burlingame, CA;
 
Ocean Import Coordinator
;

* Agility; East Boston, MA; 
Customs/Entry Writer Coordinator

* Agility; Houston, TX; 
Air Freight Export Account Executive

* Agility; Houston, TX; Ocean Export Coordinator

* Agility; Queens, NY; Air Export Coordinator;
* Agility; Queens, NY; Air Export Coordinator;

* Albemarle Corporation; Baton Rouge, LA; Logistics Specialist – Trade Compliance and Marine Specialist

#
Alcoa Group; Knoxville, TN;
Trade Compliance Administrator
;

* Amazon; Seattle, WA; Head, Global Trade and Product Compliance
;
* Amazon; Seattle, WA;
 
Global Trade Compliance Analyst;

*
Amazon; Seattle, WA; US Export Compliance PM;

#
Arrow; Multiple Locations: Centennial, CO; Phoenix, AZ; Reno, NV;
Global Trade Management & Compliance Officer – Trade Compliance Analyst
;

* Arrow; Shanghai, China; Compliance Manager;


Augusta Westland; Philadelphia, PA;
Import/Export Specialist
; Requisition ID: 1518

* BAE Systems; Rockville, MD; Compliance Specialist Senior; Requisition ID: 35809BR
* BAE Systems; Sterling, VA; Compliance Specialist Senior; Requisition ID: 36370BR

# Bass Pro Shops; Springfield, MO;
Global Trade Compliance Specialist
;
#
Boeing; Englewood, CO;
Compliance Specialist 4
; Requisition ID: 1268;

* Boeing; Zoushan, China;
Trade Compliance Manager;

* 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


#
Disney Parks & Resorts; Kissimmee, FL;
Senior Manager, Trade Compliance
; Requisition ID: 552655BR;
#
The Dow Chemical Company; Midland, MI; ITO Trade Compliance Manager – Technology;

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

* Eaton; Hungary; Manager Global Trade Management EMEA – Imports (in any EMEA location)Requisition ID: 052687

* Eaton; Multiple Locations: Cleveland, Ohio; Moon Township, Pennsylvania; Eden Prairie, Minnesota; Peachtree City, Georgia; Galesburg, Michigan; Manager, Supply Chain Governance, Risk & ComplianceRequisition ID: 054321

* Eaton; Reynosa, MexicoTrade Compliance SpecialistRequisition ID: 054044
* Eaton; Syracuse, NY; Global Logistics Manager; Requisition ID: 036620 

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

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

* Eli Lilly and Co.; Indianapolis, IN; Import/Export Trade Associate;
#
Embraer; Fort Lauderdale, FL;
Compliance Specialist II
; Requisition ID: 170685;
* 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; Bedfont, United Kingdom; 
District Trade Compliance Manager
;
* Expeditors; Detroit, MI; US Export Compliance Consultant;
* Expeditors; Dublin, IE; Consultant – Customs and Trade Compliance;
* Expeditors; Dusseldorf, Germany; Clerk, Airfreight Import;

*
 Expeditors; Krefeld, Germany; 
Clerk, Airfreight Import
; 
* Expeditors; Plainfield, IN; District Trade Compliance Manager;
* Expeditors; Sunnyvale, CA, USA; Customs Compliance Coordinator;
* Expeditors; Sunnyvale, CA, USA; Customs Compliance Specialist;
* Expeditors; Stockholm, SE; District Trade Compliance Manager;


* Export Solutions Inc.; Melbourne FL; 
Trade Compliance Specialist
;
info@exportsolutionsinc.com

* Flash Global; Mountain Lakes, NJ;
Import and Export Specialist;

* 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;
Associate Compliance Specialist
; Requistion ID: 19856BR;
#
General Atomics; San Diego, CA;
Government Compliance Specialist
; Requisition ID: 19499BR;

* General Atomics; San Diego, CA; 
Import/Export Trade Compliance Administrator – Licensing
Requisition ID: 17968BR
* General Atomics; San Diego, CA; Internal Auditor – Senior; Requisition ID: 17524BR 

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

#
General Atomics; San Diego, CA;
Senior Government Compliance Specialist
; Requisition ID: 19500BR;

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

#
General Electric; Lynn, MA;
Senior Export Control Specialist, Aviation
; Requisition ID: 3146429

* 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

* Honeywell International Inc.; Sunnyvale, CA or Lincolnshire, IL; Sr. Import/Export Analyst; HRD32371

* Hussman; Bridgeton, MO; 
Trade Compliance Specialist;

* Infineon Technologies; Milpitas, CA;
Export Compliance Specialist; Requisition ID: 26988
* Infineon Technologies; Munich, Germany; Manager Export Control;
* Infineon Technologies; Munich, Germany; Specialist Export Control;

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

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

* Johnson Controls; Boca Raton, FL; Licensing Coordinator; Requisition ID: 
WD30047852135
* Johnson Controls; Boca Raton, FL; Licensing Coordinator; Rquisition ID: 
WD30047853135
* Johnson Controls; Milwaukee, WI; Trade Compliance Analyst; Requisition ID: WD30047348124
* Johnson Controls; Tamaulipas, Matamoros, Mexico; Trade Compliance Specialist; Requisition ID: EB00064420180

* Komatsu; Milwaukee, WI; Senior International Trade Compliance AnalystRequisition ID: 12728

* Lam Research Corp.; Shanghai, China; 
Foreign Trade (FT) 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; Arlington, VA; 
Senior International Licensing Analy
st; ID: 
438635BR
* Lockheed Martin; Arlington, VA; 
International Trade Compliance Senior Analyst
; ID: 433621BR
* Lockheed Martin; Arlington, VA; 
International Trade Compliance Engineer
; ID: 
439787BR

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

* Lockheed Martin; Fort Worth, TX;
Regulatory Compliance Analyst Senior
; Requisition ID: 433405BR  

* Lockheed Martin; Orlando, FL; 
Senior International Licensing Analyst
; Requisition ID: 
434225BR 


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

* 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
* Maersk/DAMCO; Agent de transit IMPORT – EXPORT; Job Ref.: DC-164022
* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst
; Requisition ID: 16000DYY
* Medtronic; Wash DC;
Global Trade Lawyer
;
stacy.m.johnson@medtronic.com
; Requisition ID: 170002ON

#
Meggit; Akron, OH;
Senior Manager Trade Compliance;

* 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

* Muscogee International, LLC; Washington, D.C.;
DDTC Compliance Specialist II; 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.

#
Netflix; Los Angeles, CA;
Manager, Trade Compliance
;

* 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.
* OCR Services, Inc.; Rockville, MD;
Business Analyst, Global Trade Compliance;

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

* Optics 1; Bedford NH, Senior Trade Compliance Administrator

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

* Oshkosh Corporation; Greenville, WI; Senior Global Trade Compliance Analyst – Licensing; ID: 
183273

* PerkinElmer, Inc.; Shelton, CT;
Systems Analyst, Trade Compliance Solutions;
* PerkinElmer, Inc.; Singapore; ITC Specialist; Requisition ID: JR-003936

* Raytheon; Billerica, MA; 
Mgr I Export-Import Control
; Requisition ID: 
118298BR

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

* 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; Tuscon, AZ; 
Principal Analyst Export Licensing And Compliance
Requisition ID:
112176BR
* Raytheon; Woburn, MA; 
Global Trade Export Licensing & Compliance Advisor
Requisition ID:
117939BR
* Raytheon; Woburn, MA; Supply Chain Compliance Advisor; Requisition ID:
115557BR

*
 SABIC; Houston TX; 
Senior Analyst, Trade Compliance
;
Danielle.Cannata@sabic.com
; Requisition ID: 8411BR

* 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; Calabasas, CA;
Global Trade Compliance Specialist
; Requisition ID: 4088;

* 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;

* Teva Pharmaceuticals; North Wales, PA; 
Senior Analyst, Customs & Trade Compliance
;

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

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

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

* Varian; Paolo Alto, CA; Senior Trade Compliance Analyst; Requisition ID: 12735BR; Contact 
Uyen Tran at
Uyen.Tran@varian.com
* Varian; Paolo Alto, CA; 
Trade Compliance Analyst; 
Requisition ID: 
13097BR;

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

* Vigilant; Negotiable Location, USA;  
Global Trade Account Manager
;

* Virgin Galactic; Las Cruces, NM; Export Compliance Officer; Requisition ID: 2018-3558

#
Watts Water Technologies; Andover, MA;
Customs Compliance Specialist
;
#
World Wide Technology; Edwardsville, IL;
International Trade Compliance Specialist
;

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

* Xylem, Inc.; Bangalore, Karnataka, IndiaThird Party Contract & Compliance Coordinator;

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

* Xylem, Inc.; Pewaukee, WI; Logistics Manager/Trade Compliance;

* YETI; Austin, TX;
Global Trade Compliance Manager 

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

TECEX/IM TRAINING EVENTS & CONFERENCES

(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 organisations 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 practice 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

Alexis de Tocqueville (Alexis Charles Henri Clérel, Viscount de Tocqueville; 29 Jul 1805 – 16 Apr 1859) was a French diplomat, political scientist and historian. He was best known for his works Democracy in America and The Old Regime and the Revolution. Democracy in America was published after Tocqueville’s travels in the United States and is today considered an early work of sociology and political science.
  – “Democracy and socialism have nothing in common but one word, equality. But notice the difference: while democracy seeks equality in liberty, socialism seeks equality in restraint and servitude.”

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

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.  If you would to submit material for inclusion in the The Export/Import Daily Update (“Daily Bugle”), please find instructions here.

* 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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