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18-0924 Monday “Daily Bugle”

18-0924 Monday “Daily Bugle”

Monday, 24 September 2018

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The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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  1. DHS/CBP Seeks Comments on Form 7523, Entry and Manifest of Merchandise Free of Duty, Carrier’s Certificate and Release
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Announces Client Representative Division Follow-up Webinar – “Next Steps for Restructuring”
  4. DoD/DSCA Posts Policy Memo’s 18-48, 18-49, and 18-50
  5. DoD/DSS Announces Knowledge Center PCL Inquiries Closure Until 1 Oct
  6. OMB/OIRA Reviews of Proposed Ex/Im Regulations
  7. State/DDTC: (No new postings.)
  8. Treasury/OFAC Posts Reminder for the Annual Report of Blocked Property
  9. Treasury/OFAC Temporarily Extends Ukraine-related General Licenses
  1. Expeditors News: “China Announces Retaliatory Tariffs on US Goods in Response to the Latest Round of Section 301 Tariffs on Chinese Goods”
  2. Global Trade News: “RCEP Agreement May Be Finalized in November”
  3. Reuters: “China Cancels Military Talks with U.S. in Protest at Sanctions over Russia Military Equipment”
  4. ST&R Trade Report: “Customs Broker ISA Pre-Certification Test Discontinued”
  5. UPI: “Russia, China Warn U.S. of ‘Consequences’ of ‘Playing with Fire'”
  1. M. O’Kane: “New CAATSA-Related Executive Order; 33 Persons Added to CAATSA List of Russian Defense & Intelligence Sectors; 2 Chinese Persons Sanctioned”
  2. M. Volkov: “Episode 57 – A Review of the Russia Sanctions and Recent Changes”
  1. Monday List of Ex/Im Job Openings: 156 Openings Posted This Week, Including 8 New Openings
  1. FCC to Present U.S. Export Controls Awareness Training Course for Non-U.S. Organizations, 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 (19 Sep 2018), DOD/NISPOM (18 May 2016), EAR (13 Sep 2018), FACR/OFAC (29 Jun 2018), FTR (24 Apr 2018), HTSUS (14 Aug 2018), ITAR (30 Aug 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1
. DHS/CBP Seeks Comments on Form 7523, Entry and Manifest of Merchandise Free of Duty, Carrier’s Certificate and Release

(Source: Federal Register, 24 Sep 2018.) [Excerpts.]
 
83 FR 48321-48322: Agency Information Collection Activities: Entry and Manifest of Merchandise Free of Duty, Carrier’s Certificate and Release
* AGENCY: U.S. Customs and Border Protection (CBP), Department of Homeland Security.
* ACTION: 60-Day notice and request for comments; extension of an existing collection of information. …
* ADDRESSES: Written comments and/or suggestions regarding the item(s) contained in this notice must include the OMB Control Number 1651-0013 the subject line and the agency name. To avoid duplicate submissions, please use only one of the following methods to submit comments:
  (1) Email. Submit comments to: CBP_PRA@cbp.dhs.gov.
  (2) Mail. Submit written comments to CBP Paperwork Reduction Act Officer, U.S. Customs and Border Protection, Office of Trade, Regulations and Rulings, Economic Impact Analysis Branch, 90 K Street NE, 10th Floor, Washington, DC 20229-1177.
* FOR FURTHER INFORMATION CONTACT: Requests for additional PRA information should be directed to Seth Renkema, Chief, Economic Impact Analysis Branch, U.S. Customs and Border Protection, Office of Trade, Regulations and Rulings, 90 K Street NE, 10th Floor, Washington, DC 20229-1177, Telephone number (202) 325-0056 or via email CBP_PRA@cbp.dhs.gov. Please note that the contact information provided here is solely for questions regarding this notice. Individuals seeking information about other CBP programs should contact the CBP National Customer Service Center at 877-227-5511, (TTY) 1-800-877-8339, or CBP website.
SUPPLEMENTARY INFORMATION: …
  – Title: Entry and Manifest of Merchandise Free of Duty, Carrier’s Certificate and Release.
  – OMB Number: 1651-0013.
  – Form Number: CBP Form 7523.
  – Current Actions: CBP proposes to extend the expiration date of this information collection. There is no change to the burden hours or the information collected. …
  – Abstract: CBP Form 7523, Entry and Manifest of Merchandise Free of Duty, Carrier’s Certificate and Release, is used by carriers and importers as a manifest for the entry of merchandise free of duty under certain conditions. CBP Form 7523 is also used by carriers to show that articles being imported are to be released to the importer or consignee, and as an inward foreign manifest for a vehicle or a vessel of less than 5 net tons arriving in the United States from Canada or Mexico with merchandise conditionally free of duty. CBP uses this form to authorize the entry of such merchandise. CBP Form 7523 is authorized by 19 U.S.C. 1433, 1484 and 1498. It is provided for by 19 CFR 123.4 and 19 CFR 143.23. This form is accessible here. … 
 
   Dated: September 19, 2018.
Seth D Renkema, Branch Chief, Economic Impact Analysis Branch, U.S. Customs and Border Protection.

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

OGSOTHER GOVERNMENT SOURCES

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

* State; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Statement of Registration [Publication Date: 25 September 2018.]

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

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

(Source:
CSMS #18-000561, 24 Sep 2018.)
 
This is to announce a follow-up webinar for interested trade parties, such as ABI software vendors, self-programmers, brokers and importers that transmit data electronically, regarding the Client Representative Division restructuring plan (see CSMS messages 18-000460, -000473, and -000496). The purpose of the webinar is to share the division’s plan, after having incorporated the feedback we received from affected trade parties. The
webinar will be held on Thursday, October 4 at 2:00p.m. Eastern.
 
Call-In Information
 
+1 (877) 336-1828, Access Code: 612 4214
 
If the above line is full, please use the following:
 
+1 (877) 336-1829, Access Code: 849 5832
 

  – Related CSMS No.
18-000460, 18-000473, 18-000496

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

(Source:
DoD/DSCA, 24 Sep 2018.)
 
 
 
 

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

(Source:
DoD/DSS, 21 Sep 2018.)
 
Personnel Security (PCL) inquiries (option #2), to include e-QIP authentication resets, of the DSS Knowledge Center will be closed September 21, 2018, through September 28, 2018, and will resume normal operations for PCL and e-QIP inquiries on Monday, October 1, 2018.

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

(Source:
OMB/OIRA, 21 Sep 2018.)   
 
* Review of Certain Technology Transfers
  – AGENCY: DOC-BIS
  – STAGE: Prerule
  – RECEIVED DATE: 09/21/2018
  – RIN: 0694-AH61
  – STATUS: Pending Review

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

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

(Source:
Treasury/OFAC, 24 Sep 2018.)
 
On July 2, 2018, OFAC issued a recent actions notice notifying persons holding property blocked pursuant to OFAC sanctions regulations published in Chapter V of Title 31 of the Code of Federal Regulations of the requirement, as outlined in 31 C.F.R. § 501.603, to provide OFAC with a comprehensive report on all blocked property held as of June 30 of the current year by September 30. 
 
The annual reports must be filed using Form TD F 90-22.50, Annual Report of Blocked Property (ARBP).  If your institution holds 20 or more blocked accounts, OFAC recommends, but does not require, supplementing Part B of your ARBP with a spreadsheet along with your completed form.  Please send completed forms to OFACReport@treasury.gov.  Failure to submit a required report by September 30 constitutes a violation of 31 C.F.R. Part 501 (“Reporting, Procedures and Penalties Regulations”).

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

(Source:
Treasury/OFAC, 21 Sep 2018.) 
 
On 21 Sep 2018, OFAC extended the expiration date of certain general licenses related to EN+ Group plc and United Company RUSAL PLC, and issued the following three general licenses:
GENERAL LICENSE NO. 13D Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in Certain Blocked Persons,
GENERAL LICENSE NO. 14A Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with United Company RUSAL PLC, and
GENERAL LICENSE NO. 16A Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with EN+ Group PLC or JSC EuroSibEnergo.

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

NWSNEWS

(Source:
Expeditors News, 21 Sep 2018.)
 
On Sep 18, 2018, the China State Council Tariff Commission announced in Notice No. 8 the decision to impose additional tariffs on approximately $60 billion in imported goods originating from the US, in response to the US decision to levy additional tariffs to $200 billion in imported goods from China. The additional tariffs will take effect on Sep 24 at 12:01PM at rates of 10% and 5%, as specified in the following annexes:
  – Annex 1 consists of 2493 HS Headings with an additional 10% tariff (Previously announced 25%)
  – Annex 2 consists of 1078 HS Headings with an additional 10% tariff (Previously announced 20%)
  – Annex 3 consists of 974 HS Heading with an additional 5% tariff (Previously announced 10%)
  – Annex 4 consists of 662 HS Heading with an additional 5% tariff (Previously announced 5%)
 
The original Chinese announcement No. 8 may be found
here.
 
The annexes may be found here:
  – Annex 1;
  – Annex 2;
  – Annex 3; and
  – Annex 4.
 
Previous Expeditors Newsflash on announcement No.6 on Aug 3, 2018 may be found
here.
 
Google translated versions of the announcements and commodity lists may be found here:
  – Annex 1;
  – Annex 2;
  – Annex 3; and
  – Annex 4.

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

(Source:
Integration Point Blog, 21 Sep 2018.)
 
The sixth ministerial meeting of the Regional Comprehensive Economic Partnership (RCEP) held on August 30-31 culminated with greater anticipation to finalize the deal by November at the ASEAN Leaders Summit.
 
After the sixth ministerial meeting, the Ministry of Trade and Industry of Singapore stated in its press release that two additional chapters were concluded in the meeting, one on customs procedures and trade facilitation and the other on government procurement. The first two (on economic and technical cooperation and on small and medium enterprises) had already been finalized in previous meetings.
 
The concept of the RCEP came into the picture in 2012 when the leaders of Association of Southeast Asian Nation (ASEAN) resolved to forge a wide-ranging trade deal with six of their FTA partners – namely Japan, South Korea, China, India, Australia, and New Zealand. Since then, twenty-two rounds of negations and six ministerial-level talks have unfolded.
 
The major objective of the RCEP is a mutually beneficial economic partnership agreement covering a wide range of areas such as goods, services, investments, economic and technical cooperation, intellectual property rights, ecommerce, and investor-state-dispute settlement. This would ensure that every participating nation would gain improved access to each other’s growing markets.
 
The RCEP negotiations took a strategic move when U.S. President Donald Trump pulled out of the Trans-Pacific Partnership (TPP), which didn’t include major economies such as China and India. If finalized, this agreement will be the world’s largest trade deal. The RCEP member countries account for a quarter of the world’s GDP (equivalent to $23.8 trillion), nearly half of the world population, and one-third of global trade. Additionally, it attracts approximately 26% of foreign direct investments.
 
China’s advantage
 
China’s hunt for alternative and diversified markets has accelerated with the escalating trade war with the U.S., and this agreement could well provide the much-needed boost for its domestic business. Amidst the rising raw material prices and trade uncertainties, the Chinese manufacturing industry is expected to benefit the most from the deal. Chinese products which are now routed to countries like India through third nations would get a direct destination through the open market promised under RCEP.      
 
India’s apprehension 
 
RCEP members want India to eliminate or significantly reduce duties on most of its goods, to which India objected and has suggested a differential tariff regime for different country groups such as China, a major threat to its domestic textile and steel industries. India has demanded that tariffs on certain sensitive products would only be phased out in a twenty year timeframe after the implementation of the agreement. India also wants to negotiate free trade agreements with Australia, New Zealand, and China – its non-FTA partners in RCEP – under a “Bilateral Pairing Mechanism.”
 
A win-win situation for ASEAN
 
At present, ASEAN has an FTA with each of the six participating nations of the RCEP. Once implemented, the application of various tariff rates and domestic rules of origin would be streamlined, thereby reducing the trade barriers. This would not only simplify the rules and procedures of each FTA but also enhance regional connectivity.
 
The next step ahead
 
RCEP trade officials are scheduled to meet in Auckland, New Zealand between October 17-21, 2018, to continue discussing the implementation of the agreement. Two more rounds of ministerial meetings are likely to be conducted before the final RCEP Summit scheduled in November 2018.
 
For more on RCEP, visit the First Post and ASEAN Briefing.   

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

(Source:
Reuters, 22 Sep 2018.) [Excerpts.]
 
China summoned the U.S. ambassador in Beijing and postponed joint military talks in protest against a U.S. decision to sanction a Chinese military agency and its director for buying Russian fighter jets and a surface-to-air missile system. …
 
Ministry spokesman Wu Qian said China’s decision to buy fighter jets and missile systems from Russia was a normal act of cooperation between sovereign countries, and the United States had “no right to interfere”.
 
On Thursday, the U.S. State Department imposed sanctions on China’s Equipment Development Department (EED), the branch of the military responsible for weapons procurement, after it engaged in “significant transactions” with Rosoboronexport, Russia’s main arms exporter.
 
The sanctions are related to China’s purchase of 10 SU-35 combat aircraft in 2017 and S-400 surface-to-air missile system-related equipment in 2018, the State Department said.
 
A senior U.S. State Department official on Saturday said China was the only country that had taken possession of the advanced S-400 surface-to-air missile system, in a breach of a U.S. sanctions law imposed in response to Russia’s “malign behavior”.
 
The official, speaking to Reuters on condition of anonymity, insisted that the sanctions were aimed at Moscow, not Beijing.
 
The so-called Countering America’s Adversaries Through Sanctions Act, or CAATSA, was signed into law in 2017 to punish Russia for meddling in U.S. elections, aggression in Ukraine and involvement in Syria’s civil war.
 
  “China is the first country in the world to use both of those systems,” the official said. “Both of those systems are extremely sophisticated and very high value.” …
 
Washington has expressed concern that Turkey’s planned deployment of S-400s could threaten some U.S.-made weapons and other technology used by Turkey, including the F-35 fighter jet.
 
The official said the move against the Chinese agency was not discretionary, but was made because Beijing broke U.S. law. “We hope it will be paid attention to because … our goal is to prevent these types of transactions,” he added.
 
The U.S. sanctions will block the EED and its director, Li Shangfu, from applying for export licenses and participating in the U.S. financial system.
 
  “The U.S. approach is a blatant violation of the basic norms of international relations, a full manifestation of hegemony, and a serious breach of the relations between the two countries and their two militaries,” Wu said in a notice posted on the Chinese defense ministry’s official Wechat account.
 
He warned that the United States would face “consequences” if it did not immediately revoke the sanctions.

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

 
U.S. Customs and Border Protection has discontinued effective from Sept. 21 a test originally announced in April 2013 that allowed customs brokers to pre-certify importers for participation in the Importer Self-Assessment program. The Customs Broker Importer Self-Assessment Pre-Certification (Broker ISA PC) test was intended to leverage customs brokers’ relationships with importers to facilitate and promote importer participation in the ISA program. However, CBP has determined that it is not effective to continue with the test in light of “minimal importer participation” and, as a result, the agency will not move forward with a permanent Broker ISA PC program.

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

(Source:
UPI, 21 Sep 2018.)
 
China and Russia reacted strongly Friday to another round of U.S. government sanctions, with Moscow warning the Trump administration against “playing with fire.”
 
The administration announced
sanctions Thursday against nearly three dozen Russian individuals and entities, and a section of Beijing’s military. The Chinese department was sanctioned for buying fighter jets and missiles from Russia, a violation of
prior sanctions.
 
Friday, the Russian government warned that the new sanctions — the 60th round against Moscow since 2011 — could lead to trouble for the United States.
 
  “Each new round of sanctions proves our foe’s complete lack of success in pressuring Russia with previous such attempts,” Russian Deputy Foreign Minister Sergei Ryabkov said. “It would not be bad if they remembered about the concept of global stability, which they are unthinkingly undermining by whipping up tensions in Russia-U.S. relations.
 
  “Playing with fire is stupid and can become dangerous.”
 
The sanctions mean China’s Equipment Development Department will be denied U.S. foreign export licenses, is banned from making foreign exchange transactions within U.S. jurisdictions and is prohibited from using the U.S. financial system.
 
All property belonging to the EDD that’s within U.S. control will be blocked. Li Shangfu, director of the EDD, is also blocked from getting a U.S. visa.
 
Chinese officials echoed their Russian counterparts Friday,
calling the sanctions “unreasonable.”
 
  “The U.S. has seriously violated the basic norms of international relations and disturbed the relationships between China and the U.S,” Beijing Foreign Ministry spokesman Geng Shuang said. “We strongly call on the U.S. to remedy the mistake and cancel the sanctions. Otherwise, the U.S. has to bear the consequences.”
 
The new row between Washington and Beijing comes as the nations are already embroiled in an
escalating trade war. China reacted to new U.S. tariffs this week with fiscal penalties of its own against U.S. imports.

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

COMMCOMMENTARY

 
* Author: Michael O’Kane, Esq., Peters & Peters Solicitors LLP, mokane@petersandpeters.com.
 
Last week (20 September), US President Donald Trump issued a new Executive Order to further the implementation of certain CAATSA-related sanctions with respect to the Russian Federation. See new OFAC FAQPresidential Statement and Special Press Briefing for further details. In addition, the US Secretary of State has taken two actions to implement his delegated authorities pursuant to section 231 of CAATSA and to “further impose costs on the Russian Government for its malign activities”.
First, the Secretary of State has added 33 additional persons to the section 231(d) CAATSA list of those “being a part of, or operating for or on behalf of, the defense or intelligence sectors of the [Russian government]”. This action increases the number of persons identified to 72 (39 persons were originally identified in October 2017 – see previous blog). This list does not itself impose sanctions, but any person who knowingly engages in a “significant transaction” with any of the identified persons will be subject to mandatory sanctions, pursuant to section 231(a) of CAATSA.
 
Second, in consultation with OFAC (see Notice here), the Secretary of State has sanctioned Chinese entity Equipment Development Department (EDD) and its director, Li Shangfu, for “knowingly engag[ing] in significant transactions with a person that is a part of, or operates for or on behalf of, the defense sector of the [Russian government]”. According to the US Department of State Fact Sheet (which includes the additional 33 identified persons), China took delivery from Russia of ten Su-35 combat aircraft in December 2017 and a batch of S-400 (a.k.a. SA-21) surface-to-air missile system-related equipment in January 2018. Both transactions were negotiated between EDD and Russia’s main arms export entity, Rosoboronexport; an entity identified on the aforementioned section 231(d) CAATSA list. The following 5 sanctions have been selected from section 235 of CAATSA to be imposed on EDD:
 
  (1) A denial of export licences;
  (2) A prohibition on foreign exchange transactions under US jurisdiction;
  (3) A prohibition on transactions with the US financial system;
  (4) Blocking of all property and interests in property within US jurisdiction; and
  (5) The imposition of sanctions on an EDD principal executive officer, namely, its director Li Shangfu, which include a prohibition on foreign exchange transactions under US jurisdiction, a prohibition on transactions with the US financial system, blocking of all property and interests in property within US jurisdiction, and a visa ban.
 
This is the first time the US has sanctioned anyone under section 231 of CAATSA for knowingly engaging in a significant transaction with a person identified as “being a part of, or operating for or on behalf of, the defense or intelligence sectors of the [Russian government]”.

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

(Source:
Volkov Law Group Blog, 23 Sep 2018 Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
Since 2014, the United States has put into place a comprehensive set of sanctions against Russia.  In response to Russia’s annexation of Crimea and its hostile activities in the Ukraine, President Obama put in place a set of sanctions focused against various sectors of the Russian economy.  Since the Trump Administration came to power, Congress enacted additional sanctions, and the Department of Treasury adopted targeted sanctions against Russian Oligarchs.  Recently, the State Department announced new sanctions against Russia for its violation of international laws relating to chemical and biological weapons.
 
In this episode, Michael Volkov discusses the Russia Sanctions Program and the difficult compliance issues surrounding compliance.

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

MSEX/IM MOVERS & SHAKERS

MS_a118. Monday List of Ex/Im Job Openings: 156 Openings Posted This Week, Including 8 New Openings

(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; Canoga Park, CA; 
Manager, Industrial Security & Compliance
;

* Agility; Atlanta, GA; Ocean Import Coordinator

* Agility; Bensenville, IL; Ocean Export Coordinator; 


Agility; Basel, Switzerland; 
International Exhibition Coordinator
 

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


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

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


Airbus; Getafe, Spain; VIE Procurement Sustainability Management – Export Compliance; Requistion ID
: 10409879 ER EN EXT 1

Airschott, Inc.; Dulles, VA; Imports/Exports/International Logistics & Business

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

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

* Amazon; Seattle, WA;
 
Global Trade Compliance Analyst;

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

American Trucking Associations (ATA); Arlington, VA;
Mgr Customs, Immigration & Cross-Broder Ops
;

* Arrow; Shanghai, China; Compliance Manager;

*
Augusta Westland; Philadelphia, PA;
Manager, Import Export
;

* BAE
 Systems; Kingsport, TN; 
Government Compliance Manager
; Requisition ID: 41212BR;

*
Boeing; Adelaide, Brisbane, Canberra, Melbourne, Australia; 
Trade Control Specialist
; Requisition ID: 1800072289;

* Boeing; Dallas, TX; 
Global Regulatory and Compliance Specialist 4
; Requisition ID: 12795;

* Boeing; Manassas, VA; 
Export Control Manager
; Requisition ID: 1900

* Boeing; Zoushan, China; 
 Compliance Analyst
* Boeing; Zoushan, China;
Trade Compliance Manager;
*
Booz Allen Hamilton; NY; 
Associate General Counsel
; Requisition ID: R0035318;

* CGI, Fairfax, VA; 
Trade Compliance Analyst/Manager
Requisition ID: J0818-1218;


Cobham; Exeter, NH, Lansdale, PA; Export Compliance OfficerAlicia.Neice@yoh.com; Requisition ID 1611
*
Cognizant; Budapest, Hungary; 
Ethics & Compliance Senior Manager Continental Europe

Cognizant;
Mexico City, Mexico; Regional Ethics & Compliance Officer LATAM;
* 
Cognizant; Shanghai, China; Regional Ethics & Compliance Officer – APAC;

Cobham; Lansdale, PA; Export Compliance Officer; Ali Neice Alicia.Neice@yoh.com; Requisition ID 1611;

ConvaTec; Greensboro, NC; Associate Manager, Customs & Trade;

* Destaco; Auburn Hills, MI; 
Manager, Global Compliance
; Clenetta Frazier; 
cfrazier@destaco.com
; Requisition ID:  16261


* Disney Parks & Resorts; Kissimmee, FL;
Senior Manager, Trade Compliance
; Requisition ID: 552655BR;

DuPont; Wilmington, DE;
Trade Compliance Leader
; Requisition ID: 196737W-01;

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


Energizer Holdings; St. Louis, MO; Trade Compliance Analyst; Kieshana Miles,kieshana.miles@energizer.com; Requisition ID: NAM00604;

* Esterline – Korry Electronics; Everett, WA;
Manager of Trade Compliance
; Requisition ID: 14718BR;

* Expeditors; Amsterdam, Netherlands; 
Regional Compliance SME (Subject-Matter expert) Supervisor On-site

*
 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 II;  

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

* 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
;

#
FLIR; Goleta, CA; Global Trade Compliance Analyst, Traffic;  
 

* Full Circle Compliance; Bruchem, Netherlands;
Legal Analyst, Manager

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

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

* Harris Corporation; Van Nuys, CA; Trade Compliance Specialist; rwellbro@harris.com; Job ID: ES20182408-26963

# Harris Corporation; Melbourne, FL; Director Corporate Trade Compliance; Requisition ID: CHQ20182007-26041
# Harris Corporation; Melbourne, FL; Corporate Trade Compliance Investigations Lead; Requisition ID: CHQ20182007-26042 

#
Henderson Group Unlimited, Inc; Washington, DC; 
Defense Trade Control Compliance Analyst
;
#
Henderson Group Unlimited, Inc; Washington, DC; 
Commodities Jurisdiction Analyst
;

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

#
iDirect; Herndon, VA;
Senior Regulatory Compliance Engineer
; Requisition ID: 2018R-4700-56

* 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

* Kohls; Menomonee Falls, WI; Senior Manager, Customs Compliance

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

* Leonardo DRS; Cypress, CA; 
Contracts & Compliance Manager
; Requisition ID: 91594
* Leonardo DRS; Dallas, TX; 
 Contracts & Compliance Administrator
; Requisition ID: 91611
* Leonardo DRS; Dallas, TX; 
Contracts & Compliance Manager
; Requisition ID: 91608
* Leonardo DRS; Melbourne, FL; 
Senior Supply Chain Analyst – Small Business Compliance
; Requisition ID: 91669

* Livingston; CA; 
Import Analyst; 
Requisition ID: 60988
* Livingston; CA; 
Import Specialist; 
Requisition ID: 60644
* Livingston; GA; 
Import Specialist; 
Requisition ID: 61165
* Livingston; IL; 
Import Specialist; 
Requisition ID: 60803
* Livingston; IL; 
Import Specialist; 
Requisition ID: 60905
* Livingston; IL; 
Client Import Analyst; 
Requisition ID: 60964
* Livingston; NY; 
Client Import Analyst; 
Requisition ID: 61123


* Lockheed Martin; Arlington, VA; 
International Trade Compliance Engineer
; Job ID: 439787BR

* Lockheed Martin; Arlington, VA; 
International Trade Compliance Engineer
; ID: 
439787BR

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


* Luminar Technologies; Orlando, FL; Senior 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
* Maersk/DAMCO; Agent de transit IMPORT – EXPORT; Job Ref.: DC-164022
* Medtronic; Heerlen, The Netherlands;
Trade Compliance Analyst
; Requisition ID: 16000DYY

Medtronic; Minneapolis, MN;
Trade Compliance Program Manager
; Requisition ID: 18000BJW;

* Medtronic; Wash DC;
Global Trade Lawyer
;
stacy.m.johnson@medtronic.com
; Requisition ID: 170002ON

* Mercury Systems; Andover, MA; International Trade Compliance Director; Requisition ID: 18-165

* 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; Baltimore, MD; 
International Trade Compliance Analyst (level 2 or 3)- Import
; Requisition ID: 18013545
* Northrop Grumman; Baltimore, MD; 
International Trade Compliance Analyst (level 2 or 3)- Import
; Requisition ID: 18014715

* Northrop Grumman; McLean, VA; International Trade Compliance Analyst 3; Requisition ID: 18012973

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

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

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

* Polaris; Minneapolis, MN;
Sr. Global Trade Compliance Specialist, Tariff Classification
; Requisition ID: 11770BR

* Raytheon; Billerica, MA;
Import Ctl&Compliance Advisor
; Requisition ID:
119749BR

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

* Raytheon; El Segundo, CA; 
Import Control and Compliance Advisor
; APPLY Requisition ID 119247BR

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

Raytheon; Tucson, AZ; 
Import Ctl&Compliance Advisor
; Requisition ID:
119749BR

* Raytheon; Woburn, MA; Supply Chain Compliance Advisor; Requisition ID:
115557BR

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

* Textron Aviation Inc; Wichita, KS; 
Trade Compliance Specialist
; Requisition ID: 268442

* The Safariland Group; Jacksonville, FL; Counsel (International Trade Compliance)
* The Safariland Group; Jacksonville, FL; Sr. Export Compliance Specialist;

* Sierra Nevada Corporation; Denver, CO; 
International Trade Compliance Analyst III
; Requisition ID: R0006075  


* Solvay; Alpharetta, GA; Anaheim, CA; Greenville, TX; Piedmont, SC; Winona, MN;
Export Compliance Manager
; Requisition ID: GBU007183;

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

* Thales; Cambridge, UK; 
Trade Compliance Support Officer
; Krista Helvey; Requisition ID R0034813;

* Thales; Cambridge, UK; 
Trade Compliance Officer
; Krista Helvey; Requisition ID R0034820;

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

* Toro; Bloomington, MN; 
Import – Export Compliance Manager

*
 
United Technologies – Pratt & Whitney; East Hartford, CT; 
Authorizations and Investigations Specialist

Requisition ID: 70957BR

* 
United Technologies – Pratt & Whitney; East Hartford, CT; 
Export Authorization Manager, ITC Operations
; Requisition ID: 71189BR 
* 
United Technologies – Pratt & Whitney; East Hartford, CT; ITC Site Lead, Hot Section Module Center; Requisition ID: 71012BR
* 
United Technologies – Pratt & Whitney; East Hartford, CT; Senior Export Operations Associate; Requisition ID: 71010BR

* United Technologies – Pratt & Whitney; East Hartford, CT; 
Senior Manager, Digital Systems & Integration
; Requisition ID: 70425BR

* 
United Technologies – Pratt & Whitney; East Hartford, CT; 
Senior Manager, Military ITC Programs
; Requisition ID: 71119BR
* 
United Technologies – Pratt & Whitney; East Hartford, CT; 
Senior Program Manager, ITC Operations
; Requisition ID: 71195BR

* 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

#
VT iDirect; Herndon VA;
 
Manager, Global Logistics
; Requisition ID: 2018R-3120-1;
 
psingh@idirect.net
;

* World Wide Technology; Edwardsville, IL;
International Trade Compliance Specialist
;

#
Xilinx; San Jose, CA;
 
Trade Compliance Specialist
; Requisition ID: 155901

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

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

TECEX/IM TRAINING EVENTS & CONFERENCES

TE_a119. 
FCC to Present U.S. Export Controls Awareness Training Course for Non-U.S. Organizations, 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 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

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

ENEDITOR’S NOTES

* Robert Bosch (23 Sep 1861 – 12 Mar 1942; was a German industrialist, engineer and inventor, founder of Robert Bosch GmbH, a German multinational engineering and electronics company headquartered in Gerlingen, near Stuttgart, Germany.)
  – “I don’t pay good wages because I have a lot of money; I have a lot of money because I pay good wages.”
 
Monday is pun day:
* Q: Why can’t a bicycle can’t stand on?
   A: Because it is two-tired.
* I know a lot of jokes about bad pole-vaulters, but none of them seem to go over very well.
* Grocery store workers must let the customer decide if they want paper or plastic because baggers can’t be choosers.

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

EN_a321
. 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: 19 Sep 2018: 83 FR 47283-47284: Extension of Import Restrictions Imposed on Archaeological Material From Cambodia  

 
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: 13 Sep 2018: 83 FR 46391-46392: Addition of Certain Entities to the Entity List, Revision of Entries on the Entity List and Removal of Certain Entities From the Entity List; 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: 14 Aug 2018: Harmonized System Update 1812, containing 27 ABI records and 6 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: 30 Aug 2018:
83 FR 44228-44229
, USML Chapter XI(c).

  – The only available fully updated copy (latest edition: 30 Aug 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_a0322
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, Alex Witt. The Ex/Im Daily Update is emailed every business day to approximately 6,000 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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