;

18-1015 Monday “Daily Bugle”

18-1015 Monday “Daily Bugle”

Monday, 15 October 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 
here for free subscription. Contact us
for advertising inquiries and rates. 

[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Implements H.R. 4813, The Miscellaneous Tariff Bill Act of 2018
  4. State/DDTC: (No new postings.)
  5. EU Council Adopts a New Chemical Weapons Sanctions Regime
  1. Expeditors News: “Canada Implements Steel Safeguards”
  1. B.P. Curran, A.V. Capobianco & R.D. Kyle: “New Regulations Expand CFIUS’ Jurisdiction and Mandate Filings”
  2. G.R. Tuttle III: “Updates on the MTB, Section 301 Tariffs and TFTEA Drawback”
  3. M. O’Kane: “New EU Chemical Weapons Sanctions Regime”
  4. M. Volkov: “Episode 60 – A Deep Dive into the SEC’s FCPA Settlement with United Technologies”
  1. Monday List of Ex/Im Job Openings: 150 Openings Posted This Week, Including 14 New Openings
  1. ECTI Presents “A Deep Dive into AES” – 13 Nov
  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 (26 Sep 2018), FACR/OFAC (29 Jun 2018), FTR (24 Apr 2018), HTSUS (11 Oct 2018), ITAR (4 Oct 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)

* State; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Brokering Prior Approval (License) [Publication Date: 16 October 2018.]
* * * * * * * * * * * * * * * * * * * *

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

(Source:
CSMS #18-000606, 12 Oct 2018.)
 
Automated Broker Interface
 
CBP Implementation of H.R. 4813, The Miscellaneous Tariff Bill Act of 2018
 
BACKGROUND
 
On September 13, 2018 the President signed into law the H.R. 4318 Miscellaneous Tariff Bill Act of 2018 (MTB). The MTB amends the Harmonized Tariff Schedule of the United States (HTSUS) to suspend and reduce tariffs on 1,660 products through December 31, 2020. The amendments are pursuant to the new process established in the American Manufacturing and Competitiveness Act of 2016 (H.R. 4923 / P.L. 114-159).
 
Under previous MTBs, Congress determined which products should be eligible for duty suspension and reduction. Under the new process, the U.S. International Trade Commission collects industry petitions and public comments, analyzes the data, and makes final determinations with federal agency input.
 
MTB’s duty suspensions and reductions are effective for goods entered or withdrawn from a warehouse for consumption on or after October 13, 2018, which is 30 days after the date of the enactment, and will remain in effect until December 31, 2020. All MTB provisions are in HTSUS subchapter II to chapter 99. CBP Office of Trade, Trade Transformation Office (TTO) will have all HTSUS 9902.01 – 9902.18 numbers programmed in the Automated Commercial Environment prior to the October 13 implementation date.
 
SECTION 301 TRADE REMEDIES
 
Since approximately half of the 1,660 MTB-eligible items are produced in China, there is overlap with Section 301 tariffs. Products of China subject to Section 301 tariffs can benefit from MTB’s suspensions and reductions for the general (column 1) rate of duty, but remain subject to the 25 percent ad valorem rate of duty imposed by headings 9903.88.01 and 9903.88.02 or 10 percent ad valorem rate of duty imposed by headings 9903.88.03 and 9903.88.04.
 
FOR FURTHER INFORMATION:
 
For questions or more information regarding implementation of the MTB, please contact CBP Office of Trade, Trade Agreements Branch at
FTA@dhs.gov.

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

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

(Source:
EU Council, 15 Oct 2018.)
 
The Council adopted a new regime of restrictive measures to address the use and proliferation of chemical weapons. This decision is a direct follow-up to the conclusions of the European Council of 28 June 2018.
 
The EU will now be able to impose sanctions on persons and entities involved in the development and use of chemical weapons anywhere, regardless of their nationality and location.
 
The restrictive measures target persons and entities who are directly responsible for the development and use of chemical weapons as well as those who provide financial, technical or material support, and those who assist, encourage or are associated with them.
 
Sanctions consist of a travel ban to the EU and an asset freeze for persons, and an asset freeze for entities. In addition, EU persons and entities are forbidden from making funds available to those listed.
 
This decision contributes to the EU’s efforts to counter the proliferation and use of chemical weapons which poses a serious threat to international security. It supports the global prohibition of chemical weapons as laid down by the Chemical Weapons Convention, against a background of increasing chemical attacks in various parts of the world.
 

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

NWSNEWS

(Source:
Expeditors News, 12 Oct 2018.)
 
On October 11, 2018, Canada announced provisional safeguards for certain steel goods that are listed in item 82 on the Import Control List (ICL). The safeguards will take the form of Tariff Rate Quotas (TRQ).
 
According to the notice, the TRQs apply “…to steel goods imported from all countries other than those originating in and imported from:
 
  – [T]he United States;
  – Chile;
  – Mexico, other than energy tubular products and wire rod originating in and imported from Mexico;
  – Israel or another CIFTA beneficiary; and
  – [A] country benefiting from the General Preferential Tariff, other than concrete reinforcing bar originating in and imported from Vietnam.”
 
The TRQs will go into effect on October 25, 2018.
 
The Canadian notice may be found
here.

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

COMMCOMMENTARY

(Source:
Hogan Lovells, 12 Oct 2018.)
 
* Authors: Brian P. Curran, Esq.,
brian.curran@hoganlovells.com, +1 202-637-4886; Anthony V. Capobianco, Esq.,
anthony.capobianco@hoganlovells.com, +1 202-637-2568; and Robert D. Kyle, Esq.,
robert.kyle@hoganlovells.com, +1 202-637-5494. All of Hogan Lovells.
 
The Department of the Treasury (the Treasury) has released two new interim rules that (i)
update existing regulations regarding the Committee on Foreign Investment in the United States (CFIUS) pursuant to the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), and (ii)
establish a pilot program implementing a discrete set of FIRRMA provisions related to foreign investments in U.S. critical technology companies. Importantly, beginning 10 November 2018, the pilot program mandates the submission of a short-form CFIUS filing for certain critical technology investments.
 
Parties can submit public comments by 10 November 2018, and any comments will be taken into account during the process of promulgating the final rule (probably sometime next year) and will not immediately affect the two new interim rules.
The Treasury Department chairs CFIUS, a U.S. government interagency committee that conducts national security reviews of foreign investments. The Treasury’s amendments to CFIUS’ existing regulations take effect 11 October 2018 (31 C.F.R. Part 800), and the interim pilot program will take effect on 10 November 2018 (31 C.F.R. Part 801). These two sets of temporary regulations do not reflect the full scope of the regulations that ultimately will be promulgated pursuant to FIRRMA.
 
Pilot program
 
CFIUS has longstanding power to review transactions in which a foreign person could gain control of a U.S. business, but the new pilot program expands this power to cover investments in certain industries involving critical technology and partially implements FIRRMA’s mandatory declaration provisions. Under the pilot program, CFIUS will now have authority to review certain non-controlling investments in so-called pilot program industries, which include, among others, aerospace/defense, nuclear power, petrochemical manufacturing, telecommunications, battery manufacturing, nanotechnology, biotechnology, and semiconductors. The Treasury’s complete list of these pilot program industries is included below.
The pilot program expands CFIUS’ jurisdiction to cover so-called pilot program covered investments – namely, non-controlling foreign investments in a U.S. business that meet these criteria:
 
* The U.S. business is a pilot program U.S. business, meaning that it is a U.S. business that
  – “produces, designs, tests, manufactures, fabricates, or develops” critical technology that is used in the business’s activity in a pilot program industry (see list of 27 pilot program industries below); or
  – designs such technology for use in such an industry.
 
* The investment affords the foreign investor
  – access to any material nonpublic technical information of the U.S. business;
  – membership or observer rights on the U.S. business’s board of directors or the
right to nominate a member of the U.S. business’s board of directors; or
  – involvement, other than by shareholder voting, in the U.S. business’s decision- making regarding critical technology.
 
Critical technologies include
* many items subject to the Export Administration Regulations, including those controlled for reasons of national security (NS), chemical and biological weapons proliferation (CB), nuclear nonproliferation (NP), missile technology (MT), regional stability (RS), or surreptitious listening (SL);
* all defense articles and defense services subject to the International Traffic in Arms Regulations;
* nuclear-related items covered by 10 C.F.R. part 810 and 10 C.F.R. part 110;
* select agents and toxins covered by 7 C.F.R. part 331, 9 C.F.R. part 121, or 42 C.F.R. part
73; and
* emerging and foundational technologies (which ultimately will be identified and controlled pursuant to the Export Control Reform Act of 2018).
 
The pilot program also mandates the submission of a declaration (short-form filing) for any controlling or non-controlling investment in a pilot program U.S. business. Parties must submit the declaration (i) 45 days prior to closing or (ii) if the closing will occur between 10 November 2018 and 25 December 2018, on 10 November 2018 or “promptly thereafter.” CFIUS has not previously mandated filings. Parties that are required to file a mandatory declaration under the pilot program but fail to do so can face steep penalties – up to the value of the transaction.
As noted above, the pilot program will go into effect on 10 November 2018. The interim rule provides, however, that parties will not be subject to the pilot program regulations if
 
* the closing of the transaction occurs before 10 November 2018; or
* before 11 October 2018
  – the parties executed a binding written agreement establishing material transaction terms;
  – a party has made a public offer to shareholders to buy shares of the U.S. business; or
  – a shareholder has solicited proxies in connection with an election of the board of directors of the U.S. business or requested the conversion of convertible voting securities.
 
Revisions to existing CFIUS regulations
 
The Treasury’s interim rule updating the existing CFIUS regulations implements certain other provisions of FIRRMA, including, among others, an extended initial review period lasting 45 (rather than 30) days and CFIUS’ ability to extend investigations by 15 days in “extraordinary circumstances.” Both of these provisions in particular went into effect immediately when FIRRMA was signed into law on 13 August 2018. These amended regulations took effect on 11 October 2018.

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

(Source:
Law Offices of George R. Tuttle, 13 Oct 2018.)
 
* Author: George R. Tuttle III, Esq., Law Offices of George R. Tuttle, geo@tuttlelaw.com, +1 415-986-8780.
 
Miscellaneous Tariff Bill Act of 2018
 
The President signed H.R. 4318 Miscellaneous Tariff Bill Act of 2018 (MTB) into law on September 13, 2018. The MTB amends the HTSUS to suspend and reduce tariffs on 1,660 products through December 31, 2020. These amendments are pursuant to the new process established in the American Manufacturing and Competitiveness Act of 2016.
 
Previously Congress determined which products should be eligible for duty suspension and reduction. Under the new process, the U.S. International Trade Commission collects industry petitions and public comments, analyzes the data and makes the final determinations on duty suspension and reduction with federal agency input.
 
MTB duty suspensions and reductions are effective for goods entered or withdrawn from a warehouse for consumption on or after October 13, 2018 and will remain in effect until December 31, 2020. All MTB provisions are in HTSUS subchapter II to chapter 99. ACE will be updated prior to the October 13 implementation date.
 
According to CSMS# 18-000606, products subject to Section 301 tariffs can benefit from MTB suspensions and reductions for the general (column 1) duty rate. However, these products remain subject to 25% ad valorem duty rate imposed by headings 9903.88.01 and 9903.88.02 or the 10% ad valorem duty rate imposed by headings 9903.88.03 and 9903.88.04.
 
Sets and Section 301 Duties
 
In a September 6, 2018 ruling HQ H299857, CBP determined that a toolset that is classifiable under a subheading not covered by the Section 301 tariffs is still subject to those tariffs because one of the components is subject to the tariffs. The September 6 ruling was in response to a request to reconsider CBP’s earlier ruling where it applied the Section 301 rates to the entire toolset even though only a portion of the elements of the set would be subject to 301 rates if entered separately.
 
The ruling involved a 129-piece mechanic’s toolset from China. CBP initially found that the set was best classified under 8206.00.00 as “tools of two or more headings 8202 to 8205, put up in sets for retail sales.” The duty rate for that subheading is based on the “rate of duty applicable to the article in the set subject to the highest duty rate” CBP wrote in the initial ruling.
The highest duty rate was for 8466.10.0175, the classification for five items in the set, at 3.9% plus the 25% section 301 tariff rate applicable to those items. Thus, CBP calculated the total duty rate to be 28.9%.
 
The requester for reconsideration argued that this duty rate was incorrect and too high citing the Section 301 FAQ which said that if a set is classified outside the tariffs, the 301 duties won’t be assessed on individual components. CBP responded that those FAQ instructions apply only “to sets classified in accordance with General Rule of Interpretation (‘GRI’) 3.”
 
This toolset was instead classified by reference to GRI 1, and CBP contended that the FAQ instructions were not applicable to this toolset. CBP further pointed out that unlike sets classified under GRI 3, this toolset was not classified under the subheading and with the duty rate for the component that imparted the essential character for the toolset. This toolset duty rate was determined based on the article with the highest duty rate and the entire set must be taken into account. CBP stated the it couldn’t “ignore the additional duty imposed by Chapter 99 in determining what is the highest duty rate, by examining what the duty rate would have been absent the additional duty imposed by Chapter 99, and then determining if that component is subject to the 301 provisions.” 
 
Final TFTEA Drawback Regulations Must Take Effect by December 17
 
The Court of International Trade ruled on October 12, 2018 that CBP must file a final rule for drawback under the Trade Facilitation and Trade Enforcement ACT (TFTEA) with the Office of the Federal Register by December 17, 2018. The final rule will be effective when filed, except for provisions involving drawback for excise taxes. The excise tax provisions may take effect 60 days after publication.
 
This is the latest ruling in a lawsuit brought against CBP that contends that the government is improperly not processing requests for accelerated payment on TFTEEA drawback claims.

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

(Source:
European Sanctions Blog, 15 Oct 2018.)
 
* Author: Michael O’Kane, Esq., Peters & Peters Solicitors LLP,
mokane@petersandpeters.com.
 
The EU announced today that it has adopted a new sanctions regime to “address the use and proliferation of chemical weapons”. As a result, the EU will now be able to impose an EU-wide travel ban and/or asset freeze on those “involved in the development and use of chemical weapons anywhere, regardless of their nationality and location”. The EU legal acts will be published in the Official Journal in due course.
 
It is reported that Anatoliy Vladimirovich Chepiga and Alexander Mishkin – the two Russian military intelligence officers allegedly involved in the Novichok poisoning of Sergei and Yulia Skripal in Salisbury, UK – will be the first targets sanctioned under the new regime.

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

(Source:
Volkov Law Group Blog, 14 Oct 2018. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group, mvolkov@volkovlaw.com, 240-505-1992.
 
United Technologies recently settled an FCPA enforcement action with the SEC by paying $13.9 million for bribes paid by its elevator and aircraft businesses. UT disclosed the investigation to DOJ and the SEC in late 2013 or early 2014. DOJ declined to prosecute in March 2018. UT agreed to disgorge $9 million, plus interest of about $919,000 and to pay a penalty of $4 million.
 
The SEC’s FCPA settlement contains extensive details on the conduct and the alleged violations ranging from bribery through third parties to excessive gifts and entertainment involving two significant subsidiaries, Pratt & Whitney and Otis Elevator. The settlement focused on bribery schemes in Azerbaijan and China relating to third-party bribery payments. In addition to these two bribery schemes, UT was cited for improper trips and gifts paid by Otis and its Pratt & Whitney division to foreign officials in China, Kuwait, South Korea, Pakistan, Thailand and Indonesia.
 
In this episode, Michael Volkov discusses the SEC’s settlement with UTC and identifies important lessons learned from the investigation.

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

MSEX/IM MOVERS & SHAKERS

MS_a111. Monday List of Ex/Im Job Openings: 150 Openings Posted This Week, Including 14 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

 

#
Aerion Supersonic; Reno, NV;
Export Control Officer
;

* Aerojet Rocketdyne; Canoga Park, CA; 
Manager, Industrial Security & Compliance
;

* Agility; Bensenville, IL; Ocean Export Coordinator; 


Agility; Basel, Switzerland; 
International Exhibition Coordinator
 

* Agility; Carson, CA;
Air Export Coordinator
;
* Agility; Charlotte, NC;
Import Manager/Licensed Customs Broker
;
* Agility; East Boston, MA; Customs/Entry Writer Coordinator
 ;


* Agility; Queens, NY;
Air Export Supervisor
;

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

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

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

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

# Amazon; Washington D.C., DC; Manager, Export Control & Trade Compliance;

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;

# BAE Systems; Poznań, Poland; Export Control Officer;

* Bio-Rad Laboratories: Hercules, CA;
Regional Trade Compliance Manager – Americas
; Requisition ID: 2018-8158; kelly_demorais@bio-rad.com;
* Bio-Rad Laboratories; Hercules, CA;
Sr. Trade Compliance Specialist
; Requisition ID: 2018-8159; kelly_demorais@bio-rad.com;

*
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;

* Curtiss-Wright Corporation; Bournemouth, Dorset, UK; Senior Trade Compliance Manager; Requisition ID: 3621

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

*
 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.; San Jose, CA;
 
Trade Compliance Manager
;
#
Export Solutions, Inc.; Part-Time (Remote);
 
Trade Specialist – Classification
;

* Flash Global; Sao Paolo, Brazil;
Import and Export Analyst III
;

* 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;  
 

* FLIR; Täby, Sweden; 
GTC EMEA Customs Analyst
;

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

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

* General Atomics; San Diego, CA; 
Experienced Project Manager – Compliance Management
; Requisition ID: 20913BR

#
General Atomics; San Diego, CA;
Government Compliance Specialist
; Requisition ID: 20593BR

* General Atomics; San Diego, CA; 
Senior Government Compliance Specialist
; Requisition ID: 20736BR


#
General Dynamics Information Technology; Washington D.C., DC;
Export Control Analyst
;

* Google; Mountain View, CA; 
Trade Specialist, Export Compliance
; sdemian@google.com;
* 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 

* Harris Corporation; Rochester, NY; Government Compliance Shipping; Requisition ID: CS20181709-27381 
* Henderson Group Unlimited, Inc; State Dept, DDTC; Washington, DC; 
Defense Trade Control Compliance Analyst
;
* Henderson Group Unlimited, Inc; State Dept, DDTC; Washington, DC; 
Commodities Jurisdiction Analyst
;

* Hitachi Vantara; Englewood, CO, Santa Clara, CL; 
Trade Compliance Specialist

* 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

#
Indiana University; Bloomington, IN;
Export Control Specialist, Office of Research Compliance
;
#
Infineon Technologies; El Segundo, CA;
Export Compliance Specialist
;

* Infineon Technologies; Munich, Germany; Manager Export Control;
* Infineon Technologies; Munich, Germany; Specialist Export Control;

#
Inmarsat; London, UK; Export Control Officer;

*
 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; GA; 
Import Specialist; 
Requisition ID: 61165
* Livingston; IL; 
Import Specialist; 
Requisition ID: 60803


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

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

* Lockheed Martin; Bethesda, MD;
Regulatory Compliance Analyst
; Requisition ID: 449353BR

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


* Lockheed Martin; Forth Worth, TX;
International Trade Compliance Analyst
; Requisition ID: 447332BR
* Lockheed Martin; Orlando, FL;
International Trade Compliance Sr. Manager
; Requisition ID: 451764BR

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

*
 L-3 Warrior Sensor Systems; Middle East;
International Business Development Manager – Middle East Region
; Requisition ID: 093343

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

#
Mitel; Ontario, CA;
Import/Export Analyst- Trade Compliance
;

* 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.

* Northrop Grumman; Baltimore, MD;
Manager 2, International Trade Compliance
; Requisition ID:
18017919
* Northrop Grumman; Linthicum, MD;
Manager Regulatory Compliance 2
; Requisition ID:
18016051
* Northrop Grumman; Orlando, FL;
International Trade Compliance Analyst 2
; Requisition ID: 18020191
* Northrop Grumman; Redondo Beach, CA;
International Trade Compliance Analyst 4
; Requisition ID: 18021390

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

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

* 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

* 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  


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

* Textron Aviation; Wichita, KS;
Trade Compliance Analyst
; Requisition ID: 269127

* 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

#
Tyssenkrupp; Essen, Germany;
Head of Export Control and Customs (ECC)
;

* 
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 Program Manager, ITC Operations
; Requisition ID: 71195BR

* 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 

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

TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a112. ECTI Presents “A Deep Dive into AES” – 13 Nov
(Source: Danielle Hatch, danielle@learnexportcompliance.com)
 
* What: A Deep Dive into AES
* When: November 13, 2018; 1:00 p.m. (EST)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Jonathan Young
* Register: Here or Danielle Hatch, 540-433-3977, danielle@learnexportcompliance.com
* * * * * * * * * * * * * * * * * * * *

ENEDITOR’S NOTES

e. e. cummings (Edward Estlin “E. E.” Cummings; 14 Oct 14, 1894 – September 3, 1962), often styled as “e e cummings”, as he sometimes signed his name, was an American poet, painter, essayist, author, and playwright. He wrote approximately 2,900 poems, two autobiographical novels, four plays, and several essays.  Cummings is associated with modernist free-form poetry. Much of his work has original syntax and uses lower case spellings for poetic expression. His use of lower case extended to rendering even the personal pronoun I as “i”, as in the phrase “i shall go”. Cummings was politically neutral most of his life until the rise of the Cold War when he became a Republican and a supporter of Joseph McCarthy. He taught briefly at Harvard University in the 1950s, before his death in 1962.)
  – “Private property began the instant somebody had a mind of his own.”
  – “The most wasted of all days is one without laughter.”
 
* Friedrich Nietzsche (Friedrich Wilhelm Nietzsche; 15 Oct 1844 – 25 Aug 1900; was a German philosopher, cultural critic, composer, poet, philologist, and a Latin and Greek scholar whose work has exerted a profound influence on Western philosophy and modern intellectual history. Prominent elements of his philosophy include his radical critique of truth in favor of perspectivism; his genealogical critique of religion and Christian morality and his related theory of master-slave morality; his aesthetic affirmation of existence in response to the “death of God” and the profound crisis of nihilism. His eighteen books include Thus Spoke Zarathustra, Beyond Good and Evil, and On the Genealogy of Morality. 
  – “It is not a lack of love, but a lack of friendship that makes unhappy marriages.”
 
Monday is pun day:
 
Q: What do you call an alligator in a vest? 
A: An investigator.
 
Q: What do you call a classy fish? 
A: Sofishticated.
 
Q: Why are teddy bears never hungry?
A: Because they’re always stuffed.

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

EN_a314
. 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: 26 Sep 2018: 83 FR 48532-48537: Addition of Certain Entities to the Entity List, Revision of an Entry on the Entity List and Removal of an Entity From the Entity List

  
*
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: 11 Oct 2018: 
Harmonized System Update 1816
, containing 6,042 ABI records and 1,516 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:
4 Oct 2018: 83 FR 50003-50007: Regulatory Reform Revisions to the International Traffic in Arms Regulations.

  – The only available fully updated copy (latest edition: 4 Oct 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_a0315
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.

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