18-1029 Monday “Daily Bugle”

18-1029 Monday “Daily Bugle”

Monday, 29 October 2018

The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce: “Addition of Fujian Jinhua Integrated Circuit Company, Ltd (Jinhua) to the Entity List”
  3. DoD/DSCA Posts 2 New Policy Memos
  4. State/DDTC: (No new postings.)
  1. Court News UK: “Elderly Couple ‘Duped into Supplying Aircraft Parts to Iran'”
  2. Defense News: “Export Constraints Emerge as Sticking Point for Future German-French Combat Aircraft: Report”
  3. Financial Times: Chinese Military Researchers Exploit Western Universities”
  4. Reuters: “Germany Seeks Common European Response on Saudi Arms Sales Over Khashoggi Killing”
  5. ST&R Trade Report: “Dispute Settlement, Trade Negotiations, Transparency Among Focuses of WTO Reform Effort”
  1. L. Colombo: “Does Cloud-Based Data Storage Still Work Under GDPR?”
  2. O. Torres, A. Fraser-Reid & D. Kyle: “A Crude Awakening: U.S. Sanctions on the Russian Oil Sector”
  1. Monday List of Ex/Im Job Openings: 151 Openings Posted This Week, Including 19 New Openings
  1. ECTI Presents “Export Compliance Toolkit: Checklists and Workflows” on 7 Nov 2018
  2. FCC Presents “Designing an Internal Compliance Program for Export Controls & Sanctions”, 5 Feb 2019 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 (24 Oct 2018), FACR/OFAC (29 Jun 2018), FTR (24 Apr 2018), HTSUS (22 Oct 2018), ITAR (4 Oct 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 



[No items of interest noted today.]
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OGS_a11. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* Commerce/BIS; RULES; Entity List: Addition [Pub. Date: 30 Oct 2018.]
* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Pub. Date: 30 Oct 2018.]

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Commerce: “Addition of Fujian Jinhua Integrated Circuit Company, Ltd (Jinhua) to the Entity List”
Commerce, 29 Oct 2018.) 
Effective October 30, 2018, the Department of Commerce has taken action to restrict exports to Fujian Jinhua Integrated Circuit Company, Ltd. (Jinhua) by adding them to the Entity List (Supplement No. 4 to Part 744 of the Export Administration Regulations (EAR)), because Jinhua poses a significant risk of becoming involved in activities that are contrary to the national security interests of the United States.
Jinhua is nearing completion of substantial production capacity for dynamic random access memory (DRAM) integrated circuits. The additional production, in light of the likely U.S.-origin technology, threatens the long term economic viability of U.S. suppliers of these essential components of U.S. military systems.
  “When a foreign company engages in activity contrary to our national security interests, we will take strong action to protect our national security. Placing Jinhua on the Entity List will limit its ability to threaten the supply chain for essential components in our military systems,” Secretary of Commerce Ross said.
Pursuant to Section 744.11(b) of the EAR, the Entity List identifies entities reasonably believed to be involved, or to pose a significant risk of being or becoming involved, in activities contrary to the national security or foreign policy interests of the United States. The EAR imposes additional license requirements on, and limits the availability of most license exceptions for, exports, re-exports, and transfers (in-country) to listed entities.
As a result of adding Jinhua to the Entity List, a license is required for all exports, re-exports, and transfers of commodities, software and technology subject to the EAR to Jinhua. Such license applications will be reviewed with a presumption of denial.

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DoD/DSCA Posts New Policy Memo 

DoD/DSCA, 29 Oct 2018.) 
This memo revises 
Table C4.T2B. – Security Cooperation (SC) Customer and Regional Codes and FMS Eligibility (DSCA/DFAS Reserved)
C15.T2. – Afghanistan Security Forces Fund (ASFF))
 to assign Program Code “QB” to track FY 2019 Afghanistan Security Forces Funds (ASFF).

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State/DDTC: (No new postings.)


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Court News UK, 29 Oct 2018.) [Subscription required; excerpts.]
A naive couple who were “groomed” into supplying embargoed components for Iran’s nuclear programme have been spared jail. Paul Attwater, 65, and Iris Attwater, 66, smuggled prohibited aircraft parts to Alexander George, 76, in Malaysia from their company Pairs Aviation. But the couple were handed suspended sentences after Mr Attwater insisted he had no idea the “nuts and bolts” he was exporting had a military application. George, who is due to be sentenced next month, acted as a broker between … 

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Defense News: “Export Constraints Emerge as Sticking Point for Future German-French Combat Aircraft: Report”

Defense News, 28 Oct 2018.) [Excerpts.] 
French-German plans for a joint fighter aircraft project may be off to a rocky start, as reports emerged last week about fundamental disagreements between the two partners over export restrictions for such a weapon.
According to a report on the website of the German magazine 
Der Spiegel, French negotiators made unlimited exportability of the so-called “Future Combat Air System” a prerequisite for getting started on the project. 
The position is at odds with a more restrictive policy by Berlin, where arms deals to sensitive countries traditionally are more heavily scrutinized for the potential of human-rights abuses by the recipient government. 
The Spiegel based its report on a four-page confidential cable from Germany’s ambassador in Paris, Nikolaus Meyer-Landrut, describing the outcome of a Sept. 21 “crisis meeting” in the French capital.
So deep ran the diverging views at the gathering that Claire Landais, the French secretary-general for defense and national security, threatened to cancel further planning unless Germany would agree to French demands for unconstrained exports of the future combat aircraft, according to the Spiegel.
Airbus CEO Tom Enders, whose company is involved in the 
planning alongside Dassault Aviation, criticized the reported German insistence on export caveats. “Berlin can’t urge greater European cooperation in its Sunday speeches and then refuse it when concrete projects are taking shape,” he told the magazine.
The idea behind the Future Combat Air System program is to create a sixth-generation aircraft that would eventually help wean European air forces from U.S.-made hardware. A development contract is eyed for the mid-2020s following years of concept studies. … 

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Financial Times: Chinese Military Researchers Exploit Western Universities”

Financial Times, 29 Oct 2018.) [Excerpts.] 
Study shows US and UK scientists aiding high-tech progress for People’s Liberation Army.
China has sent thousands of scientists affiliated with its armed forces to western universities – especially in countries that share intelligence with the US – and is building a web of research collaboration that could boost Beijing’s military technology development.
About 2,500 researchers from Chinese military universities spent time at foreign universities – led by the US and UK – over the past decade, and many hid their military affiliations, according to a new report from the Australian Strategic Policy Institute (ASPI), a think-tank partly funded by Australia’s department of defense.

The research effort focused on members of the so-called “Five Eyes” group of countries with which the US shares an intelligence relationship: the UK, Australia, New Zealand and Canada. Over the past five years, researchers affiliated to the People’s Liberation Army published more joint papers with scientists from the UK and the US than with those of any other country. … 

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Reuters: “Germany Seeks Common European Response on Saudi Arms Sales Over Khashoggi Killing”

Reuters, 27 Oct 2018.) [Excerpts.] 
Germany, which has pledged to suspend arms exports to Saudi Arabia over the killing of journalist Jamal Khashoggi, said on Saturday it expects the European Union to adopt a common position on potential limits to weapons sales. 
The killing of Khashoggi – a Washington Post columnist and a critic of Saudi Arabia’s de facto ruler, Crown Prince Mohammed bin Salman – has sparked global outrage and pitched the world’s top oil exporter into crisis.
The incident has put the West’s relationship with Riyadh into sharp focus, given scepticism about Saudi Arabia’s shifting explanations of the killing at the Istanbul consulate. The kingdom’s public prosecutor said this week the killing was premeditated, contradicting a previous official statement that it happened accidentally.
  “We agreed that when we have more clarity… we will try to find a unified European solution or reaction from all member states of the European Union,” German Chancellor Angela Merkel said, referring to the sale of arms to the kingdom.
She was speaking at a joint news conference with French President Emmanuel Macron as well as Russian President Vladimir Putin and Turkish President Tayyip Erdogan at the conclusion of a four-way summit on Syria.
Macron said that any decisions that would be taken, including potential sanctions, must be made at the European level to ensure coordination.
Merkel has previously vowed to halt all German arms exports to Saudi Arabia until the killing is explained. Macron has said he told Crown Prince Mohammed that France, and its partners, could take action against those held responsible for the murder.
France, along with the United States and Britain, is one of the main arms suppliers to Saudi Arabia and its Gulf Arab allies. … 

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ST&R Trade Report: “Dispute Settlement, Trade Negotiations, Transparency Among Focuses of WTO Reform Effort” 

Sandler, Travis & Rosenberg Trade Report, 29 Oct 2018.)
Stating that the current situation at the World Trade Organization “is no longer sustainable,” 13 WTO members have identified a functioning dispute settlement system, a reinvigorated negotiating function, and more transparency into members’ trade policies as the three areas they intend to focus on as part of an emerging WTO reform effort. In a joint communique issued at the end of an Oct. 24-25 meeting in Ottawa, these members expressed a “common resolve for rapid and concerted action” on these issues and said they will meet again in January to review progress. The U.S. and China are not currently included in this discussion group.
The countries said the rules-based multilateral trading system embodied by the WTO has helped foster “an unparalleled chapter in global prosperity, growth, and job creation around the world.” However, they added, this system now faces “unprecedented challenges,” including a rise in protectionism, growing trade tensions linked to major shifts in the global trading landscape, and difficulties in concluding negotiations. To address these concerns and restore confidence in the WTO, the members identified three issues requiring “urgent consideration.”
Dispute settlement – unblocking the appointment of Appellate Body members and discussing ways to improve the functioning of the dispute settlement system while preserving its essential features
Negotiation – concluding negotiations on fisheries subsidies in 2019, updating WTO rules to reflect 21st century realities (which may require flexible and open negotiating approaches toward multilateral outcomes), addressing market distortions caused by subsidies and other instruments, and exploring how to best pursue development (including special and differential treatment) in rulemaking efforts
Transparency – strengthening the monitoring and transparency of members’ trade policies, including by improving members’ compliance with their notification obligations
The communique states that these objectives “will only be reached through sustained and meaningful political engagement and through dialogue with all WTO members.” The 13 participants therefore offered a political commitment to “moving forward urgently” on these issues, including by working “constructively and collaboratively” with other WTO members who have offered their own proposals. The European Union noted that the meeting’s outcome “broadly supports” the proposals it made in a September concept paper.
House Ways and Means Committee Chairman Kevin Brady, R-Texas, said he supports the goals outlined above and offered specific outcomes he would like to see achieved. These include “meaningful consequences” for WTO members that do not timely submit notifications of compliance with their obligations, “procedural fixes” to prevent the Appellate Body from diverging from established timelines and procedures, and structural reforms “to avoid troubling Appellate Body overreach and ‘gap-filling’ that go beyond its mandate.”

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L. Colombo: “Does Cloud-Based Data Storage Still Work Under GDPR?”

The FCPA Blog, 29 Oct 2018.) [Excerpts.] 
* Author: Lindsay Colombo, Esq. and founder of 
eSpear LLC. She can be contacted 
For most companies looking for a third-party compliance solution now opt to have their data stored on cloud servers located in the jurisdictions where their employees are located and where their business operations take place. However, some companies prefer to host data on in-house, installed solutions.
Installed solutions can create a lot of extra work, liability, downtime and cost to customers. And yet there are advantages to using in-house servers, as well as some preference towards using them in light of recent privacy regulations and scandals.

For example, under the EU’s GDPR, companies are facing new concerns about cloud storage. Providers, data controllers and users are equally responsible for violations and data breaches. This forces providers such as third-party compliance vendors to raise their standards in order to meet the obligations of the GDPR and be equipped to do business with customers. … 

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O. Torres, A. Fraser-Reid & D. Kyle: “A Crude Awakening: U.S. Sanctions on the Russian Oil Sector”

Torres Trade Law, 22 Oct 2018.) [Excerpts.] 
* Author’s Note: Olga Torres, Esq.; Andrea Fraser-Reid, Esq.; and Derrick Kyle, Esq. All of Torres Trade Law. 
This article will discuss U.S. economic sanctions on Russia as enforced by the Office of Foreign Assets Control (“OFAC”), a government agency within the U.S. Department of the Treasury. Specifically, we will provide an overview of Directive 4 to Executive Order 13662 (“Directive 4”), which prohibits certain transactions related to the Russian oil sector. While Directive 4 does not prohibit all oil sector transactions with companies in Russia, it does create many potential obstacles for U.S. businesses. We will also briefly discuss Russian oil sector prohibitions administered by the Department of Commerce Bureau of Industry and Security (“BIS”). Russia and Texas are two of the largest producers of oil and gas in the world, and, because many companies involved in the petroleum industry in Texas have dealings with Russian entities or individuals, they are likely to be faced with sanctions issues. … 
[Editor’s Note: This article first appeared in the Newsletter of the International Law Section (www.ilstexas.org) of the State Bar of Texas. To read the entire item, click on the source link below the item title.] 

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MS_a112. Monday List of Ex/Im Job Openings: 151 Openings Posted This Week, Including 19 New Openings

(Source: Editor) 

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


” New or amended listing this week


Acco Brands; Lake Zurich, IL; 
North America Trade Compliance Specialist Classification

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

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

Analog Devices; Wilmington, MA; 
Director, Global Trade Compliance

Apple; Cupertino, CA; 
Export Compliance Progam Manager

* Arrow; Shanghai, China; Compliance Manager;

Ascent Aerospace; Lake Orion, MI; 
ITAR/EAR/Export Compliance Manager

ASML; Veldhoven, Netherlands; 
Expertise Manager Export Control;

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

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

Boeing; Saint Louis, MO; 
Trade Control Specialist
Requisition ID 1800078843

* Boeing; Zoushan, China; 
 Compliance Analyst
* Boeing; Zoushan, China;
Trade Compliance Manager;

Cubic; San Diego, CA; 
Export Compliance Analyst
; Requisition ID: 15764

Culmen International; Alexandria, VA; 
Government Property and Export Control Specialist

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

Doosan; West Fargo, ND; Director Customs & Trade Compliance

DynCorp International; Forth Worth, TX; 
Trade Compliance Manager
; Requisition ID: 1804484

 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;

Entegris; Shanghai, China; Senior Manager, ASJ Trade Compliance;

Esri; Redlands, CA; 
Export Compliance Specialist

* 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

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

* FLIR; Irvine, 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

Fortive; Irvine, CA; 
Export Control 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; Arlington, VA; 
Export Policy Analyst
; Requisition ID: 2018-48185 

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

Google; Sunnyvale, CA; 
Export Compliance Manager

Greene, Tweed & Co.; Kulpsville, PA; 
Export Compliance Specialist

* Harris Corporation; Van Nuys, CA; 
Trade Compliance Specialist
; 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 
# HealthNewCo; Irivine, CA; Director, Global Trade Compliance;
* 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

Henkel AG; Rocky Hill, CT; Global Trade Defense Information Manager;

* 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

* Infineon Technologies; El Segundo, CA;
Export Compliance Specialist

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

Infinera; Sunnyvale, CA; Director, Global Logistics and Trade Compliance;

* 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

Intertec International; tempe, AZ; 
Export Compliance Officer;

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

* 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; IL; 
Import Specialist; 
Requisition ID: 60803

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

* Lockheed Martin; Forth Worth, TX;
International Trade Compliance Analyst
; Requisition ID: 447332BR

Medtronic; Minneapolis, MN; Associate Export Controls Analyst; Requisition ID: 18000K22

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

Microsoft; Redmond, WA; 
Senior Trade Manager, Export Control

MIT Lincoln Laboratory; Cambridge, MA; 
Export Compliance & Document Control Analyst;

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
 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
 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:
* Northrop Grumman; Linthicum, MD;
Manager Regulatory Compliance 2
; Requisition ID:
* 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

NXP; Eindhoven, Netherlands; 
Trade Compliance Coordinator

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

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

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

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

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

* 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

 SABIC; Houston TX; 
Senior Analyst, Trade Compliance
; Requisition ID: 8411BR

* 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;

Supermicro; San Jose, CA; 
Import/Export Specialist;

* 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

Toyota Tsusho America; Georgetown, KY; 
Import Export Compliance Specialist;

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

University of South Florida; Tampa, FL; Export Control Officer;
Vigilant; Budapest, Hungary; Jr. Compliance Analyst;

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

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

* VT iDirect; Herndon VA;
Manager, Global Logistics
; Requisition ID: 2018R-3120-1;

Wesco International; Houston, TX; 
Export Compliance Specialist

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

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

XPO Logistics; Amsterdam, Netherlands; Compliance Officer;

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

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


TE_a113ECTI Presents “Export Compliance Toolkit: Checklists and Workflows” on 7 Nov 2018 

(Source: D. Hatch, 
* What: Export Compliance Toolkit: Checklists & Workflows
* When: November 7, 2018; 1:00 p.m. (EST)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Felice Laird
* Register: 
here or Danielle Hatch, 540-433-3977, 

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

TE_a214FCC Presents “Designing an Internal Compliance Program for Export Controls & Sanctions”, 5 Feb 2019 in Bruchem, the Netherlands

(Source: Full Circle Compliance, 
The next Full Circle Compliance (FCC) academy course is specifically designed for beginning compliance professionals who aim to enhance their organization’s compliance efforts.  The course will cover multiple topics and tackle various questions, including but not limited to:
 – Setting the Scene: ensuring compliance in the export control and sanctions arena
 – What is expected from your organization? A closer look at the frameworks and guidelines from U.S. and European government agencies (incl. State/DDTC, Commerce/BIS, Treasury/OFAC, European Union, The Netherlands, and Germany) 
 – Key elements of an Internal Compliance Program
 – Strategic benefits of an Internal Compliance Program
 – Best practice tips for enhancing your compliance activities
 – Compliance Toolkit: internal controls samples (policies, procedures, instructions, checklists)
* What: Designing an Internal Compliance Program for Export Controls & Sanctions 
* When: Tuesday, 5 Feb 2019, 9.00 AM – 4.30 PM (CET)
* Where: Landgoed Groenhoven, Bruchem, the Netherlands
* Sponsor: 
Full Circle Compliance (FCC)
* Instructors: Drs. Ghislaine C.Y. Gillessen RA, Marco F.N. Crombach MSc
* Information & Registration: via the 
event page, via
events@fullcirclecompliance.eu or call +31 (0)23 – 844 – 9046.

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James Cook (27 Oct 1728 – 14 Feb 1779; was a British explorer, navigator, cartographer, and Captain in the Royal Navy. Cook made detailed maps of Newfoundland before making three voyages to the Pacific Ocean, during which he achieved the first European contact with the Hawaiian Islands, the eastern coastline of Australia, and the first circumnavigation of New Zealand.)
– “Do just once what others say you can’t do, and you will never pay attention to their limitations again.”

Niccolo Paganini (27 Oct 1782 – 27 May 1840; was an Italian violinist, violist, guitarist, and composer. He was the most celebrated violin virtuoso of his time, and left his mark as one of the pillars of modern violin technique.)
  – “I am not handsome, but when women hear me play, they come crawling to my feet.”
Monday is pun day:  
* Q. What do mummies like listening to on Halloween?

        A. Wrap music!
* Q. Why didn’t the skeleton eat his Halloween candy?
        A. He didn’t have the stomach for it.
* Q. Why do ghosts like to ride in an elevator?
        A. It raises their spirits.
* Q.  What kind of a street do vampires like to live on?

        A.  A dead end.

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. 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.
: 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. 
: 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  


  – 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 

: 15 CFR Subtit. B, Ch. VII, Pts. 730-774

  – Last Amendment: 24 Oct 2018: 83 FR 53742-53793: Wassenaar Arrangement 2017 Plenary Agreements Implementation; Final Rule [Revision of EAR Parts 740, 742, 744, 772, and 774.]

: 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 

: 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
  – 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.  
, 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: 22 Oct 2018: Harmonized System Update 1818

containing 1,544 ABI records and 286 harmonized tariff records.

  – HTS codes for AES are available 
  – HTS codes that are not valid for AES are available 
  – 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
. BAFTR subscribers receive a $25 discount on subscriptions to the BITAR, please
contact us
to receive your discount code.

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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 

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* 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.

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