18-1112 Monday “Daily Bugle”

18-1112 Monday “Daily Bugle”

Monday, 12 November 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/BIS: (No new postings.)
  3. Justice: “Iranian National Pleads Guilty to Conspiring to Illegally Export Products from the United States to Iran”
  4. Justice: “Two Residents of Lebanon Arrested in Seattle in Connection with Scheme to Illegally Export Firearms to Lebanon”
  5. State Releases Conventional Arms Transfer Policy Implementation Plan Update
  6. State/DDTC: “Last Week to Test the New Advisory Opinions Application!”
  7. Treasury/OFAC Extends Expiration Date of Ukraine-Related General Licenses
  8. EU Publishes Regulation and Directive Related to Anti-Money Laundering Efforts
  1. Reuters: “U.S. Postpones Sanctions Deadline on Russian Tycoon’s Firms”
  2. The Wall Street Journal: “U.S. Adopts New Battle Plan to Fight China’s Theft of Trade Secrets”
  1. A. Minter: “Your Old Smartphone Is a Security Risk. Live With It”
  2. The Export Compliance Journal: “Fujian Jinhua Integrated Circuit Company, Ltd Added to Entity List Without Committing Export Violation”
  1. Monday List of Ex/Im Job Openings: 7 New Openings Posted This Week
  1. ECTI Presents “United States Export Control (ITAR/EAR/OFAC) Seminar Series” in San Diego, CA on 21-24 Jan 2019
  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 (1 Nov 2018), FACR/OFAC (5 Nov 2018), FTR (24 Apr 2018), HTSUS (2 Nov 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)

[No items of interest noted today.]

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Commerce/BIS: (No new postings.)


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Justice: “Iranian National Pleads Guilty to Conspiring to Illegally Export Products from the United States to Iran”

Justice, 8 Nov 2018.) [Excerpts.] 
Arash Sepehri, 38, a citizen of Iran, pleaded guilty on Nov. 7, to a federal charge stemming from his role in a conspiracy to cause the export of controlled goods and technology to Iran, in violation of U.S. Department of Commerce and military controls, as well as in contravention of sanctions imposed against Iran. … 
Sepehri pleaded guilty in the U.S. District Court for the District of Columbia, to conspiracy to unlawfully export U.S. goods to Iran in violation of the International Emergency Economic Powers Act and the Iranian Transactions and Sanctions Regulations, and to defraud the United States.
According to court documents filed in this case, Sepehri was an employee and a member of the board of directors of an Iranian company, Tajhiz Sanat Shayan, or Tajhiz Sanat Company (TSS).  TSS and other companies involved in the conspiracy were listed by the European Union on May 23, 2011, as entities being sanctioned for their involvement in the procurement of components for the Iranian nuclear program.  Through TSS and associated companies, Sepehri and others conspired to obtain high-resolution sonar equipment, data input boards, rugged laptops, acoustic transducers and other controlled technology from the United States without obtaining proper licenses and in violation of economic sanctions.
As stated in the court documents, Sepehri and his co-conspirators sought to evade legal controls through a variety of means, including the use of a variety of aliases, United Arab Emirates (UAE)-based front companies and an intermediary shipping company based in Hong Kong.  Payments for the goods were arranged through the UAE.
The conspiracy charge in this case is a felony punishable by a statutory maximum of five years in prison and potential financial penalties.  The maximum statutory sentence is prescribed by Congress and is provided here for informational purposes.  The sentencing of the defendant will be determined by the court based on the advisory Sentencing Guidelines and other statutory factors. The Honorable Rosemary M. Collyer scheduled sentencing for Jan. 16, 2019.

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Justice: “Two Residents of Lebanon Arrested in Seattle in Connection with Scheme to Illegally Export Firearms to Lebanon”

Justice, 9 Nov 2018.) [Excerpts.] 
Hicham Diab, of Tripoli, Lebanon, and Nafez El Mir, a Canadian citizen residing in Lebanon, were arrested yesterday after they traveled to a Seattle warehouse and began hiding firearms in a vehicle they planned to ship to Lebanon.  Diab and El Mir appeared in federal court this afternoon, charged with conspiracy to violate the Arms Export Control Act. … 
Both men were ordered detained pending additional hearings set for next week.
According to a criminal complaint unsealed today, in 2016, Diab began communicating with a person in the U.S. who Diab believed was willing to locate firearms for him to smuggle to Lebanon.  The person in the U.S. alerted Homeland Security Investigations (HSI) about the contact.  Over the course of 2017 and 2018, undercover HSI agents posed as people able and willing to supply firearms sought by Diab in furtherance of his smuggling scheme.  In October 2018, Diab made plans to come to the U.S. and successfully wired funds for the purchase of firearms and a vehicle in which to hide the firearms.  Diab arrived in Seattle on Nov. 7, and was accompanied by El Mir who, according to Diab, had experience smuggling firearms hidden in automobile panels.
On November 7 and 8, Diab went with the undercover agents to a warehouse containing firearms that had been secured by HSI and the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), and inspected the firearms, which included: twenty Glock handguns, a Smith & Wesson .50 revolver, one FN Fiveseven pistol, an AR15 rifle kit and a M203 grenade launcher.  Diab and El Mir, during their November 8 warehouse visit, began hiding the firearms in door panels and bumper space inside a sport-utility vehicle.  El Mir also discussed ways to get the vehicle shipped to Lebanon with the hidden weapons.  The men were arrested the evening of Nov. 8, as they exited the warehouse.
Conspiracy to violate the Arms Control Export Act is punishable by up to five years in prison.  . . .

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State Releases Conventional Arms Transfer Policy Implementation Plan Update

State, 8 Nov 2018.) 
In July, the Secretary of State submitted to the President the Implementation Plan requested as part of the 
Conventional Arms Transfer (CAT) Policy (NSPM-10). This plan supports the U.S. National Security Strategy through a whole-of-government approach to better align our conventional arms transfers with our national security and economic interests. 
In developing the 
CAT Policy Implementation Plan, and in order to ensure that it is fully integrated the real-world challenges we face, the Administration collected inputs from Congress, American industry and the non-governmental community. We are grateful for their cooperation in this process.
The Plan accounts for the increasingly competitive environment described in the National Security Strategy, and seeks to modernize the U.S. Government’s policies and processes regarding arms transfers. It establishes three Lines of Effort (LOE) to implement our CAT Policy goals. Each LOE is supported by a number of tasks that will be undertaken by the relevant U.S. Government agencies.
Line of Effort 1 – Prioritize Strategic and Economic Competition
This LOE directly addresses the challenges of increasing strategic competition, and enables the U.S. Government to prioritize allocation of its resources to overcome those challenges. It reorients the United States to a more proactive approach to arms transfers, and ensures these transfers reflect the priorities articulated in the National Security Strategy (NSS), the National Defense Strategy (NDS), the recent Report on Strengthening the Manufacturing and Defense Industrial Base and Supply Chain Resiliency of the United States that was mandated by Executive Order 13806, and other relevant strategic guidance. 
Tasks within this line of effort include:
  – Effectively compete with strategic competitors by providing allies and partners with alternatives to foreign defense articles in order to maintain U.S. influence in key regions;

Identify critical partner capability requirements essential to achieving U.S. foreign policy and national security objectives; 
  – Prioritize and expedite critical transfers that reflect these partner capability requirements;

Identify and revise outdated arms transfer policies that are legacies of past international security challenges; and

Develop holistic policies in support of arms transfers by creating proactive, strategic policy guidance to prevent ad hoc decisions on individual transfers.
Line of Effort 2 – Organize for Success
This LOE ensures that the Executive Branch is organized, staffed, and resourced to best support efficient execution of the conventional arms transfer policy, and that its processes are similarly aligned. 
Tasks under this LOE include:
  – Streamline the International Traffic in Arms Regulations (ITAR), with the goal of reducing regulatory burdens for U.S. industry and barriers to the commercial defense trade; 

Revise the United States Munitions List (USML) to ensure that it clearly describes and adequately controls only those items that merit USML control;

Update the Commerce Control List (CCL) to account for technological developments, practical application issues identified by exporters and re-exporters, and changes in the military and commercial non-military applications of controlled items; 
  – Facilitate exports for certain U.S. and cooperative programs so that the U.S. government has the needed flexibility to execute its mission; 
  – Establish objective milestones and standard timelines for Foreign Military Sales (FMS) to enable increased transparency, enhance the Defense acquisition system’s ability to meet critical FMS milestones and timelines, and to assist industry planning for FMS case execution;

Increase the competiveness of high-demand American weapons systems by identifying and assessing challenges and developing potential solutions for those challenges;

Build exportability, coalition interoperability, and configuration standardization into the Defense Department capability requirements development and approval processes; 

Improve contracting for FMS through innovative and pilot programs such as those made available in section 830(d) of the FY 2017 National Defense Authorization Act;

Enhance U.S. Government advocacy so we can apply the full weight and influence of the United States in support of defense exports that are in our national interest;

Expand support for Non-Programs of Record to broaden the scope of American defense offerings in order to better address partner demand; 

Improve FMS Letter of Offer and Acceptance (LOA) processes and policies so that U.S. offerings will be more responsive and competitive in foreign competitions;

Examine the U.S. Government policy on offsets to ensure that it is relevant and effective in promoting American exports and protecting American technologies and jobs; and 

Develop financing options to support foreign partner procurements of U.S. defense articles. 
Line of Effort 3 – Create Conducive Environments 
The intent of this line of effort is to ensure that Congressional, business, and international climates foster efficient operation of U.S. defense trade. 
Tasks in this line of effort include:
  – Improve the FMS requirements development approach to assist foreign partners in better identifying desired capabilities;

Reduce costs associated with FMS such as surcharges and fees;
  – Improve the funding flexibility associated with FMS to reduce prohibitive upfront costs for partners; 
  – Request from Congress, where needed, legislative changes regarding contracting requirements for FMS, in order to enhance the speed of the contracting processes and lower unit costs for U.S. military services;

Establish an Offset Task Force to develop recommendations, in consultation with industry, on actions that could be taken to minimize the adverse impact of offsets in defense trade while not hindering the flexibility of U.S. industry as it competes in the global defense market;

Modernize the Missile Technology Control Regime to reflect advances in technology while continuing to constrain the proliferation of systems that can deliver weapons of mass destruction; 

Improve trade promotion and expand U.S. Government engagement in support of American defense manufacturing; and

Work with U.S. industry to incentivize increased production capacity and timely delivery, including by developing strong and stable market signals and by utilizing contracting approaches that reward faster delivery. 
Progress and the Way Ahead
The Administration is assessing progress on a quarterly basis, and revising the plan where needed. We continue to solicit input from industry, non-governmental organizations, and Congress to improve the arms transfer process, as well as feedback on the results of our efforts. To date, the Administration has made great progress in developing strategies to compete against strategic and economic rivals, has revised numerous policies to increase U.S. competitiveness, has reduced costs, is on track to streamline regulations and improve processes, among other accomplishments.
For further information, please contact the 
Bureau of Political-Military Affairs, Office of Congressional and Public Affairs at 
PM-CPA@state.gov, and follow the Bureau of Political-Military Affairs on Twitter, 

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State/DDTC: “Last Week to Test the New Advisory Opinions Application!”

State/DDTC, 9 Nov 2018.) 
Haven’t had a chance to test out DDTC’s new online 
Advisory Opinions Application? Try it out now before the testing period ends on Friday, 16 November at 5pm. It’s quick and easy.
  (2) First time users must enroll to create a new user account, then use their account to login to the DECCS Portal. 
  (3) Once logged in, users can select Advisory Opinion from the menu bar at the top of the page to test the online form. 
  (4) Provide feedback through the “Submit Feedback” button on the right-hand side of the screen. 
Registration Application
Participants may continue to test the registration application by contacting the DDTC Test Support Team
 at the number or email below to sign up and receive further guidance. 
DDTC Test Support Team
(202) 663-1282
(202) 663-2838

The DDTC Test Support Team will be available during the week from 10am to 4pm.

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Treasury/OFAC Extends Expiration Date of Ukraine-Related General Licenses

Treasury/OFAC, 9 Nov 2018.)

Today (9 Nov) OFAC extended the expiration date of certain general licenses related to EN+ Group PLC, United Company RUSAL PLC, and GAZ Group, and issued the following four general licenses: General License No. 13G – Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in Certain Blocked Persons, General License No. 14C – Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with United Company RUSAL PLC, General License No. 15B – Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with GAZ Group, and General License No. 16C – Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with EN+ Group PLC or JSC EuroSibEnergo. 

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EU Publishes Regulation and Directive Related to Anti-Money Laundering Efforts

Official Journal of the European Union, 12 Nov 2018.) 

Regulation (EU) 2018/1672 of the European Parliament and of the Council of 23 October 2018 on controls on cash entering or leaving the Union and repealing Regulation (EC) No 1889/2005

Directive (EU) 2018/1673 of the European Parliament and of the Council of 23 October 2018 on combating money laundering by criminal law

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Reuters: “U.S. Postpones Sanctions Deadline on Russian Tycoon’s Firms”

Reuters, 9 Nov 2018.) [Excerpts.] 
The United States on Friday said it was postponing the enforcement of sanctions on Russian companies EN+, Rusal and Gaz PAO for nearly four weeks as their top shareholder works on a plan to cut his stakes. 
The U.S. Treasury Department had given Russian tycoon Oleg Deripaska until Dec. 12 to reduce his holdings in the three companies but said in a statement that the deadline had been moved to Jan. 7, 2019.
  “EN+, RUSAL, and GAZ are proposing substantial corporate governance changes that could potentially result in significant changes in control of these sanctioned entities,” Treasury said in a statement explaining why the deadline was postponed.
Rusal, En+ and GAZ declined to comment.
The U.S. Treasury imposed the sanctions in April on Deripaska and several companies in which he is a large shareholder, citing “malign activities” by Russia, as well as allegations of past crimes by Deripaska himself.
The sanctions, the toughest since Moscow’s 2014 annexation of Crimea, have been postponed several times as the U.S. considers plans by Deripaska to divest shares in the companies so that he no longer controls them, among other moves.
Rusal and its parent En+ Group have recruited directors and management not linked to Deripaska in recent months as part of talks with Washington over easing U.S. sanctions. … 
Friday’s move extends licenses relating to the sanctioned firms to authorize activities needed to wind down operations or contracts, according to a statement on the U.S. Treasury Department’s website. It also extends licenses to authorize transactions needed to divest debt, equity and other holdings. … 

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The Wall Street Journal, 12 Nov 2018.) [Excerpts. Subscription required.]
The strategy, launched with a crackdown on a Chinese chip maker accused of stealing from Micron, opens a new front in Washington’s commercial dispute with Beijing
The Trump administration is broadening its China trade battle beyond tariffs with a plan to use export controls, indictments and other tools to counter the theft of intellectual property, according to people familiar with the matter.

The opening move in the new strategy came in the form of a recent crackdown by the Commerce and Justice Departments on a Chinese state-owned chip maker, which the U.S. administration accused of stealing trade secrets from Idaho-based Micron Technology Inc., the people said. … 

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A. Minter: “Your Old Smartphone Is a Security Risk. Live With It”

Bloomberg, 11 Nov 2018.) [Excerpts.] 
* Author: Adam Minter, Bloomberg Opinion columnist, and author of
Junkyard Planet: Travels in the Billion-Dollar Trash Trade.
Banning exports of used electronics, as the Trump administration proposes to do, will be counterproductive.
That obsolete smartphone stashed away in a drawer or closet may not look like a national security risk, but the Trump administration is contemplating 
treating it as one.
Unscrupulous Chinese recyclers and manufacturers could transform old phones into “counterfeit goods that may enter the United States’ military and civilian electronics supply chain,” according to a 
draft rule. To prevent that from happening, the Department of Commerce proposes to severely restrict the export of used electronics. … 

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The Export Compliance Journal: “Fujian Jinhua Integrated Circuit Company, Ltd Added to Entity List Without Committing Export Violation”

The Export Compliance Journal, 5 Nov 2018.) 
On Monday, 29 October 2018, the 
Department of Commerce announced that it had added Fujian Jinhua Integrated Circuit Company, Ltd (Jinhua) to the Entity List, restricting their ability to receive exports, re-exports, and transfers of commodities, software and technology subject to the EAR.
Typically, an addition to the Entity List would not be a notable event. However, in this instance, restrictions against Jinhua have been enacted pre-emptively. While U.S. chip maker, Micron Technology Inc. has accused them of stealing their chip designs, they have not yet been determined to have committed any export violations.
The actions against Jinhua are the result of the determination that they pose “a significant risk of becoming involved in activities that are contrary to the national security interests of the United States.” Their growth threatens companies involved in manufacturing defense-related items-specifically DRAM components that national security directives dictate must be manufactured by U.S.-based companies. [FN/1]

  “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,” states Secretary of Commerce Wilbur Ross.
Moving forward, companies looking to sell their dual-use items to Jinhua will be required to apply for a license to do so, while the Commerce Department has advised that such applications will be reviewed with the presumption of denial-effectively signaling that Jinhua is persona non grata.
The actions taken against Jinhua further demonstrate how important it is to 
rescreen your customers, vendors, and other business partners, as you often won’t have any other indication that their status may have changed.

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MS_a113. Monday List of Ex/Im Job Openings: 7 New Openings Posted This Week

(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

* 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

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

Apple; Cupertino, CA; 
Export Compliance Progam Manager

* Arrow; Shanghai, China; Compliance Manager;

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

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

CIRCOR International, Inc.; Burlington, MA; Director of Corporate Trade Compliance 

ConvaTec; Greensboro, NC; 
Associate Manager, Customs & Trade
; Requisition ID: JR0000536

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;

 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

GCP Applied Technologies; Cambridge, MA; 
Trade Compliance 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; Munich, Germany; Specialist Export Control;
Infinera; Sunnyvale, CA; Director, Global Logistics and Trade Compliance;

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

Leonardo DRS; Philadelphia, PA; 
Manager of Import/Export
; Requisition ID: 1530; 

* 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;

MEGGITT Control Systems; North Hollywood, CA; 
Sr. Trade Compliance Specialist

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

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

Richemont; Forth Worth, TX; 
Import/Export Manager
; Requisition ID: 8057

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

* The Safariland Group; Jacksonville, FL; Sr. Export Compliance Specialist;

TE Connectivity; El Cajon, CA or Middletown, PA; 
International Trade Compliance Specialist

; Requisition 39143

TE Connectivity; El Cajon, CA or Middletown, PA; 
Licensing Specialist
; Requisition 40514

* 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

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

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

* 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

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TE_a114ECTI Presents “United States Export Control (ITAR/EAR/OFAC) Seminar Series” in San Diego, CA on 21-24 Jan 2019

(Source: Jill Kincaid, 
* What: United States Export Control (ITAR/EAR/OFAC) Seminar Series in San Diego, CA
* When: ITAR Seminar: January 21-22, 2019; EAR/OFAC Seminar: January 23-24, 2019
* Where: Doubletree Hotel San Diego Downtown
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel: Scott Gearity, Greg Creeser, Melissa Proctor, and Marc Binder
* Register: 
Here, or contact Jessica Lemon, 540-433-

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

TE_a215FCC 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.

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


Fyodor Dostoevsky (Fyodor Mikhailovich Dostoevsky; 11 Nov 1821 – 9 Feb 1881; was a Russian novelist, short story writer, essayist, journalist and philosopher.
  – “The soul is healed by being with children.”
  – “Deprived of meaningful work, men and women lose their reason for existence; they go stark, raving mad.”
George S. Patton (George Smith Patton Jr.; 11 Nov 1885 – 21 Dec 1945; was a General of the United States Army who commanded the U.S. Seventh Army in the Mediterranean theater of World War II, and the U.S. Third Army in France and Germany following the Allied invasion of Normandy in June 1944.
  – “A good plan violently executed now is better than a perfect plan executed next week.”
Auguste Rodin (François Auguste René Rodin;12 Nov 1840 – 17 Nov 1917; was a French sculptor. He was schooled traditionally, took a craftsman-like approach to his work, and desired academic recognition, although he was never accepted into Paris’s foremost school of art.)
  – “Nothing is a waste of time if you use the experience wisely.”
Monday is pun day.
* There was a kidnapping at school yesterday. But don’t worry, he woke up.
* The guy who invented throat lozenges died last week. There was no coffin at the funeral.
* Why do math teachers make good dancers? Because they have algorithm.

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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: 2 Nov 2018: 
83 FR 55099: Wassenaar Arrangement 2017 Plenary Agreements Implementation [Correction to 24 Oct EAR Amendment Concerning Supplement No. 1 to Part 774, Category 3.]

: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders

  – Last Amendment: 5 Nov 2018: 
83 FR 55269-55271: Iranian Transactions and 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: 1 Nov 2018: 
Harmonized System Update 1819, containing 1,200 ABI records and 245 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.

* 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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