;

18-1126 Monday “Daily Bugle”

18-1126 Monday “Daily Bugle”

Monday, 26 November 2018

TOP
The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events.  Subscribe 
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  1. Commerce/BIS Publishes Denial Order Concerning Gregory Allen Justice of Safford, AZ
  2. Commerce/BIS Publishes Procedures for Participating in User Testing of the New Commerce 232 Exclusion Process Portal
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DoD/DSCA Policy Memos of Interest
  4. State/DDTC Publishes DTAG Plenary Session Documents
  5. Dutch Government Explains License Approval Concerning Mexico
  1. Bloomberg: “The Chipmaker Caught in U.S. Assault on China’s Tech Ambitions”
  2. Financial Times: Trade War Puts U.S. Tech Sector in Line of Fire”
  3. Nikkei Asian Review: “U.S. to Ease Restrictions on Space Tech Tie Ups — Except with China”
  4. ST&R Trade Report: “New Report Claims China Has Not Altered Practices Targeted by Section 301 Tariffs”
  1. J.F. Revis, E.P. Rópolo & A. De Lille-Calatayud: “Customs Basic: What you Need to Know About Importing into Mexico, Brazil, and Argentina”
  2. L. Lyons: “Caveats for On-Line Shopping”
  1. Monday List of Ex/Im 157 Job Openings: 28 New Openings Posted This Week
  1. ECS Presents “Web Meeting Series – Managing Foreign Nationals in the Workplace: Be Confident, Competent, and Compliant” on 11 Dec
  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 (2 Nov 2018), FACR/OFAC (15 Nov 2018), FTR (24 Apr 2018), HTSUS (1 Nov 2018), ITAR (4 Oct 2018) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

1. 
Commerce/BIS Publishes Denial Order Concerning Gregory Allen Justice of Safford, AZ

(Source: 
Federal Register, 26 Nov 2018.) [Excerpts.] 
 
83 FR 60395-60396: Order Denying Export Privileges
 
In the Matter of: Gregory Allen Justice, Inmate Number: 73792-112, FCI Safford, P.O. Box 9000, Safford, AZ 85548.
 
On September 19, 2017, in the U.S. District Court for the Central District of California, Gregory Allen Justice (“Justice”) was convicted of violating Section 38 of the Arms Export Control Act (22 U.S.C. 2778 (2012)) (“AECA”), among other crimes. Justice was convicted of violating Section 38 of the AECA by knowingly and willfully attempting to export, cause others to export, and aid and abet the export to Russia, for the intended benefit of the Russian Government, of defense articles designated on the United States Munitions List (“USML”), without the required U.S. Department of State licenses. Justice, an engineer who worked for a defense contractor, knowingly and willfully sold and provided USML-controlled technical data relating to U.S. military satellite programs to a person he believed to be an agent of a Russian intelligence service, but who was in fact an undercover Federal Bureau of Investigation employee. Justice was sentenced to 60 months in prison, three years of supervised release, and a $200 special assessment. … 
 
Based upon my review and consultations with BIS’s Office of Export Enforcement, including its Director, and the facts available to BIS, 
I have decided to deny Justice’s export privileges under the Regulations for a period of 10 years from the date of Justice’s conviction. I have also decided to revoke all BIS-issued licenses in which Justice had an interest at the time of his conviction. … 
 
[T]his Order is effective immediately and shall remain in effect until September 19, 2027.
 
  Issued this 15th day of November, 2018.
Karen H. Nies-Vogel, Director, Office of Exporter Services.

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

EXIM_a2

2.
Commerce/BIS Publishes Procedures for Participating in User Testing of the New Commerce 232 Exclusion Process Portal 
(Source: 
Federal Register, 26 Nov 2018.) [Excerpts.] 
 
83 FR 60393-60395: Procedures for Participating in User Testing of the New Commerce 232 Exclusion Process Portal
 
* AGENCY: Bureau of Industry and Security, Office of Technology Evaluation, U.S. Department of Commerce.
* ACTION: Notice on procedures for requesting participation in user testing phase.
* SUMMARY: The Department of Commerce has developed an online portal that will replace the use of the Federal rulemaking portal (
http://www.regulations.gov) for persons submitting exclusion requests, objections to exclusion requests, rebuttals, and surrebuttals in connection with duties or quotas imposed pursuant to Section 232 of the Trade Expansion Act of 1962, as amended (“232”). In order to improve the 232 exclusion process, the Department of Commerce plans to transition to the new Commerce 232 portal sometime in late 2018 to early 2019. This notice describes the process for the public to submit requests to participate in the public testing phase of the new Commerce 232 portal, and the procedures for attending the public testing.
* DATES: The public testing will be held on December 6 and 7, 2018 at the U.S. Department of Commerce, Room 6872A, 1401 Constitution Avenue NW, Washington, DC 20230. Each public testing day will be broken into a morning session from 9 a.m. to 12 p.m. and an afternoon session from 1 p.m. to 4 p.m.
* FOR FURTHER INFORMATION CONTACT: Kevin Coyne, System & Application Support Division, Bureau of Industry and Security, U.S. Department of Commerce,
kevin.coyne@bis.doc.gov
For more information about the section 232 program, including the regulations and the text of previous investigations, see 
here
.
  For questions regarding the December 6 and 7 public testing, please contact 
Commerce232portal@bis.doc.gov
, (202) 482-5642, or (202) 482-4757.

* SUPPLEMENTARY INFORMATION: … Two components of the Department of Commerce, the Bureau of Industry and Security (BIS) and the International Trade Administration (ITA), have developed a new Commerce 232 portal to facilitate parties’ ability to make 232 exclusion-related submissions, and the Department of Commerce’s management of the 232 exclusion process. The new Commerce 232 portal will replace the use of the Federal rulemaking portal (
http://www.regulations.gov) for parties submitting exclusion requests, objections to exclusions requests, rebuttals, and surrebuttals under the 232 exclusion process. The new portal will streamline the exclusion process for external parties, including importers and domestic manufacturers, by replacing the data collection point with web-based forms, which will enhance data integrity and quality controls. In addition, this new system will allow parties to more easily view all exclusion request, objection, rebuttal, and surrebuttal documents in one, web-based system. Finally, parties will be able to track submission deadlines in this same system. The new portal will also allow for better collaboration between government agencies processing 232 exclusion requests.
  The Department of Commerce plans to transition to the new Commerce 232 portal sometime in late 2018 to early 2019, once testing is completed and any final updates are made. This notice describes the process for the public to submit requests to participate in the public testing phase of the new Commerce 232 portal, and the procedures for attending the public testing.
  Once the Commerce 232 portal is ready to be implemented, the Department of Commerce will publish a rule making changes to the 232 exclusion process in Supplements No. 1 (for steel exclusion requests) and 2 (for aluminum exclusion requests) to Part 705. The public will have an opportunity to submit comments on the new portal once the rule is published. As much as possible, the Department of Commerce seeks input from the public on the new Commerce 232 portal prior to it going live, and believes allowing parties that will use the new portal to test it and provide feedback to the development team prior to implementation will be beneficial to both the Department and the public users of the system. 
  – Location for public testing. The public testing will occur in Washington, DC. See the ADDRESSES section for the physical address. There will be no remote testing available, so parties who wish to participate must attend the public testing in person.
  – Dates and times. The public testing will occur on December 6 and 7, 2018. Each public testing day will be broken into a morning session from 9:00 a.m. to 12:00 p.m. and an afternoon session from 1:00 p.m. to 4:00 p.m. Each party will be allowed to test the system for one hour and testing during each window will be limited to three parties at a time. For example, during the 10:00 a.m.-11:00 a.m. window, up to three parties can test the system at the same time.
  – Facilities and items to bring. The public testing will be done on government provided computers. Parties selected to participate are encouraged to bring examples of past exclusions, objections to exclusions, rebuttals, or surrebuttals they may have submitted or intend to submit in the near future to use in the testing environment. However, this is not required in order to participate in the public testing. Foreign persons are not eligible to participate in the testing. People selected to participate in the testing of the Commerce 232 portal will be limited to citizens of the United States, lawful permanent residents of the United States, or any other protected individuals as defined by 8 U.S.C. 1324b(a)(3).
  – Costs to participate. There is no fee to participate in the public testing and participants will not be compensated for their time. In addition, participants will be responsible for all travel-related costs to attend the public testing.
  – Limit on number of participants. The public testing will be limited to thirty-six people because of the size limitations of the testing room and to provide sufficient opportunities for the development team to interact with… 
 
  Dated: November 20, 2018.
 
Matthew S. Borman, Deputy Assistant Secretary for Export Administration.

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

OGSOTHER GOVERNMENT SOURCES

OGS_a13. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* State; NOTICES; 
  – Designation as a Specially Designated Global Terrorist: Hajji ‘Abd al-Nasir, aka Hajji Abdelnasser, aka Hajji Abd al-Nasr, aka Taha al-Khuwayt; and
  – Determination on Imposition and Waiver of Sanctions under the Foreign Relations Authorization Act [Pub. Dates: 27 Nov 2018.]

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

OGS_a2
4. 
Commerce/BIS: (No new postings.)

(Source: 
Commerce/BIS)

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

OGS_a35. 
DoD/DSCA Policy Memos of Interest  

(Source: 
DoD/DSCA, 26 Nov 2018.) 
 
  This memorandum clarifies the Defense Security Assistance Management System (DSAMS) milestone used to measure Group A, B, and C Letter of Offer and Acceptance (LOA) and Amendment preparation timelines.

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

(Source: 
State/DDTC, 26 Nov 2018.)
 
Plenary Session (25 October 2018) Documents:
 
The Defense Trade Advisory Group (DTAG) is established under the general authority of the Secretary and Department of State as set forth in Title 22 of United States Code.
 
The purpose of the DTAG is to provide a formal channel for regular consultation and coordination with U.S. private sector defense exporters and defense trade specialists on issues involving U.S. laws, policies, and regulations for exports of defense articles, services, and related technical data. The DTAG serves the Department in solely an advisory capacity.
 
Membership of the DTAG is appointed by the Assistant Secretary. The DTAG consists of up to 50 members, who are designated as representatives for the purpose of Federal ethics rules. Members must be U.S. citizens.

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

OGS_a57. 
Dutch Government Explains License Approval Concerning Mexico
(Source: 
Rijksoverheid, 23 Nov 2018.)
 
Minister Kaag (Foreign Trade and Development Cooperation) and Minister Blok (Foreign Affairrs) have informed the 
Tweede Kamer about the license granted to a Dutch company to ship export-controlled items to Mexico.  
 
Read the letter (in Dutch) 
here.

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

NWSNEWS

NWS_a0
8

Bloomberg: “The Chipmaker Caught in U.S. Assault on China’s Tech Ambitions”

(Source: 
Bloomberg, 25 Nov 2018.) [Excerpts.] 
 
For a sense of the damage Donald Trump can inflict on China with 
export controls, take a trip to the city of Jinjiang on the country’s southeastern coast.
 
That’s where 
Fujian Jinhua Integrated Circuit Co. built a $6 billion plant to produce semiconductors as part of China’s goal of making the country a self-sufficient technology powerhouse. But after the U.S. President barred exports to the company, its dream is now in 
tatters with consultants from American suppliers gone, the factories silent and workers rattled.
 

Less than a month ago, Jinhua was full-speed ahead on an enormous undertaking financed by the local government that blanketed its corner of the city with bristling power plants, hulking workers’ dormitories and modern research labs. It was within months of a deadline to kick off full-scale production of some 60,000 wafers a month, a key step to giving China a competitive producer of memory chips used in smartphones. … 

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

NWS_a1
9
Financial Times: Trade War Puts U.S. Tech Sector in Line of Fire”

(Source: 
Financial Times, 25 Nov 2018.) [Excerpts.] 
 
Silicon Valley concerned that export controls aimed at China could miss the target
 
Silicon Valley has rung alarm bells over the Trump administration’s latest salvo in its 
trade war with China – a threat to put export controls on a wide range of emerging technologies including artificial intelligence and robotics. 
 
U.S. technology companies are concerned that the sweeping nature of the commerce department targets, imposed on national security grounds, could undermine the goal of maintaining a US lead in the sector.
 
  “Unilateral export controls on U.S. companies and U.S. researchers could really disadvantage them,” said Christian Troncoso, head of policy at the BSA/Software Alliance, the industry lobby group. “Overbroad export controls will undermine U.S. national security by disrupting the…innovation that is essential to economic prosperity.” …  

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

NWS_a310

Nikkei Asian Review: “U.S. to Ease Restrictions on Space Tech Tie Ups — Except with China” 

(Source: 
Nikkei Asian Review, 24 Nov 2018.) [Excerpts.] 
 
Trump administration plans move to counter Beijing military expansion
 
The administration of U.S. President Donald Trump is planning to expand cooperation with other countries on the U.S. space program as part of a strategy to counter China’s technological and military expansion.
 
Washington is considering easing restrictions on exports of space technologies to U.S. allies, as well as working with Japan and Europe on new manned NASA missions to the moon.
 
With the U.S. and China competing in areas ranging from trade to security, the White House intends to fully maintain existing restrictions on exports of space technology to its increasingly powerful rival, and the country’s astronauts will not be asked to participate in new lunar missions.
 
  “I don’t see any liberalization or relaxation of space export controls with respect to China,” said Scott Pace, the man leading development of the new U.S. space policy. “I can imagine some relaxation with respect to close friends and allies,” he added. … 

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

NWS_a411

ST&R Trade Report: “New Report Claims China Has Not Altered Practices Targeted by Section 301 Tariffs” 

(Source: 
Sandler, Travis & Rosenberg Trade Report, 26 Nov 2018.)
 
The Office of the U.S. Trade Representative claims in a Nov. 20 report that the Chinese government has not fundamentally altered the unfair, unreasonable, and market-distorting practices that have led to the imposition of additional duties on some $250 billion worth of U.S. imports from China and instead appears to have taken “further unreasonable actions” in recent months.
 
(
Click here for more detailed information on affected products and other aspects of the Section 301 process.)
 
The report updates information on USTR’s Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. It discusses, among other things, how China ostensibly continues its policy and practice of conducting and supporting cyber-enabled theft and intrusions into the commercial networks of U.S. companies and those of other countries, as well as other means by which China attempts to illegally obtain information. USTR asserts that this conduct provides the Chinese government with unauthorized access to IP, including trade secrets, or confidential business information, as well as technical data, negotiating positions, and sensitive and proprietary internal business communications.
 
The report also describes how, despite the relaxation of some foreign ownership restrictions and certain other incremental changes in 2018, the Chinese government has persisted in using foreign investment restrictions to require or pressure the transfer of technology from U.S. companies to Chinese entities. USTR notes that numerous foreign companies and other trading partners share U.S. concerns regarding China’s technology transfer regime.
 
Also, under scrutiny in the report are what USTR describes as China’s discriminatory licensing restrictions. In addition, the report indicates that despite an apparent aggregate decline in Chinese outbound investment in the U.S. this year the Chinese government continues to direct and unfairly facilitate the systematic investment in, and acquisition of, U.S. companies and assets by Chinese entities in an effort to obtain cutting-edge technologies and IP and generate large-scale technology transfer in industries deemed important by state industrial plans.

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

COMMCOMMENTARY

COMM_a00
12. 
J.F. Revis, E.P. Rópolo & A. De Lille-Calatayud: “Customs Basic: What you Need to Know About Importing into Mexico, Brazil, and Argentina”

(Source: 
Baker McKenzie, 30 Oct 2018.) 
 
* Authors: Jennifer F. Revis, Esq; Esteban Pablo Rópolo, Esq.; and Armando De Lille-Calatayud, Esq. All of Baker McKenzie. Contact details 
here.
 
Baker McKenzie attorneys present a session on what you need to know about importing into Mexico, Brazil and Argentina as part of the global trade and supply chain webinar series.
 

Click here to view the video. 

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

COMM_a01
13
L. Lyons: “Caveats for On-Line Shopping”

(Source: Editor, 26 Nov 2018.) 
 
* Author: Laura Lyons, 
Laura.Lyons@efi.com
 
Given today is Cyber Monday, please be aware of the following:
  (1) 
Phishing scams are skyrocketing, especially driven by deals and rebate offers. Don’t open any attachments or click on links appearing to be from trusted vendors you shop with. Go directly to the website of the vendor to look for the sales and deals.
  (2) 
Do not use ATM/debit cards online, only use credit cards and think about setting a voluntary limit, or at least a text when a purchase gets made.
  (3) 
Delivery- and non-delivery scams. Watch out for emails that confirm shipments or that try to scam you with “shipment problems.”
  (4) Don’t fall for 
deals that are too good to be true on Cyber Monday. Increase your security awareness levels, and maintain a healthy skepticism when you see special offers in email or social media.
  (5) Watch out for 
fake discount coupons, and fake “game codes”, that are nothing but a nonsense string of letters and numbers.
  (6) Keep an eye out for online 
credit card collection imposters. Bad guys are sending emails that claim to be from the credit card company claiming your account is overdue and is subject to being shut down unless you make a payment immediately. You may be tricked into giving away your credit card information.
  (7) 
Holiday Ransomware: You should understand that information-e.g. order confirmation emails- on your computers increase in value over the holiday season, and that means that you are more likely to panic and pay ransom if ransomware strikes.
  (8) Be very wary when you get 
an inbound phone call – never give out any personal information 
if you did not initiate the call yourself.
  (9) 
Avoid downloading anything from questionable websites. Disable popups on your devices by using trusted, reliable popup blockers.
  (10) If you suspect that you may have entered 
your credit card data into a fake website after all, immediately call your credit card company and cancel your card. Then change your passwords and pin-codes for your online banking sites. Use strong passwords and never use the same password for several websites or services, because if one is stolen then all of your accounts will be put at risk. To create strong passwords without having to remember them, use a password manager.

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


MSEX/IM MOVERS & SHAKERS

MS_a114. Monday List of Ex/Im of 157 Job Openings: 28 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 
jobs@fullcirclecompliance.eu
.

 
* COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFORMATION; REQUISITION ID
 

#
” New or amended listing this week

 


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


Addison Group; Tulsa, OK; 
Senior Compliance Analyst
;


Agility; Atlanta, GA; 
Export Compliance Administrator
;

* Agility; Carson, CA;
Air Export Coordinator
;
* Agility; Charlotte, NC;
Import Manager/Licensed Customs Broker
;


Agility; Dallas, TX; 
Ocean Export Coordinator
;

Agility; East Boston, MA; 
Air Export Coordinator
;

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


Agility; Houston, TX; 
Ocean Export 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
;


Arlanxio; Pittsburgh, PA; 
Trade & Compliance Specialist
;
 

* Arrow; Shanghai, China; Compliance Manager;

BAE Systems; Arlington, VA; 
HR Operations & Compliance Specialist
; Requisition ID: 43632BR

BAE Systems; Kingsport, TN; 
Procurement Compliance Analyst
; Requisition ID: 43934BR

BAE Systems; Louisville, KY; 
Director Supply Chain Compliance
; Requisition ID: 43499BR

BAE Systems; Phoenix, AZ; 
Procurement Compliance Analyst
; Requisition ID: 41374BR


BAE Systems; York, PA; 
Director Supply Chain Compliance
; Requisition ID: 41857BR

BAE Systems; York, PA; 
Senior Procurement Compliance Analyst
; Requisition ID: 
43033BR 

Boeing; Berlin, Germany; 
Trade Control Specialist (Experienced)
; Requisition ID: 1800083558


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;

CDS Air Freight Inc.; Dulles, VA; 
Import Export Coordinator
;


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

CISCO; Amsterdam, The Netherlands; 
Global Export Trade Manager – EMEAR
;

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


Culmen International; District of Columbia, D.C.; 
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 Analyst II
;

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

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

Electrolux; Charlotte, NC; 
Director Customs and Trade Compliance


ELTA North America; Baltimore, MD; 
Compliance Officer

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; 
Director of Global Trade & Compliance;

* 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
;


Forum Energy Technologies; Houston, TX; 
Trade Compliance Manager
;
 
 

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

*
GCP Applied Technologies; Cambridge, MA; 
Trade Compliance Manager


GForce Life Sciences; Chicago, IL; 
Global 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; Melbourne, FL; Corporate Trade Compliance Investigations Lead; Requisition ID: CHQ20182007-26042 


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


IAP Worldwide Services; Cape Carneval, FL; 
Admin Global Trade Compliance
;

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


IMI Precision Engineering; Littleton, CO; 
International Trade Compliance Analyst
;

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

* 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
;


ITT Inc.; Irivine, CA; 
Trade Compliance Coordinator
;

Jabil; Tampa, FL; 
Trade Compliance Manager

* 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


Kulicke & Sofa; Fort Washington, PA; Import/Export, Trade Compliance Analyst;

* 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; 
Justin.johnson3@agustawestland.com

Leonardo DRS; Wilmington, DE; Import Export Manager;

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


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


McCormick & Company; Hunt Valley, MD; 
International Trade Compliance Analyst
;


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
;


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

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


Mitsubishi Hitachi Power Systems Americas, Inc.; Houston, TX; 

* 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; Linthicum, MD;
Manager Regulatory Compliance 2
; Requisition ID:
18016051

* Northrop Grumman; McLean, VA; 
Intl Trade Compliance Analyst 3
; Requisition ID:
18013157

* 
NXP; Eindhoven, Netherlands; 
Trade Compliance Coordinator
;


Oerlikon; Old Westbury; NY; 
Local Trade Control Specialist
;

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

Ormco; Amersfoort, The Netherlands; 
EU Trade Compliance Specialist;

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


Panalpina; Sterling, VA; Government Operations Associate;


Philips; Eindhoven, The Netherlands; 
Export Control Officer
;

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


PPG industries; Cranberry Township, PA; 
Export Control Specialist
;


Raytheon; Dulles, VA; 
Principal Global Trade License

* 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; 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
;
Danielle.Cannata@sabic.com
; Requisition ID: 8411BR

Signify; Eindhoven, The Netherlands; 
Global Trade Compliance Officer Export Controls


SPA; Washington D.C.; 
Senior Program Analyst, International Affairs
;

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



Teledyne Technologies Inc.; Hawthorne, CA; 
Sr. International Trade Compliance Specialist

TLR Inc.; Portland, OR; 
Export Compliance Specialist
;

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

tbaker@te.com
; Requisition 39143


TE Connectivity; El Cajon, CA or Middletown, PA; 
Licensing Specialist
tbaker@te.com
; 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;


The Toro Company; Bloomington, MN; 
Customs Compliance Specialist
;


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

United Technologies – Pratt & Whitney; East Hartford, CT; 
International Trade Compliance Specialist

Requisition ID 72822BR

United Technologies – Pratt & Whitney; East Hartford, CT; 
Sr. Manager International Trade Compliance

Requisition ID 75970BR

United Technologies – Pratt & Whitney; East Hartford, CT; 
International Trade Compliance Authorizations Owner
; Requisition ID: 72822BR

* 
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

* 
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;
 
psingh@idirect.net
;
*
 
Wesco International; Houston, TX; 
Export Compliance Specialist
;

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

World Wide Technology; Oude Meer, Netherlands; 
Trade and Compliance Specialist
;

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

* 
XPO Logistics; Amsterdam, Netherlands; Compliance Officer

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

TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a115ECS Presents “Web Meeting Series – Managing Foreign Nationals in the Workplace: Be Confident, Competent, and Compliant” on 11 Dec

 
* What: Web Meeting Series – Managing Foreign Nationals in the Workplace: Be Confident, Competent, and Compliant
* When: December 11, 2018; 1:00-2:30 p.m. EST
* Where: Online
* Sponsor:  Export Compliance Solutions & Consulting (ECS)
* ECS Instructors: Suzanne Palmer, Melva Exner
* Register here or by calling 866-238-4018 or by emailing

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

TE_a216FCC Presents “Designing an Internal Compliance Program for Export Controls & Sanctions”, 5 Feb 2019 in Bruchem, the Netherlands

(Source: Full Circle Compliance, 
events@fullcirclecompliance.eu.)
 
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.

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

ENEDITOR’S NOTES

Andrew Carnegie (25 Nov 1835 – 11 Aug 1919; was a Scottish-American industrialist, business magnate, and philanthropist who led the expansion of the American steel industry in the late 19th century and became one of the world’s richest persons.)
  – “Do your duty and a little more and the future will take care of itself.”
 
William Cowper (26 Nov 1731 – 25 Apr 1800; was an English poet and hymnodist. One of the most popular poets of his time, Cowper changed the direction of 18th-century nature poetry by writing of everyday life and scenes of the English countryside. In many ways, he was one of the forerunners of Romantic poetry.)
  – “The darkest day, if you live till tomorrow, will have passed away.”
 
Monday is pun day.
 
Q. Why did the cross-eyed teacher lose her job? 
    A. Because she couldn’t control her pupils.
 
Q. What do you call a priest that becomes a lawyer? 
   A. A father in law.
 
* Thanks for explaining the word “many” to me, it means a lot.

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

EN_a318
. 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: 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.]


*
FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR)
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders

  – Last Amendment: 15 Nov 2018: 83 FR 57308-57318: Democratic Republic of the Congo 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: 1 Nov 2018: 
Harmonized System Update 1819, containing 1,200 ABI records and 245 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_a0319
Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

Review last week’s top Ex/Im stories in “Weekly Highlights of the Daily Bugle Top Stories” published 
here

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

EPEDITORIAL POLICY

* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Alexander P. Bosch and Vincent J.A. Goossen; and Events & Jobs Editor, Alex Witt. The Ex/Im Daily Update is emailed every business day to approximately 6,000 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOE/NRC, DOJ/ATF, DoD/DSS, DoD/DTSA, FAR/DFARS, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

* RIGHTS & RESTRICTIONS: This email contains no proprietary, classified, or export-controlled information. All items are obtained from public sources or are published with permission of private contributors, and may be freely circulated without further permission, provided attribution is given to “The Export/Import Daily Bugle of (date)”. Any further use of contributors’ material, however, must comply with applicable copyright laws.  If you would to submit material for inclusion in the The Export/Import Daily Update (“Daily Bugle”), please find instructions here.

* CAVEAT: The contents of this newsletter cannot be relied upon as legal or expert advice.  Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources.  If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.


* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website

* BACK ISSUES: An archive of Daily Bugle publications from 2005 to present is available HERE.

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

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