;

18-1210 Monday “Daily Bugle”

18-1210 Monday “Daily Bugle”

Monday, 10 December 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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[No items of interest noted today.]

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS Seeks Information Leading to Arrest of Iranian National Allegedly Involved in Illegal Procurement of U.S. Technology
  3. State/DDTC: (No new postings.)
  4. Treasury/OFAC Extends Expiration Date of General Licenses Related to EN+, RUSAL, and GAZ
  5. EU Council Extends Sanctions Against Democratic Republic of the Congo for One Year, Announces Additional Sanctions Concerning Ukraine
  6. Singapore Customs Circulars of Interest
  1. Hong Kong Free Press: “U.S. Urges Hong Kong To Better Enforce Export Controls and UN Sanctions on North Korea and Iran”
  2. Reuters: “EU’s Top Diplomat: EU-Iran Trade Vehicle Could Be Ready by Year-End”
  3. Reuters: “Huawei CFO Seeks Bail on Health Concerns; Canada Wants Her in Jail”
  4. World Customs Organization Welcomes Suriname as New Member
  1. A. Raghavendran: “Understanding the Changes Introduced by USMCA”
  2. J. Feld & D. Stella: “Are You at Risk of Having Electronic Data Seized When Traveling Abroad?”
  3. M. Volkov: “Episode 68 – FCPA Guidance and Safe Harbors”
  1. Monday List of Ex/Im Job Openings: 144 Openings Posted This Week, Including 15 New Openings
  1. ECTI Presents “Export Control Recordkeeping, Compliance Automation and End-User Screening Update 2019” Webinar, 23 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 (29 Nov 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

[No items of interest noted today.]

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

OGSOTHER GOVERNMENT SOURCES

OGS_a11. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

* Commerce/BIS; NOTICES; Requests for Comments: 
Impact of the Implementation of the Chemical Weapons Convention on Legitimate Commercial Chemical, Biotechnology, and Pharmaceutical Activities Involving Schedule 1 Chemicals (including Schedule 1 Chemicals produced as Intermediates) During Calendar Year 2018 [Pub. Date: 11 Dec 2018.]

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

OGS_a2
2. 
Commerce/BIS Seeks Information Leading to Arrest of Iranian National Allegedly Involved in Illegal Procurement of U.S. Technology

(Source: 
Commerce/BIS, 10 Dec 2018.) 
 
BIS is seeking information leading to the arrest of an Iranian national allegedly involved in illegal procurement of U.S. technology.
 
Read the entire statement 
here.

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

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

OGS_a44. 
Treasury/OFAC Extends Expiration Date of General Licenses Related to EN+, RUSAL, and GAZ
(Source: 
Treasury/OFAC, 7 Dec 2018.)       
On 7 December, 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. 13H – Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in Certain Blocked Persons, 
General License No. 14D – Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with United Company RUSAL PLC, 
General License No. 15C – Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with GAZ Group, and 
General License No. 16D – Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with EN+ Group PLC or JSC EuroSibEnergo. 
 
  – Read the related press release 
here

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

OGS_a55
EU Council Extends Sanctions Against Democratic Republic of the Congo for One Year, Announces Additional Sanctions Concerning Ukraine 

(Source: 
European Council,  10 Dec 2018.) [Excerpts.] 
On 10 December 2018, the Council extended the restrictive measures currently in place against the Democratic Republic of the Congo until 12 December 2019. The sanctions comprise an asset freeze and a ban on entering the European Union and are targeted at 14 individuals. They were adopted on 12 December 2016 and 29 May 2017 in response to the obstruction of the electoral process, and the related human rights violations, in the DRC. … 

In addition, the EU announced additional sanctions against nine persons involved in “elections” in ”Donetsk People’s Republic” and “Luhansk People’s Republic” to sanctions list. Read the related press release here.

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

OGS_66. 
Singapore Customs Circulars of Interest 

(Source: 
Singapore Customs, 7 Dec 2018.)
 
Singapore Customs has released Circular No: 12/2018:

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

NWSNEWS

NWS_a0
7

Hong Kong Free Press: “U.S. Urges Hong Kong To Better Enforce Export Controls and UN Sanctions on North Korea and Iran”

(Source: 
Hong Kong Free Press, 10 Dec 2018.) [Excerpts.] 
 
The U.S. government has urged Hong Kong to improve its enforcement of United Nations sanctions on North Korea and Iran, as well as export controls of strategic commodities and controlled items. The recommendations came during a previously unannounced meeting in the city last week.
 
The U.S. Consulate General issued a statement on Monday morning revealing that between last Wednesday and Friday, senior delegations from the U.S. Department of State and U.S. Department of Commerce met with representatives of several Hong Kong government agencies. The officials reviewed recent progress and performance in bilateral cooperation on sanctions enforcement and strategic trade controls. … 
 
The consular statement also touched on demands from the US side regarding export controls.
 
  “[T]he U.S. delegation sought further improvements in Hong Kong’s tracking of strategic commodities and controlled items building on recent progress, and additional action and assistance in enforcement of restrictions on re-exports, so as to prevent diversion of such items to the development and production of weapons of mass destruction and unauthorized military end users,” the statement said. … 

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

NWS_a1
8
Reuters: “EU’s Top Diplomat: EU-Iran Trade Vehicle Could Be Ready by Year-End” 

(Source: 
Reuters, 10 Dec 2018.) 
 
The European Union’s foreign policy chief said on Monday a system to facilitate non-dollar trade with Iran and circumvent U.S. sanctions could be in place by year’s end.
 
The European Union wants the so-called Special Purpose Vehicle (SPV) to help preserve the economic benefits for Iran deriving from the curbs it placed on its nuclear program under a 2015 deal with world powers, from which President Donald Trump withdrew the United States in May.
 
EU diplomats had hoped to have the SPV in place by now but ran into delays as member states balked at hosting it for fear of being targeted by the revived U.S. sanctions regime against Iran.
 
Asked about progress on the SPV, EU foreign policy chief Federica Mogherini told reporters: “I would expect this instrument to be established in the coming weeks so before the end of the year as a way to protect and promote legitimate business with Iran.”
 
She did not offer any other details following a meeting of the bloc’s foreign ministers in Brussels but said work on creating the mechanism was “advancing well”.
 
France and Germany are now due to take joint responsibility for the SPV. But EU diplomats have said its ambitions could be scaled back to encompass only less sensitive items such as humanitarian and food products – rather than oil trade.
 
French Foreign Minister Jean-Yves Le Drian told the bloc’s ministers in a closed-door meeting in Brussels on Nov. 19 that Paris and Berlin were working closely together to achieve something by year-end, two other EU diplomats said.
 
The discussion came as EU nations have debated potential new sanctions on Iran after accusations of Iranian attack plots in France and Denmark.
 
“Our strong support for the implementation of the JCPOA (2015 nuclear deal) doesn’t mean we turn a blind eye for other issues,” Mogherini told reporters.
 
Until now, the EU has been straining to uphold the 2015 nuclear accord between Iran and world powers, but has been less willing to consider sanctions, instead seeking fresh talks with the Islamic Republic.
 
Iran has warned it could ditch the nuclear deal if EU powers do not protect its trade and financial benefits.

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

NWS_a39

Reuters: “Huawei CFO Seeks Bail on Health Concerns; Canada Wants Her in Jail”

(Source: 
Reuters, 9 Dec 2018.) [Excerpts.] 
 
The CFO of China’s Huawei Technologies Co Ltd argued that she should be released on bail while awaiting an extradition hearing, citing her longstanding ties to Canada, properties she owns in Vancouver and fears for her health while incarcerated, court documents showed on Sunday.
 
Huawei Chief Financial Officer Meng Wanzhou is fighting to be released on bail after she was arrested on Dec. 1 in Vancouver at the request of the United States. She is also fighting the extradition request, and China has protested her arrest to U.S. and Canadian officials.
 
Meng, 46, faces U.S. accusations that she misled multinational banks about Huawei’s control of a company operating in Iran. This deception put the banks at risk of violating U.S. sanctions and incurring severe penalties, according to court documents seen by Reuters. U.S. officials allege that Huawei was trying to use the banks to move money out of Iran.
 
China has demanded her immediate release. The arrest has roiled global markets as investors worried it could torpedo attempts to thaw trade tensions between Washington and Beijing.
 
In a sworn affidavit, Meng, the daughter of Huawei’s founder, said she is innocent and will contest the allegations at trial in the United States if she is surrendered there.
 
Meng said she was taken to a hospital for treatment for hypertension after being detained. She cited hypertension in a bail application seeking her release pending an extradition hearing. She also noted that she owns two homes in Vancouver worth millions of dollars each. … 
 
The Case 
 
The United States has been looking since at least 2016 into whether Huawei shipped U.S.-origin products to Iran and other countries in violation of U.S. export and sanctions laws, Reuters reported in April.
 
The U.S. case against Meng involves Skycom Tech Co. Ltd, which Huawei has described as one of its “major local partners” in Iran. Huawei used Skycom’s Tehran office to provide mobile network equipment to several major telecommunications companies in Iran, people familiar with the company’s operations have told Reuters.
 
In December 2012, Reuters reported that documents showed Skycom had tried to sell embargoed Hewlett-Packard computer equipment in 2010 to Iran’s largest mobile-phone operator. Reuters later reported that Skycom had much closer ties to Huawei and Meng than previously known.
 
In Canadian court papers made public on Friday, an investigation by U.S. authorities found Huawei operated Skycom as an “unofficial subsidiary” to conduct business in Iran.
 
Huawei said its Iran operations were “in strict compliance with applicable laws, regulations and sanctions” of the United Nations, United States and European Union, according to Canadian court documents released on Sunday.
 
U.S. officials allege that Meng and other Huawei representatives misled financial institutions about Huawei’s control of Skycom, so the Chinese company could gain access to the international banking system. As a result, an unidentified financial institution cleared more than $100 million worth of transactions related to Skycom through the U.S. between 2010 and 2014, the court papers said.
 
On Thursday, Reuters identified HSBC Holdings Plc as one of the banks involved in the Meng case and, citing sources, reported that the probe included possible bank fraud.
 
Companies are barred from using the U.S. financial system to funnel goods and services to sanctioned entities.
 
U.S. Senator Marco Rubio said on Sunday he would “100 percent absolutely” introduce a measure in the new Congress that would ban Chinese telecom companies from doing business in the United States.
 
  “We have to understand Chinese companies are not like American companies. OK. We can’t even get Apple to crack an iPhone for us in a terrorist investigation,” he told CBS “Face the Nation.”
 
  “When the Chinese ask a telecom company, we want you to turn over all the data you’ve gathered in the country you’re operating in, they will do it. No court order. Nothing like that. They will just do it. They have to. We need to understand that.”
 
Rubio was a strong critic of China’s ZTE Corp, which pleaded guilty in 2017 to violating U.S. laws that restrict the sale of American-made technology to Iran.

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

NWS_a410

World Customs Organization Welcomes Suriname as New Member

(Source: 
World Customs Organization, 5 Dec 2018.) 
 
The Republic of Suriname deposited with the Belgian Government its instrument of accession to the Convention Establishing a Customs Co-operation Council on 26 November 2018.  
A Dutch-speaking country on the north-eastern coast of South America, Suriname will be part of the WCO’s Americas/Caribbean region.
 
The WCO is pleased to welcome Suriname into the international Customs family.

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

COMMCOMMENTARY

COMM_a00
11. 
A. Raghavendran: “Understanding the Changes

Introduced by USMCA”
(Source: GTKonnect, 7 Dec 2018.  Available by subscription via 
anandr@gtkonnect.com.) 
 
* Author: Anand Raghavendran, GTKonnect President, 
 
On October 1, 2018, the U.S., Canada, and Mexico formed a new agreement known as the United States-Mexico-Canada Agreement, or USMCA for short. Essentially a revision of NAFTA, USMCA will introduce new standards and regulations to North American trading. Here’s is a brief overview of the major changes proposed by USMCA that businesses need to be aware of. 
 
U.S. Farmers Gain Access to the Canadian Dairy Market
 
  – Canada will open its dairy market to U.S. farmers, including in-quota access to various dairy products, poultry, and eggs
 
Rules of Origin for Automobiles and Parts
 
  – Automobiles must have 75% of their components manufactured in North America to be exempt from tariffs. 
(up from 62.5%) 
  – 40-45% of auto parts have to be made by workers who earn minimum high-wage (US $16 an hour) by 2023.
  – Mexico will pass legislation that gives workers the right to union representation, extends labor protections to migrant workers, and protects women from discrimination.
 
Intellectual Property & Digital Trade 
 
  – The terms of copyright will be extended to 70 years beyond the life of the author. (Up from 50 years.)
  – The time that pharmaceutical drugs can be protected from generic competition will increase.
  – New regulations for the digital economy, such as prohibiting duties on things like music and e-books, will be introduced.
  – New protections for internet companies so they cannot be held liable for the content that their users produce will be introduced.
 
These are some of the main changes that USMCA will make to NAFTA trading standards. For more information regarding the new regulations laid out in USMCA, please explore the details of the trade agreement 
here.

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

COMM_a01
12
J. Feld & D. Stella: “Are You at Risk of Having Electronic Data Seized When Traveling Abroad?”

(Source: 
Dykema, 6 Dec 2018.) 
 
* Authors: Jonathan Feld, Esq., 
jfeld@dykema.com; and Dante Stella, Esq., 
dstella@dykema.com. Both of Dykema, Chicago/Washington DC and Detroit, respectively.  
 
Executives and in-house counsel should be aware that traveling with sensitive data can lead to its seizure-with potentially severe consequences worldwide. Recently, Parliament in the United Kingdom seized from a traveling executive a USB drive containing data that had been produced in a United States lawsuit between Six4Three, a software company, and Facebook. Put simply, that data was in the wrong place at the wrong time.
 
Several Members of Parliament, frustrated with the apparent refusal of Facebook’s CEO and co-founder Mark Zuckerberg to appear for testimony, summoned (via a sergeant at arms) Ted Kramer, the founder of Six4Three, at his hotel room in London. According to reports, the executive met with a parliamentarian, was threatened with contempt, “panicked,” and copied onto a USB drive a large amount of lawsuit-related data that previously had been synchronized to his laptop from a DropBox account.
 
The consequences were immediate in the U.K., and severe back in the U.S. The USB drive ended up in the hands of Damian Collins, Parliament’s chair of the culture, media and sport select committee. This exposed the contents of the drive, including potential trade secret information, to a foreign investigative body that was not subject to the jurisdiction of the California state court that had issued a confidentiality order prohibiting disclosure to third parties. Collins then announced an intent to publish the documents. But back in California state court, things got worse. Not only did Kramer’s turning over the data violate the confidentiality order; the executive possessed the information by erroneous DropBox permissions that themselves violated the confidentiality order by giving him access to “attorneys eyes only” material. The state court judge called the situation “unconscionable” and ordered forensic examinations of numerous devices of Kramer and his attorneys, who had to withdraw from the case.
 
There are many lessons to be learned, but this event highlights three things about physically moving data across borders. First, once data is within the boundaries of another country, it is subject to seizure and search according to the laws of that country. U.S. components of multinationals are frequently confronted with the hazards of importing data from the EU or Asia, where such data might be sought for a U.S. civil or criminal action. But the recent seizure in London underscores that when sensitive U.S. data-even when subject to a confidentiality order from a U.S. court-moves out of the country, neither its U.S. origin nor protective orders of American courts are necessarily effective in preventing a foreign law enforcement agency (or legislative body) from taking it.
 
Second, once data is in the custody of a foreign government, the information is at risk of being disclosed to third parties or the public-in a context where expected principles of confidentiality (or the protection of U.S. law) is absent. A foreign authority may simply decide that the public interest of its country outweighs comity. Notions of privilege can also vary dramatically. Europe and parts of Asia accord far less protection for in-house counsel’s activities than do principles of law in the United States. And some foreign governments may be interested in (involuntary) technology transfers.
 
Finally, when U.S.-based data comes back into its home country, even when there is no incident abroad, it can still be seized at the border, without being subject to Fourth Amendment protections. Data seized by the Department of Homeland Security may be disclosed to other federal investigative agencies, and there have been multiple recently reported instances of Customs and Border Patrol personnel forcing entrants to allow searches of electronic devices, where a purely internal law enforcement agency would have to obtain a warrant.
 
There are several ways to mitigate risks that stem from crossing international borders while carrying electronically stored data:
  – For in-house counsel traveling on business, consider taking devices containing only what you need, not everything you have. For example, if you are dealing with a specific matter, you could minimize the amount of material you are carrying related to other matters.
  – For all employees, minimize the amount of unnecessary technical material you are carrying, for data security; competitive; and reasons related to the International Traffic in Arms Regulations and Export Administration Regulations. And what data you do carry should never be the only copy of that data.
  – If you are a producing party in litigation, consider confidentiality orders that prohibit adversaries from moving your data abroad, be it hosting or physical carrying.
  – Make sure that your data is encrypted on the device. This will not prevent all unwanted access, but it can provide some protection, even if a device simply becomes the subject of theft.
  – If you review company data that is resident in another country, carefully consider the risks of bringing it to the United States, whether those risks stem from the General Data Protection Regulation (GDPR), data residency laws, or pending investigations.

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

COM_a3
13
M. Volkov: “Episode 68 – FCPA Guidance and Safe Harbors”

(Source: 
Volkov Law Group Blog, 9 Dec 2018. Reprinted by permission.) 
 
* Author: Michael Volkov, Esq., Volkov Law Group, 
mvolkov@volkovlaw.com, 240-505-1992. 
 
The FCPA Guidance continues to inform compliance practitioners on compliance best practices. Issued in 2012, the FCPA Guidance provides important information concerning a number of compliance functions and risks.  The FCPA Guidance includes important discussions about legal intent, due diligence, successor liability and other issues, which can be used to establish important safe harbors for an effective ethics and compliance program.
 
In 
this episode, Michael Volkov discusses the enduring importance of the FCPA Guidance and discusses specific examples of areas where the FCPA Guidance can be used to inform day-to-day compliance decisions.

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


MSEX/IM MOVERS & SHAKERS

MS_a114. Monday List of Ex/Im Job Openings: 144 Openings Posted This Week, Including 15 New Openings

(Source: Events & Jobs 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; Basel, Switzerland; SachbearbeiterIn Ocean Freight Export;

* 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; Erlanger, KY; Air/Ocean Export Coordinator;

*
 
Agility; Houston, TX; 
Ocean Export Coordinator
;


Agility; Houston, TX; Ocean Export Team Leader;

Agility; Montreal, Canada; Senior Ocean Export Coordinator;

Airbus; Getafe, Spain; Export Control Officer; Requisition ID: 
10397123 ML EN EXT 6

*
 
Ajilon; Grapevine, TX; 
Import/Export Compliance Manager
;

*
 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; Chelmsford, MA; 
Import-Export Analyst
;


Apple; Cupertino, CA; 
Export Compliance Progam Manager
;

* 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; 
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;

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;

Eddie Bauer; Bellevue, WA; 
Customs Compliance Analyst
;

Electrolux; Charlotte, NC; 
Director Customs and Trade Compliance
*
 
ELTA North America; Baltimore, MD; 
Compliance Officer

*
 Expeditors; Krefeld, Germany; 
Clerk Import / Export
;
*
 Expeditors; Bedfont, United Kingdom;
Customs Brokerage Clerk
;

* Expeditors; Bedfont, United Kingdom; 
District Trade Compliance Manager
;
* Expeditors; Dusseldorf, 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;

* 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
;

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

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

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

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

* General Atomics; San Diego, CA; 
Senior Government Compliance Specialist
; Requisition ID: 20736BR
*
 
Gibson Brands, Inc.; Nashville, TN; 
Import/Export Compliance Manager;
#
GSK, London, United Kingdom; Global Logistics Compliance Manager; Requisition ID:
WD187594

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

* 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
;

* 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; 
Senior Export Compliance Specialist
;

*
 InteliTrac Global Solutions; Herndon, VA; 
ITAR Compliance Official / Deputy Facility Security Officer
;

*
 InteliTrac Global Solutions; Herndon, VA;
ITAR Compliance Official
;

# IPG Photonics; Oxford, MA;
 
Global Director Trade Compliance

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

* 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
*
 
KIA Motors; West Point; GA; Specialist, General Purchasing (Trade Compliance Logistics)
*
 
Kulicke & Sofa; Fort Washington, PA; Import/Export, Trade Compliance Analyst;

* 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

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


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


Lockheed Martin; 
Grand Prairie, TX; 
International Trade Compliance Specialist / International Licensing Analyst
; Requisition ID: 459286BR


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;

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

*
 
MSC Mediterranean Shipping Company; Chicago, IL; 
US Export Compliance Analyst
;

* 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.


Muscogee International, LLC; Washington, D.C.; 
DDTC Office Support
; Apply 
HERE
 or contact their 
recruiting team
.

*
 
NASA jet Propulsion Laboratory; Pasadena, CA; 
Export Compliance Advisor
;

* 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
;
*
 
Ocean Spray Cranberries; Middleboro, MA; 
Customs & Trade Compliance Specialist
;
*
 
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;

*
 
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
*
 
PrincetonOne; Franksville, WI; 
Customs Compliance Manager
;
*
 
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; Dulles, VA; Senior Trade Counsel/Regulatory Compliance Director; Requisition ID: 128137

* Raytheon; El Segundo, CA; Fullerton, CA; Goleta, CA; Aberdeen, MD; Plano, TX; McKinney, TX; Principal Analyst, Global Trade Licensing; Requisition ID: 117247BR

*
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

* 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; Arlington, VA; 
Trade Compliance Officer
; Requisition ID: R0044069

*
 
Thales; New Delhi, India; 
Manager – Trade Compliance
; Requisition ID:
R0038060
*
 
The Toro Company; Bloomington, MN; 
Customs Compliance Specialist
;


Toyota Tsusho America; Georgetown, KY; 
Import Export Compliance Specialist;
#
 Tradeweb; Amsterdam, The Netherlands; Trade Surveillance & Compliance Officer;

Trek Bicycle; Waterloo, WI; Trade Compliance Specialist

United Technologies – Aerospace Systems; Windsor Locks, CT; Manager – International Trade Compliance; Requisition ID 
71658BR


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
;


Vitol Group; Rotterdam, The Netherlands; KYC Compliance Analyst EMEA & Asia

* VT iDirect; Herndon VA;
 
Manager, Global Logistics
; Requisition ID: 2018R-3120-1;
 
psingh@idirect.net
;
*
 
Wesco International; Houston, TX; 
Export Compliance Specialist
;
*
 
WestRock Company; Atlanta, GA; 
International Logistics Coordinator

* 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_a115ECTI Presents “Export Control Recordkeeping, Compliance Automation and End-User Screening Update 2019” Webinar, 23 Jan 2019

(Source: D. Hatch, danielle@learnexportcompliance.com.)
 
* What: Export Control Recordkeeping, Compliance Automation and End-User Screening Update 2019
* When: 23 January 2019 1:00 p.m. (EST)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Felice Laird
* Register: HERE or contact Danielle Hatch, 540-433-3977,

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

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

John Milton (
9 Dec 1608 – 8 Nov 1674; was an English poet, polemicist, man of letters, and civil servant for the Commonwealth of England under its Council of State and later under Oliver Cromwell. He is best known for his epic poem Paradise Lost (1667), written in blank verse.  William Hayley’s 1796 biography called him the “greatest English author”, and he remains generally regarded as one of the preeminent writers in the English language.)
  – “The superior man acquaints himself with many sayings of antiquity and many deeds of the past, in order to strengthen his character thereby.”
 
Emily Dickinson (Emily Elizabeth Dickinson; 10 Dec 1830 – 15 May 1886; was an American poet.  Despite Dickinson’s prolific writing, fewer than a dozen of her poems were published during her lifetime. After her younger sister discovered the collection of nearly of her 1800 poems, Dickinson’s first volume was published four years after her death. Thomas H. Johnson published Dickinson’s Complete Poems in 1955.)
  – “Success is counted sweetest by those who never succeed.”
  – “Old age comes on suddenly, and not gradually as is thought.
 
Monday is pun day:  
 
* Q. What did E.T.’s mother say to him when he got home?
   A. “Where on Earth have you been?”

* Q. Why was the young leopard unsuccessful at playing hide and seek?
   A. Because he was always spotted.
 
* Q. If a short psychic broke out of jail, who would the law be looking for?
 
   A. A small medium at large.

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

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.

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