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18-1231 Monday “Daily Bugle'”

18-1231 Monday “Daily Bugle”

Monday, 31 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 
here for free subscription. Contact us
for advertising inquiries and rates. [Note: The Daily Bugle will not be released tomorrow,Tuesday, 1 January 2019, a U.S. Federal Holiday. Happy New Year!]   

[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Posts Notice on Section 301 Product Exclusions
  4. State/DDTC: (No new postings.)
  5. Singapore Customs Announces TradeNet Extended Downtime on 13 Jan
  1. N. Nègre-Eveillard & O. Berg: “Foreign Investments in France: New Legislation Expands and Strengthens the National Security Review Mechanism”
  2. T.G. Ficaretta: “Department of Justice Rescinds ATF Guidance Documents”
  1. Monday List of Ex/Im Job Openings: 148 Openings Posted This Week, Including 12 New Openings
  1. FCC Presents Renewed U.S. Export Controls Awareness Course: “ITAR & EAR from a non-U.S. Perspective”, 9 April in Bruchem, the Netherlands
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (18 Dec 2018), DOC/EAR (20 Dec 2018), DOC/FTR (24 Apr 2018), DOD/NISPOM (18 May 2016), DOE/AFAEC (23 Feb 2015), DOE/EINEM (20 Nov 2018), DOJ/ATF (26 Dec 2018), DOS/ITAR (4 Oct 2018), DOT/FACR/OFAC (15 Nov 2018), HTSUS (19 Dec 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)

 

[No items of interest noted today.]  

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

OGS_a2
2. 
Commerce/BIS: (No new postings.)

(Source: 
Commerce/BIS)

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

(Source:
CSMS #18-000757, 31 Dec 2018.)
 
Notice of Product Exclusions: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation (Section 301)
 
BACKGROUND:
 
On December 28, 2018, the U.S. Trade Representative published Federal Register Notice 83 FR 67463 announcing the decision to grant certain exclusion requests from the 25% duty assessed on goods of China with an annual trade value of approximately $34 billion (Tranche 1), as part of the action in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The product exclusions announced in this notice will apply as of the July 6, 2018 effective date of the $34 billion action (see Federal Register 83 FR 28710), and will extend for one year after the publication of this notice.
 
At the conclusion of the government funding hiatus, CBP will issue instructions on entry guidance and implementation. Any updates to the Automated Customs Environment (ACE) will be implemented 10 business days after the shutdown has concluded. Until these updates are completed, entry and entry summaries must be submitted without the Chapter 99 product exclusion number referenced in 83 FR 67463. Entry and entry summaries will be rejected by ACE if the Chapter 99 product exclusion number referenced in 83 FR 67463 is transmitted.
 
Once CBP issues guidance and implements ACE enhancements, a Post Summary Correction (PSC) or a Protest may be submitted for a refund.
 
All questions related to Section 301 entry filing requirements should be emailed to traderemedy@cbp.dhs.gov. After the funding hiatus, questions from the importing community concerning ACE rejections should be referred to their ABI Client Representative.
 
  – Related CSMS No. 18-000753, 18-000752, 18-000624

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

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

 
In addition to the usual housekeeping time for TradeNet on Sundays from 0400 hours to 0800 hours, we wish to inform you that Singapore Customs will be performing system maintenance work which will affect TradeNet from 0400 hours to 1200 hours on 13 January 2019.
 
During this period, all applications can still be submitted through TradeNet. These applications will not be processed, and processing of these applications will resume in TradeNet after 1200 hours on 13 January 2019.
 
Please bring the contents of this Notice to the attention of your staff. Kindly plan in advance and submit applications before the downtime, to minimise disruptions to your business operations. We apologise for any inconvenience caused.

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

COMMCOMMENTARY

(Source:
White & Case LLP, 27 Dec 2018.)
 
* Authors: Nathalie Nègre-Eveillard, Esq.,
nnegre@whitecase.com, +33 1 55 04 15 63; and Orion Berg, Esq.,
oberg@whitecase.com, +33 1 55 04 58 63. Both of White & Case LLP.
 
Like other EU countries, France is bolstering its national security-related regulatory regimes. The French government recently affirmed its goal to remain attractive for foreign investments while preserving French national interests.
 
Expanding the List of Sensitive Sectors
 
The latest reform of the French legal system of national security review, implemented in May 2014, expanded the scope of activities reviewed (whether EU or non-EU) by the so-called “Montebourg Decree,” notably to energy, water supply, transportation, telecoms and public health.
 
A new Decree, n° 2018-1057 of 29 November 2018, further amends and expands the list of sensitive sectors subject to prior authorization by the Ministry of Economy (MoE). With respect to EU as well as non EU/EEA investors, the review mechanism will now cover interception/detection of correspondences/conversations, capture of computer data, security of information systems, space operations and electronic systems used in public security missions. The new Decree also expands the scope of review to R&D activities in cybersecurity, artificial intelligence, robotics, additive manufacturing, semiconductors, certain dual-use goods and technologies, and sensitive data storage. Concerns regarding protection of sensitive data are now a specific ground for the MoE to impose mitigation requirements or to refuse to authorize a foreign investment.
The new Decree introduces the option for the target company to submit a written request to the Minister of Economy to get comfort about whether the projected investment is subject to prior authorization review; previously, such requests could be submitted only by the foreign investor.
 
The new Decree applies to requests for prior authorization filed from 1 January 2019.
 
Strengthening the Enforcement Powers of the Ministry of Economy
 
In 2017, the French National Assembly created a Parliamentary Enquiry Committee to investigate how French national security interests have been protected in recent transactions involving strategic companies. The investigation has increased the pressure on the services of the MoE in charge of the review process to ensure that they have completed a thorough review of both the activities at stake and the profile and intentions of the foreign investors.
 
Against this background, a new set of measures to reform the review mechanism is currently discussed by the French Parliament as part of the so-called “PACTE Law.”
 
On 10 October 2018, the draft PACTE Law was subject to a first vote by the French National Assembly. The draft will next be submitted to the Senate, and a final version of it is likely to be adopted by the Parliament in early 2019. Article 55 of the draft amends the French legal framework applicable to national security reviews.
 
The draft PACTE Law proposes to amend the sanctions mechanism in case of infringement of the prior approval obligations. While removing the sanction consisting in the nullity of the infringing transaction, the proposed reform aims at giving the French government a larger pallet of possible sanctions it can adapt and leverage.
 
Notably, if a transaction has been implemented without prior authorization, the MoE will now have the power to order the investor to:
 
  – amend the transaction
  – file for a prior authorization request
  – restore the previous pre-transaction situation at his own expense
  – suspend the voting rights of the investor and appoint a temporary manager entrusted with the management, the operation and the representation of the legal entity at stake
  – suspend, restrict or prohibit temporarily the free disposal of all or part of the assets related to the sensitive activities at stake
  – prohibit or limit the distribution of dividends to shareholders
 
If an investor fails to comply with the clearance conditions imposed by the MoE, the MoE will also have the power to withdraw the authorization and to order the investor to:
 
  – divest all or part of the sensitive activities at stake
  – implement the initial clearance conditions or new conditions set out by the MoE, including measures to restore the previous pre-transaction situation
 
The MoE may also impose daily penalties in case of non-compliance with its order.
 
Eventually, the MoE may also have the power to impose monetary sanctions in case of infringement of FIC obligations; i.e., a fine, the amount of which cannot exceed the highest of the following amounts:
 
  – twice the value of the investment at stake
  – Ten percent of the annual turnover achieved by the undertaking concerned by the foreign investment
  – €1 million for natural persons
  – €5 million for legal entities
 
Finally, in order to improve transparency over the review process, the Parliament is also considering the creation of a new permanent Parliamentary Committee in charge of economic security.
 
This new Committee would be composed of eight members of the National Assembly and eight members of the Senate, all subject to specific national security confidentiality rules. The government would be required to report annually to this new Committee on past transactions reviewed, cleared or rejected during the previous year. In the same vein, the MoE would issue yearly public general statistics (on a no-name basis) in relation to French national security reviews.
 
Foreign investors should be aware that identifying and protecting strategic activities has become an increasing concern in the French review process, as well as in relation to clearance commitments that may be required as a condition to obtain prior authorization.

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

(Source: Author, 31 Dec 2018.) 
 

* Author:  Teresa G. Ficaretta, Esq., 
teresa@ficarettalegal.com, 301-353-3558; Ficaretta Legal Services, LLC.
 
In a 
press release issued on December 21, 2018, Acting Attorney General Matthew Whitaker announced the rescission of 69 guidance documents the Department of Justice (DOJ) believes are unnecessary, outdated, inconsistent with existing law or otherwise improper.  The documents were rescinded pursuant to Executive Order 13777 and a November 16, 2017, memorandum signed by Attorney General Sessions.  The Sessions memorandum stated that its purpose was to prevent DOJ from evading required rulemaking processes by using guidance documents to create de facto regulations. 
 
All of the guidance documents rescinded by DOJ were issued by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), with the exception of two documents relating to school discipline.  ATF officials advise the agency will be publishing a list of the rescinded documents that includes a summary of the document and its full text.  Publication will occur sometime after the government shutdown is over.  
 
This bulletin provides a summary of each document and why rescission has no impact on federal firearms licensees, federal explosives licensees, and federal explosives permittees.   Because most of the documents are no longer available on ATF’s website or elsewhere in electronic format, full text of the documents is not provided. 
 
ATF Guidance Documents Rescinded on December 21, 2018
 
Rev. Rul. 69-114
:
  This ruling issued by the Internal Revenue Service (ATF’s predecessor agency) addressed the contiguous state requirements of the Gun Control Act (GCA) that allowed unlicensed individuals to purchase a rifle or shotgun from a federal firearms licensee (FFL) outside the individual’s state of residence if certain requirements were met.  The GCA was amended in 1986 to allow residents of any state (not just contiguous states) to purchase firearms from FFLs if the transaction fully complies with the laws of the buyer’s state and seller’s state.  See 18 U.S.C. § 922(b)(3)(A).  This ruling is obsolete because the contiguous state requirements are no longer in the statute.  In addition, the provisions of Massachusetts law referenced in the ruling are no longer in effect. 
 
ATF Rul. 77-25
:
  This ruling addressed the law enforcement certification requirements of regulations implementing the National Firearms Act in 27 C.F.R. Part 479.  The law enforcement certification requirement was repealed by ATF 41-F, published in the Federal Register on January 15, 2016.  The law enforcement certification previously required on ATF Form 4, Application for Tax Paid Transfer and Registration of Firearm, was replaced with a requirement to provide written notification of the proposed firearm transfer to the chief law enforcement officer of the locality in which the transferee resides.  See, 27 C.F.R. § 479.84(c).  Accordingly, ATF Rul. 77-25 is obsolete.  
 
ATF Rul. 77-26
:
  This ruling provides a list of ammunition that is interchangeable between rifles and pistols or revolvers.  The ruling provided guidance for a provision added to the GCA in 1969 that exempted interchangeable ammunition from the record keeping provisions of the statute.  All of the record keeping requirements applicable to ammunition (except for armor piercing ammunition) were repealed by the Firearms Owners Protection Act of 1986.  Accordingly, this ruling is obsolete.
 
ATF Rul. 75-30
:  This ruling addressed record keeping requirements for federal explosives licensees and permittees as those requirements existed in 1975.  The ruling held that licensees and permittees were allowed to keep records of their daily explosives transactions for each magazine at a centrally located area on the licensed premises, rather than with each magazine as required by regulations.  The ruling became obsolete when regulations were subsequently amended to allow central storage of the daily summary records.  See 27 C.F.R. § 555.127.  Accordingly, this ruling is obsolete.  
 
ATF Rul. 77-13
:  This ruling provided guidance to federal explosives licensees and permittees on compliance with the statutory requirement that they report thefts or losses of explosive materials to ATF and local authorities within 24 hours after discovery.  The ruling required notice by calling ATF and confirming the call by filing Form 4712 with the nearest ATF office.  This requirement was subsequently incorporated into regulations and requires notice through a nationwide toll-free number, by filing ATF Form 5400.5, and by notifying local authorities.  See 27 C.F.R. § 555.30.  Accordingly, the ruling is obsolete.
 
ATF Rul. 80-22:
  This ruling allowed federal explosive licensees and permittees to move previously approved mobile magazines storing explosive materials if certain requirements were met.  This position was codified in ATF regulations when they were amended in 1981.  See, 27 C.F.R. § 55.63.  Accordingly, this ruling is obsolete.
 
ATF Procedure 80-7
:
  This procedure specified the process for federal explosives licensees and permittees to obtain approval for movement of mobile magazines for the storage of explosive materials and implements ATF Rul. 80-22.  The procedure became obsolete when the regulations were amended, as explained above.  
 
ATF Rul. 80-23
:  This ruling authorized the use of electrical lighting in explosive storage magazines if certain specified requirements were satisfied.  The provisions of this ruling were subsequently incorporated into the regulations.  See 27 C.F.R. § 555.217.  Accordingly, the ruling is obsolete.  
 
Open Letter to FFLs dated August 31, 2006
:  This letter requested assistance from FFLs in recovering firearms stolen from a pawn shop in Greenville, SC.  As Dthis investigation began over 12 years ago, it is unlikely ATF still requires assistance from FFLs.
 
Open Letter Dated August 22, 2001
:  This letter notified licensed firearms importers and licensed firearms manufacturers of amendments to the regulations specifying minimum depth and height requirements for serial numbers and other information required to be marked on firearms.  As the regulations have been in place for over 17 years, the open letter is no longer necessary.  
 
Open Letter Dated November 20, 2001
:  This letter notified FFLs and federal explosives licensees and permittees that ATF had not received mail since October 25, 2001.  The situation was caused by the 2001 delivery of mail containing anthrax to federal facilities, the media, and members of Congress.  In response, federal agencies diverted all incoming mail to a central facility in D.C. for decontamination.  This problem has been addressed and ATF is currently receiving mail.  Accordingly, the Open Letter is not necessary.
 
Open Letter Dated November 4, 2008
:  This letter to all FFLs notified them that a new version of Form 4473 with a revision date of August 2008 must be used on and after November 15, 2008.  This date is long gone and the letter is not necessary.
 
Open Letter to Washington FFLs Dated August 12, 2011
.  This letter advised FFLs in Washington state that concealed pistol licenses issued on or after July 22, 2011, qualify as NICS alternatives.  This means that unlicensed purchasers presenting valid concealed pistol licenses were not required to undergo a NICS check in accordance with 18 U.S.C. § 922(t).  Some time after this letter was issued ATF learned that Washington state law requires a background check for all firearms transfers to nonlicensed purchasers unless there is a specific exemption under federal or state law.  See RCW 9.41.113, approved by the Washington legislature on November 4, 2014.  ATF’s position is reflected on the agency’s website at https://www.atf.gov/rules-and-regulations/permanent-brady-permit-chart.  This Permanent Brady Permit Chart indicates that, as of May 10, 2017, the state of Washington has no concealed carry permits that qualify as NICS alternatives.  Accordingly, the letter dated August 12, 2011, is obsolete. 
 
53 Open Letters Dated February 1994
:
  These letters provided guidance to states, the District of Columbia, Commonwealth of Puerto Rico, and possessions of the United States regarding the interim provisions of the Brady Handgun Violence Prevention Act, enacted on November 30, 1994.  The interim provisions became effective on February 28, 1994, and ceased to apply on November 30, 1998, when the permanent provisions of the statute (18 U.S.C. § 922(t)) became effective.  The letters provided guidance on provisions of the law no longer in effect and are obsolete. 
 
Open Letter to All Federal Explosives Licensees and Permittees Dated February 12, 2003
.  This letter provided notice to federal explosives licensees and permittees concerning a January 29, 2003, notice of proposed rulemaking.  The notice published in the Federal Register proposed amendments to regulations implementing the federal explosives laws in 27 C.F.R. Part 555.  The Open Letter encouraged all interested persons to submit written comments no later than April 29, 2003.  As this rulemaking project has concluded, the Open Letter is obsolete.   
 
Conclusion
 
All of the ATF guidance documents rescinded by the Department of Justice are obsolete or unnecessary.  Rescission has no impact on the operations of federal firearms licensees, federal explosives licensees, and federal explosives permittees.  

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


MSEX/IM MOVERS & SHAKERS

MS_a18. Monday List of Ex/Im Job Openings: 148 Openings Posted This Week, Including 12 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

 

#
ABB; Atlanta, GA; Trade Compliance Leader; Requisition ID: US67317342_E1;


Acco Brands; Lake Zurich, IL; 
North America Trade Compliance Specialist Classification
;
*
 
Addison Group; Tulsa, OK; 
Senior Compliance Analyst
;

* AeroVironment; Los Angeles, CA; Trade Compliance Specialist;

*
 
Agility; Basel, Switzerland; SachbearbeiterIn Ocean Freight Export;
*
 
Agility; Carson, CA; 
Air Import Coordinator
;

* Agility; Charlotte, NC;
Import Manager/Licensed Customs Broker
;
*
 
Agility; Dallas, TX; 
Air Import Coordinator
;
*
 
Agility; Dallas, TX; 
Air Import Supervisor
;
*
 
Agility; Dallas, TX; 
Ocean Export Coordinator
;
*
 
Agility; East Boston, MA; 
Air Export Coordinator
;
*
 
Agility; East Boston, MA; 
Import Coordinator / Customs Entry Writer
;
*
 
Agility; Houston, TX; 
Air Freight Export Account Executive
;
*
 
Agility; Houston, TX; 
Ocean Export Coordinator
;
*
 
Agility; Houston, TX; Ocean Export Team Leader;
*
 
Agility; Montreal, Canada; Senior Ocean Export Coordinator;
*
 
Agility; Queens, NY; 
Air Import Coordinator
;
* Airbus; Manching, Germany; Export Compliance Officer (m/f); Requisition ID: 10434415 NK EN EXT 1;
 
 

*
 
AM General; Auburn Hills, MI; 
International Compliance Analyst

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
;


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

#
Arconic; Cleveland, OH; Global Trade Compliance Manager;


BAE Systems; Kingsport, TN; 
Procurement Compliance Analyst
; Requisition ID: 43934BR
*
 
BAE Systems; Nashua, NH; 
Procurement Compliance
; Requisition ID: 
44996BR

BAE Systems; Poznań, Poland; Export Control Officer;

*
 
BAE Systems; Sterling Heights, MI; 
Senior Procurement Compliance Analyst
; Requisition ID: 
4BR


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

* Baker Hughes; Several locations worldwide; International Trade Compliance Special Programs Leader (Legal)

*
 
Beiersdorf; Hamburg, Germany; International Trade Expert;

*
 
Boeing; Everett, WA; 
Export Compliance Specialist
; Requisition ID: 1800090316

*
 
Boeing; Berlin, Germany; Trade Control Specialist;

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

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

* Brunswick Boat Group; Knoxville, TN; Trade Compliance Specialist; 

CISCO; Amsterdam, The Netherlands; 
Global Export Trade Manager – EMEAR
;
*
 
Cobham Advanced Electronic Solutions; Colorado Springs, CO; 
Export Compliance Manager
; Requisition ID: req2102;

* Column Technical Services; Buchanan, MI; Compliance Manager;

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

* DHL; Schiphol-Rijk, the Netherlands; Manager Customs Operations & Compliance;
* DHL; United Kingdom; Customs Compliance Manager; Requisition ID: req69782;


Doosan; West Fargo, ND; 
Director Customs & Trade Compliance
*
 
DuPont; Neu-Isenburg, Germany; 
Logistics Specialist Customs & Trade Compliance EMEA
; Requisition ID: SOU00001629;
*
 
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;
*
 
Eaton; Titchfield, United Kingdom; Senior Global Trade Analyst; Requisition ID: 056506;

* EDCO; Eindhoven, the Netherlands; Customs & Trade Compliance Coordinator;  
*
 
ELTA North America; Baltimore, MD; 
Compliance Officer
;
*
 
Energy Resourcing Group; Houston, TX; 
Trade Compliance Manager
;
*
 
Erickson Inc.; Portland or Central Point, OR; 
Import Specialist

Susan Colletto
; Requisition ID 927130;

ESG; Fürstenfeldbruck, Germany; Specialist Export Control Compliance (M/W) (Processes, Implementation & IT);

* Esri; Redlands, CA; Export Compliance Specialist;

*
 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 Compliance Solutions/ECScreening; Remote; Sales Representative

* Export Solutions, Inc.; San Jose, CA; 
Director of Global Trade & Compliance;

#
First Solar; Perrysburg, OH; Trade Compliance Specialist II;

* Flexport; Amsterdam, the Netherlands; Customs Director Europe;
* Flexport; San Francisco, CA; Customs Compliance Manager;

* 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

Google; Mountain View, CA; Trade Specialist, Export 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
;

* Honeywell International Inc.; Sunnyvale, CA or Lincolnshire, IL; Sr. Import/Export Analyst; HRD32371
*
 
Hypertherm; Hanover, NH; 
Senior Trade Compliance & Logistics Specialist
;

* iDirect; Herndon, VA;
Senior Regulatory Compliance Engineer
; Requisition ID: 2018R-4700-56
* IKEA; King of Prussia, PA; Customs Operations Specialist; 
*
 Infineon; El Segundo, CA; 
Manager, Export Control
; Requisition ID: 33841

*
Infineon Technologies, El Segundo, CA;
Senior Export Compliance Specialist
; Requisition ID: 31215;

*
 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
;
*
 IPG Photonics; Oxford, MA;
 
Global Director Trade Compliance 
*
 
ITT Inc.; Irivine, CA; 
Trade Compliance Coordinator
;

* John Crane; Slough, United Kingdom; Senior Manager International Trade Compliance EMEA; Requisition ID: JCRANE01688; 
* 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

# Kansas City Power & Light Company; Kansas City, MO; Energy Trading Compliance Program Manager;  
*
 
KIA Motors; West Point; GA; Specialist, General Purchasing (Trade Compliance Logistics)

# Kohler Co; Kohler, WI; Analyst, International Trade Compliance; Requisition ID: 18105; 
*
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; 
Grand Prairie, TX; 
International Trade Compliance Specialist / International Licensing Analyst
Requisition ID: 459286BR
*
 
Lockheed Martin, Grand Prairie, TX OR Orlando, FL.; 
International Trade Compliance Engineer Staff
; Requisition ID 462509BR
*
 
Lockheed Martin, Orlando, FL.; 
International Licensing Analyst
; Requisition ID 460554BR


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

*
 
Mohawk Global Trade Advisors; Chicago, IL; 
Vice President and General Manager of Consulting Division
; Contact: CSardella@mohawkglobal.com;  
*
 
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
;
*
 Newell Brands; Norwalk, CT; 
Manager of Trade Operations

* Norma Group; Maintal, Germany; Manager Global Trade Compliance and Forwarding; Requisition ID: 8843; 

* Optimas Solutions; Chicago, IL; Global Trade Compliance Specialist;


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


Philips; Eindhoven, The Netherlands; 
Export Control Officer
;

#
PwC; Atlanta, GA; Customs and International Trade Director; Requisition ID: 38078WD;
#
PwC; Houston, TX; Customs and International Trade Director; Requisition ID: 38150WD;

* Ravago; Orlando, FL; Export Compliance Coordinator; 
*
 
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
*
 
Regal Beloit Corporation; Franksville, WI; Trade Compliance Analyst;

#
Rohde & Schwarz; Columbia, MD; Import/Export Compliance Specialist;

*
 
Rohde Schwarz; Munich, Germany; 
Spezialist Exportkontrolle (m/w) 

*
 SABIC; Houston TX; 
Senior Analyst, Trade Compliance

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

* Shell; London, UK; Trade Compliance Manager; Requisition ID 96669BR


Signify; Eindhoven, The Netherlands; 
Global Trade Compliance Officer Export Controls
# Smiths Detection; Hemel Hempstead, United Kingdom; Trade Compliance Manager; Requisition ID: SDET00748; 
* Societé Générale Securities Services; Munich, Germany; Sachbearbeiter Trade Compliance; Requisition ID: 1800112L;  
*
 
SpaceX; Hawthorne, CA; Counsel, Export Compliance Officer;


*
 
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; 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;
*
 
Triniseo; Frankfurt, Germany; 
International Trade & Compliance Specialist EMEA
;
*
 
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; 
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
*
 
University of California; San Francisco, CA; 
Export Control Officer
; Requisition ID: 51010;

#
Wellesley Asset Management; Wellesley, MA; Chief Compliance Officer;
World Wide Technology; Edwardsville, IL; 
International Trade Compliance Specialist
;

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

* 
XPO Logistics; Amsterdam, Netherlands; 

#
YETI Coolers; Austin, TX; Inbound Logistics and Trade Compliance Manager; 

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

TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a19FCC Presents Renewed U.S. Export Controls Awareness Course: “ITAR & EAR from a non-U.S. Perspective”, 9 April in Bruchem, the Netherlands

 
Our next academy course is specifically designed for beginning compliance professionals and those in a similar role who aim to stay up-to-date with the latest U.S. export control requirements that apply to non-U.S. transactions, and industry’s best practices.
 
The course will cover multiple topics relevant for organizations outside the U.S. that are subject to U.S. export controls, including: the U.S. regulatory framework, key concepts and definitions, tips regarding classification and licensing, essential steps to ensure a U.S. export control compliant shipment, how to handle a (potential) non-compliance issue, recent enforcement trends, and the latest and anticipated regulatory amendments.  Participants will receive a certification upon completion of the training.
 
* What: Awareness Course U.S. Export Controls: ITAR & EAR from a Non-U.S. Perspective 
* When: Tuesday, 9 Apr 2010, 9.30 am – 4.30 pm (CET)
* Where: Landgoed Groenhoven, Bruchem, the Netherlands
* Sponsor: Full Circle Compliance (FCC)
* Instructors: Michael E. Farrell, and Drs. Alexander P. Bosch 
* Information & Registration: HERE, email 
events@fullcirclecompliance.eu,
 or call us at +31 6 15 65 02 09.
 
Register now and get a 10% Early Bird discount 
on the course fee!

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

ENEDITOR’S NOTES


Rudyard Kipling
(Joseph Rudyard Kipling; 30 Dec 1865 – 18 Jan 1936, was an English journalist, short-story writer, poet, and novelist. He was born in India, which inspired much of his work. His works of fiction include The Jungle Book (1894), Kim (1901), and many short stories, including “The Man Who Would Be King” (1888). His most famous poems include “Mandalay” (1890) and “Gunga Din” (1890). Kipling is regarded as a major innovator in the art of the short story, and his children’s books are classics of children’s literature.)
  – “All the people like us are We, and everyone else is They.”
  – “He wrapped himself in quotations–as a beggar would enfold himself in the purple of Emperors.”
 
* Horace Smith (Horace (born Horatio) Smith; 31 Dec 1779 – 12 Jul 1849; was an English poet and novelist, perhaps best known for his participation in a sonnet-writing competition with Percy Bysshe Shelley.)
  – “Courage is the fear of being thought a coward.” 
 
Today is New Year’s Eve:
* A New Year’s resolution is something that goes in one year and out the other.
* My New Year’s resolution is to stop hanging out with people who ask me about my New Year’s resolutions.
* If you were born in September, it’s pretty safe to assume your parents started out the New Year with a Bang!
* I have only one resolution. To rediscover the difference between wants and needs. May I have all I need and want all I have.

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

EN_a311
. Are Your Copies of Regulations Up to Date?
(Source: Editor)

 
* DHS CUSTOMS REGULATIONS: 19 CFR, Ch. 1, Pts. 0-199.  Implemented by Dep’t of Homeland Security, U.S. Customs & Border Protection.
  – Last Amendment: 18 Dec 2018: 83 FR 64942-65067: Modernized Drawback  
 

DOC EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774. Implemented by Dep’t of Commerce, Bureau of Industry & Security.
  – Last Amendment: 20 Dec 2018: 83 FR 65292-65294: Control of Military Electronic Equipment and Other Items the President Determines No Longer Warrant Control Under the United States Munitions List (USML); Correction [Concerning ECCN 7A005 and ECCN 7A105.]
 
* DOC FOREIGN TRADE REGULATIONS (FTR): 15 CFR Part 30.  Implemented by Dep’t of Commerce, U.S. Census Bureau.
  – Last Amendment: 24 Apr 2018: 83 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 website.  BITAR 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.   

 

DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM): DoD 5220.22-M. Implemented by Dep’t of Defense.
  – 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.)
 
 
DOE ASSISTANCE TO FOREIGN ATOMIC ENERGY ACTIVITIES: 10 CFR Part 810; Implemented by Dep’t of Energy, National Nuclear Security Administration, under Atomic Energy Act of 1954.
  – Last Amendment: 23 Feb 2015: 80 FR 9359, comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. This rule also identifies destinations with respect to which most assistance would be generally authorized and destinations that would require a specific authorization by the Secretary of Energy.
 
DOE EXPORT AND IMPORT OF NUCLEAR EQUIPMENT AND MATERIAL; 10 CFR Part 110; Implemented by Dep’t of Energy, U.S. Nuclear Regulatory Commission, under Atomic Energy Act of 1954.
  – Last Amendment: 20 Nov 2018, 10 CFR 110.6, Re-transfers.
 

* DOJ ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War.  Implemented by Dep’t of Justice, Bureau of Alcohol, Tobacco, Firearms & Explosives.
  – 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.  

 

DOS INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130. Implemented by Dep’t of State, Directorate of Defense Trade Controls.
  – 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.
 
* DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders. 

Implemented by Dep’t of Treasury, Office of Foreign Assets Control.

  – Last Amendment: 15 Nov 2018: 83 FR 57308-57318: Democratic Republic of the Congo Sanctions Regulations
  
* USITC HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA), 1 Jan 2018: 19 USC 1202 Annex. Implemented by U.S. International Trade Commission. (“HTS” and “HTSA” are often seen as abbreviations for the Harmonized Tariff Schedule of the United States Annotated, shortened versions of “HTSUSA”.)
  – Last Amendment: 19 Dec 2018: Harmonized System Update (HSU) 1820, containing 19,061 ABI records and 3,393 harmonized tariff records.
  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

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

EN_a0312
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 6,500 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOE/NRC, DOJ/ATF, DoD/DSS, DoD/DTSA, FAR/DFARS, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

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

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


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