;

19-0107 Monday “Daily Bugle'”

19-0107 Monday “Daily Bugle”

Monday, 7 January 2019

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.

[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. DoD/DSCA Posts Policy Memo 18-64
  4. State/DDTC: (No new postings.)
  5. Dutch/Foreign Affairs Posts Factsheet on Russian Sanctions
  1. Android News: “ZTE’s Senator Hiring Prompts Angry Anti-Corruption Calls” 
  2. Reuters: “Chinese Tech Investors Flee Silicon Valley as Trump Tightens Scrutiny” 
  3. ST&R Trade Report: “New Importer ID Form Expected to be Released in February” 
  1. J.A. Lee, R. Kirk & P. Alexiadis: “Government Shutdown Update – Sanctions, Export Controls, and Other International Trade Operations”
  2. M. Volkov: “Episode 71 – 2019 Ethics and Compliance Predictions and Trends”
  1. Monday List of Ex/Im Job Openings: 146 Openings Posted This Week, Including 22 New Openings
  1. ECTI Presents “Empowered Officials: Who They Are and What They Need to Know”, Webinar – 30 Jan
  2. FCC Presents 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:
DoD/DSCA, 7 Jan 2018.)
 
  – This memo rescinds DSCA Policy Memo 18-47 due to potential negative consequences in meeting the requirements outlined in Section 1297(b) of the National Defense Authorization Act for Fiscal Year 2017. Over the next 120 days, DSCA will lead a reassessment of options for responding to the requirements of Section 1297(b).

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

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

(Source:
Rijksoverheid, 20 Dec 2018.)
 
The Dutch Ministry of Foreign Affairs has posted a new factsheet on the Russian sanctions to assist organizations in navigating them.  The factsheet (in Dutch) can be downloaded here.

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

NWSNEWS

NWS_a16. Android News: “ZTE’s Senator Hiring Prompts Angry Anti-Corruption Calls”

(Source: Android News, 5 Jan 2019.) [Excerpts.]
 
ZTE’s hiring of former United States Senator Joe Liberman as a senior member of its stateside lobbying team is already causing political backlash in Washington. Massachusetts Senator Elizabeth Warren criticized the move earlier this week as something that shouldn’t be legal, calling for a lifetime ban on lobbying work for Congress members. …
 
Mr. Liberman officially registered as a ZTE lobbyist several days back and is now set to be part of the company’s team seeking to lower the tensions between the American government and the Chinese telecom giant that’s majority-owned by a state company. The exact scope of his activities remains unclear, though he’s likely to attempt leveraging his decades-old connections in Washington to make life easier for ZTE.
 
A year’s worth of trouble
 
ZTE had a bad 2018 by most metrics given how it nearly went bankrupt after the Department of Commerce opted to cripple it with a denial order that prevented it from licensing or outright purchasing any kind of American technologies over a seven-year period. The move was made in response to the revelation that the company failed to adhere to the terms of a 2017 settlement with the same agency that saw it plead guilty to a conspiracy to circumvent stateside trade embargoes imposed on Iran and North Korea. Following extensive lobbying and pressure from Beijing itself, President Trump personally intervened and ordered the Commerce Department to cut a new deal with ZTE that would punish it for its transgression in a manner that doesn’t guarantee its demise. The White House opted to do so as it believed giving a lifeline to ZTE would help its trade talks with China, though that assumption didn’t pan out given how it later got involved in a full-blown trade war with the Far Eastern country which is currently on hold, albeit only temporarily.
 
After months of additional negotiations, the Commerce Department lifted its anti-ZTE denial order and replace it with numerous other concessions which still left the Chinese firm in a troublesome state. The company was forced to throw out the entirety of its board and management, paid close to $1 billion in additional fines, finance an independent body that will be auditing it for future embargo violations over the next decade, and even agreed to increase its reliance on American goods in the near term. Coupled with some four months of halted operations, the new settlement forced ZTE to take out a $10 billion loan in order to resume normal business, with many industry watchers now doubting its ability to stay afloat, at least in the U.S. That’s particularly true given how Congress outlawed federal use of ZTE’s telecom equipment as part of its 2018 federal spending bill, citing national security concerns.
 
… and then it got worse
 
ZTE’s troubles with the U.S. government are seeing no end in sight either, with recent reports suggesting the White House is considering an executive order that would extend the aforementioned telecom ban to the private sector. At the same time, the company may be facing yet another investigation of potential trade sanction violations, this time due to its dealings with Venezuela and its government’s efforts to oppress its people. For its part, ZTE admits it made mistakes in the past but remains adamant that the very notion of its technologies posing a spying risk is baseless. The Western intelligence community disagrees, citing China’s strict laws that allow its authorities to easily compel companies into yielding information on its customers or compromising them in other ways with essentially no justification.
 
For the time being, ZTE continues to operate in the U.S. but the number of its devices being sold in the country dropped by a significant margin over the course of the last several months, while prepaid brands – by far its largest customers prior to the 2018 incident – are now extremely reluctant to do business with the firm, fearing political backlash. …

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

NWS_a27. Reuters: “Chinese Tech Investors Flee Silicon Valley as Trump Tightens Scrutiny”

(Source: Reuters, 7 Jan 2018.) [Excerpts.]
 
New Trump administration policies aimed at curbing China’s access to American innovation have all but halted Chinese investment in U.S. technology startups, as both investors and startup founders abandon deals amid scrutiny from Washington.
 
Chinese venture funding in U.S. startups crested to a record $3 billion last year, according to New York economic research firm Rhodium Group, spurred by a rush of investors and tech companies scrambling to complete deals before a new regulatory regime was approved in August.
 
Since then, Chinese venture funding in U.S. startups has slowed to a trickle, Reuters interviews with more than 35 industry players show.
 
U.S. President Donald Trump signed new legislation expanding the government’s ability to block foreign investment in U.S. companies, regardless of the investor’s country of origin. But Trump has been particularly vocal about stopping China from getting its hands on strategic U.S. technologies.
 
The new rules are still being finalized, but tech industry veterans said the fallout has been swift.
 
  “Deals involving Chinese companies and Chinese buyers and Chinese investors have virtually stopped,” said attorney Nell O’Donnell, who has represented U.S. tech companies in transactions with foreign buyers. …
 

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

NWS_a38. ST&R Trade Report: “New Importer ID Form Expected to be Released in February”

 
U.S. Customs and Border Protection has posted to its website a final draft of the revised CBP Form 5106 (see attached), which will be renamed the Create/Update Importer Identity Form. This form is expected to be released in February when CBP plans to automate and modernize the process for inputting it via the Automated Commercial Environment.
 
The collection of the information on CBP Form 5106 is the basis for establishing bond coverage, release and entry of merchandise, liquidation, and the issuance of bills and refunds. Each person, business firm, government agency, or other organization that intends to file an import entry must file this form with the first formal entry or request for services that will result in the issuance of a bill or a refund check upon adjustment of a cash collection. This form is also filed for the ultimate consignee for whom an entry is being made.
 
The updated form requests a variety of additional information from importers that CBP has said will support more advanced risk analysis and provide for more informative risk assessments prior to importation. Much of this information will come from section 3, which requests personal information about company owners and officers (e.g., social security numbers and passport numbers) as well as employer identification numbers or importer of record numbers for related business entities, both current and previous.
Tom Gould, senior director, customs and international trade, for Sandler, Travis & Rosenberg, states that CBP is expected to use this information to enhance its enforcement efforts. For example, if CBP finds that a company listed on the form as related to the filer has a negative import history (penalties, sanctions, liquidated damages, unpaid duties, etc.), that information could be used to target the filer for additional scrutiny. Gould adds that while many of the new data elements are optional, shipments and importers that do not provide them could see ramifications such as more inspections, document reviews, and CF-28s.
 
On the other hand, CBP has said the updated form will also provide for more streamlined processing for importers, brokers, sureties, and others through the ability to create, edit, and update importer information. Gould states that the revised form also provides additional benefits for companies certified under the Customs Trade Partnership Against Terrorism and Importer Self-Assessment programs, which will not have to provide personally identifying or other information in section 3.
 
Current importers with a valid form 5106 on file will not be required to resubmit once the revised form is released, but if there is any reason for submitting a new form 5106 (e.g., change of name or address) the new form will be required.
 
View Document(s):

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

COMMCOMMENTARY

 
* Authors: Judith A. Lee, Esq., jalee@gibsondunn.com, +1 202-887-3591; Ronald Kirk, Esq., rkirk@gibsondunn.com, +1 214-698-3295; and Peter Alexiadis, Esq., palexiadis@gibsondunn.com, +32 2 554 72 00. All of Gibson, Dunn & Crutcher LLP.
 
The U.S. Government is now approaching the second week of a partial shutdown that has affected nine departments, several agencies, and approximately 800,000 federal workers. The U.S. Government agencies responsible for administering U.S. sanctions, export controls, and other trade-related functions are among those affected by the lapse in federal appropriations. As a result, these agencies have substantially reduced their operations. While some of these agencies’ core functions will continue to operate, the shutdown will certainly increase wait times for licenses, advisory opinions, or other responses and will generally hamper communication with the agencies, even on time-sensitive requests. A brief overview of the current operating status of these international trade-related agencies follows below.
OFAC
 
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), which administers U.S. sanctions programs, remains functional but in limited capacity. [FN/1] OFAC continues to administer the Specially Designated Nationals and Blocked Persons (“SDN”) List and to enforce U.S. sanctions and will administer newly authorized sanctions should the need arise. OFAC is situated in the U.S. Treasury Department’s Office of Terrorism and Financial Intelligence, which will continue to perform certain limited national security-related functions.
 
Guidance from the Department indicates that OFAC will also have limited capacity to communicate with financial institutions and other affected industries during the shutdown. As a result of these restrictions, the public can expect increased wait times for responses to license applications, voluntary disclosures, advisory opinions, and other communications. In our experience, most efforts to contact OFAC policy personnel have gone unanswered and messages to compliance officers have been met with out-of-office replies citing the shutdown.
BIS and DDTC
 
Although the U.S. Department of Commerce is closed, its Bureau of Industry and Security (“BIS”), which is responsible for administering U.S. export controls applicable to dual use items, remains relatively well-staffed. According to the Department’s shutdown guidance, almost 70 percent of the Bureau’s 358 employees are excepted from the shutdown either because they are considered essential or because funding for their positions comes from alternative sources. [FN/2] The Department’s shutdown guidance also notes that ongoing export enforcement will continue during the lapse in appropriations. [FN/3] However, as with the other agencies described here, even a slight reduction in personnel may make it more difficult to receive responses from BIS.
 
The U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) administers restrictions on the export of defense articles, defense services, and related technical data. While the State Department has provided relatively little information regarding its shutdown operations, DDTC has helpfully set forth certain specifics regarding its “significantly curtailed” operations. [FN/4] During the shutdown DDTC will have limited ability to process license requests, advisory opinions, and retransfers. DTrade, the portal for requesting and receiving license requests, automatically rejects new submissions, and the Directorate’s daily pick-up and drop-off service is cancelled. Requests in-process at the time of the shutdown will remain in-process but further action will not occur until funding is restored. DDTC may, however, respond to certain emergency requests.
Other Trade-Related Functions
 
Other offices and agencies responsible for performing trade-related functions are differently impacted by the ongoing shutdown. For example, The Committee on Foreign Investment in the United States (“CFIUS”), the interagency committee tasked with reviewing foreign investment in the United States, is also operating at reduced capacity. According to guidance published by the Department of the Treasury, CFIUS will be able to perform “caretaker functions” related to existing reviews or investigations of inbound investment initiated before the recently enacted Foreign Investment Risk Review Modernization Act (“FIRRMA”), but ongoing cases will be tolled. [FN/5] Although the Committee will continue to perform certain national security functions, other CFIUS activities are suspended.
 
Although BIS is experiencing only limited personnel reductions, the Department of Commerce’s International Trade Administration and the Bureau of Economic Analysis are operating with a fraction of their normal operating personnel. The U.S. International Trade Commission is closed, which could delay the release of the Commission’s report on the economic impact of the new U.S.-Mexico-Canada Agreement. [FN/6] The Office of the U.S. Trade Representative, which administers the new tariffs on Chinese imports, remains operational. [FN/7]
 
————-

   [FN/1]   U.S. Dep’t of the Treasury,
Lapse of Appropriations Plan 7 (Dec. 2018).

   [FN/2]   U.S. Dep’t of Commerce, Plan for Orderly Shutdown Due to Lapse of Congressional Appropriations 6 (Dec. 17, 2018).
   [FN/3]   U.S. Dep’t of Commerce, Shutdown Due to Lapse of Congressional Appropriations, Blog (Dec. 22, 2018).
   [FN/4]   DDTC, U.S. Dep’t of State, Industry Notice: Lapse in Funding, News & Events (Dec. 22, 2018).
   [FN/5]   U.S. Dep’t of the Treasury, Lapse of Appropriations Plan 7 (Dec. 2018).
   [FN/6]   Jennifer Scholtes, Caitlin Emma, and Katy O’Donnell, How the Shutdown Is Reaching a Breaking Point, Politico (Jan. 3, 2018).
   [FN/7]   Press Release, Office of the U.S. Trade Representative, USTR Operating Status (Dec. 28, 2018).

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

(Source:
Volkov Law Group Blog, 6 Jan 2019. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
In 2018, ethics and compliance professionals continued to innovate and push for compliance program enhancements. In response to growing demand, compliance industry vendors helped to implement new and innovative tools for use in compliance programs.
 
In
this episode, Michael Volkov reviews ethics and compliance trends and developments during 2018 and outlines predictions for the upcoming year.
 

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


MSEX/IM MOVERS & SHAKERS

MS_a111. Monday List of Ex/Im Job Openings: 146 Openings Posted This Week, Including 22 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; Budapest, Hungary; Trade Compliance Leader; Requisition ID: HU67333494_E1;

* 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;
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

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; 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; 

#
Cargill; Miami, FL; Export Trade Compliance Operations Specialist; Requisition ID: MIA00137;
#
Cargill; Miami, FL; Trade Compliance Analyst II; Requisition ID: COR00539;

#
CIRCOR International; Houston, TX; 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;


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

*
 
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; 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;

#
FLIR; Arlington, VA or Billerica, MA; Senior Director, Global Export Compliance; Requisition ID: REQ11409;

#
FLIR; Täby, Sweden; Compliance Site Operations Leader; Requisition ID: REQ11291;

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

GCP Applied Technologies; Cambridge, MA; 
Trade Compliance Manager

* General Atomics; San Diego, CA; 
Senior Government Compliance Specialist
; Requisition ID: 20736BR

#
General Dynamics; Falls Church, VA; Manager, Intl Trade Compliance; Requisition ID: 2018-50910;
#
General Electric Co; Grand Rapids, MI or Evendale/Cincinnati, OH; Senior Specialist-International Trade Compliance, Aviation and Military Exports;


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


# GSW Manufacturing Inc; Findlay, OH; Trade Compliance Analyst; 
* 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 Export & Trade Compliance Specialist; Requisition ID: 2164;

* 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; Milwaukee, WI; Director, Global Trade Compliance; Requisition ID: WD30055791295;

#
Johnson Controls; Tamaulipas, Matamoros, Mexico; Trade Compliance Specialist; Requisition ID: EB00064485194;

* Kansas City Power & Light Company; Kansas City, MO; Energy Trading Compliance Program Manager;  

* 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

#
Lutron Electronics Co; Lehigh Valley, PA; Trade Compliance Coordinator; Requisition ID: 4025;


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;

#
PAX Labs; San Francisco, CA; Trade Compliance Manager;


Philips; Eindhoven, The Netherlands; 
Export Control Officer
;

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

#
Raytheon; Tuscon, AZ; Senior Export Licensing and Compliance Specialist; Requisition ID: 129588BR;

*
 
Regal Beloit Corporation; Franksville, WI; Trade Compliance Analyst;

#
Richemont; Fort Worth, TX; Import/Export Manager; Requisition ID: 8837;

* 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; 
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 – Carrier; Charlotte, IA; Senior Product Classification Specialist; Requisition ID: 12944;
#
United Technologies – Collins Aerospace; Cedar Rapids; Compliance Specialist-Government; Requisition ID: 01271793;

#
 United Technologies – Collins Aerospace; Windsor Locks, CT; Senior Manager, International Trade Compliance; Requisition ID: 01277872;

*
 
University of California; San Francisco, CA; 
Export Control Officer
; Requisition ID: 51010;

#
ValueOptim; Shelton, CT; Trade Compliance Supervisor;

* 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_a112. ECTI Presents “Empowered Officials: Who They Are and What They Need to Know”, Webinar – 30 Jan

(Source: Danielle Hatch, danielle@learnexportcompliance.com)
 
* What: Empowered Officials: Who They Are and What They Need to Know
* When: January 30, 2019; 1:00 p.m. (EST)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker: Scott Gearity
* Register: Here or Danielle Hatch, 540-433-3977, danielle@learnexportcompliance.com.

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

TE_a213FCC Presents 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

Thomas Dewar (Thomas Robert “Tommy” Dewar, 1st Baron Dewar; 6 Jan 1864 – 11 April 1930; was a Scottish whisky distiller who, along with his brother John Dewar, built their family label, Dewar’s, into an international success.)
  – “Judge not a man by his clothes, but by his wife’s clothes.”
 
* Zora Neale Hurston (7 Jan 1891 – 8 Jan 1960; was an influential author of African-American literature and anthropologist.  Her most popular book was the 1937 novel, Their Eyes Were Watching God.)
  – “Ships at a distance have every man’s wish on board.”
 
Monday is pun day:
 
* The first time I got a universal remote control, I thought to myself “This changes everything!”
 
* A geologist discovered a rock yesterday that measured 5,280 feet in length. Must been a real milestone.
 
* Why do the French eat snails? They don’t like fast food.
* * * * * * * * * * * * * * * * * * * *

EN_a315
. 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 (1 Jan 2019) 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: 1 Jan 2019) 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_a0316
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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