;

19-0114 Monday “Daily Bugle'”

19-0114 Monday “Daily Bugle”

Monday, 14 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.

  1. DHS/CBP Amends Regulations, Extents Import Restrictions Imposed on Certain Archaeological and Ecclesiastical Ethnological Material from Bulgaria 
  2. DHS/CBP Amends Regulations, Extends Import Restrictions Imposed on Certain Archaeological Material from China 
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. EU Amends Regulations Concerning Certain Economic and Financial Restrictions with Iraq
  1. Defense News: “France, Germany Aim to Unify Their Clashing Weapons-Export Rules” 
  2. ST&R Trade Report: “Export Services on Hold During Shutdown but Enforcement Continues” 
  1. M. Lester: “UN Sanctions Best Practices Guide”
  2. M. Volkov: “Episode 72 – 2018 Review of OFAC Sanctions Enforcement and Compliance Trends”
  3. Trade Practitioner: “US-EU Export Controls and Sanctions Alert: In Case of Hard Brexit, EU and UK Issue Plans for Export of Dual-use Goods”
  1. Brian Nilsson is Appointed President, Brewton Kobbe Consulting LLC
  2. Monday List of Ex/Im Job Openings: 147 Openings Posted This Week, Including 16 New Openings
  1. “18th Annual ‘Partnering for ComplianceTM’ Export/Import Control Conference” on 5-7 Mar; “Customs/ Import Boot Camp” on 8 Mar; Both in Orlando, FL
  2. FCC Presents U.S. Export Controls Awareness Course: “ITAR & EAR from a non-U.S. Perspective”, 9 April in Bruchem, the Netherlands
  1. VSDs to Commerce/OEE Being Returned Unopened 
  2. Bartlett’s Unfamiliar Quotations 
  3. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (14 Jan 2019), 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) 
  4. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1
1. DHS/CBP Amends Regulations, Extents Import Restrictions Imposed on Certain Archaeological and Ecclesiastical Ethnological Material from Bulgaria

(Source: Federal Register, 14 Jan 2019.) [Excerpts.]
 
84 FR 112-116: Extension of Import Restrictions Imposed on Certain Archaeological and Ecclesiastical Ethnological Material from Bulgaria
* AGENCY: U.S. Customs and Border Protection, Department of Homeland Security; Department of the Treasury.
* ACTION: Final rule.
* SUMMARY: This document amends the U.S. Customs and Border Protection (CBP) regulations to reflect an extension of import restrictions on certain archaeological and ecclesiastical ethnological material from Bulgaria. The restrictions, which were originally imposed by CBP Dec. 14-01, are due to expire on January 14, 2019. The Assistant Secretary for Educational and Cultural Affairs, United States Department of State, has made the requisite determination for extending the import restrictions that previously existed and entering into a new Memorandum of Understanding (MOU) with Bulgaria to reflect the extension of these import restrictions. The new MOU supersedes and replaces the existing agreement that became effective on January 14, 2014. This new MOU also corrects an inconsistency existing between the previous MOU and the Designated List that describes the types of archaeological and ecclesiastical ethnological material to which the restrictions apply.
* DATES: Effective January 14, 2019.
* FOR FURTHER INFORMATION CONTACT: For regulatory aspects, Lisa L. Burley, Branch Chief, Cargo Security, Carriers and Restricted Merchandise Branch, Regulations and Rulings, Office of Trade, (202) 325-0215, ot-otrrculturalproperty@cbp.dhs.gov. For operational aspects, Christopher N. Robertson, Branch Chief, Commercial Targeting & Analysis Center, Trade Policy and Programs, Office of Trade, (202) 325-6586, CTAC@cbp.dhs.gov.
* SUPPLEMENTARY INFORMATION: …
   The bilateral agreement between the United States and Bulgaria includes, but is not limited to, the categories of objects described in the designated list set forth below. These categories of objects are subject to the import restrictions set forth above, in accordance with the above explained applicable law and the regulation amended in this document (19 CFR 12.104(g)(a)).
   The import restrictions include complete examples of objects and fragments thereof. …
 
  Kevin K. McAleenan, Commissioner, U.S. Customs and Border Protection.
Approved: January 8, 2019.
  David J. Kautter, Assistant Secretary of the Treasury.

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

EXIM_a2
2. DHS/CBP Amends Regulations, Extends Import Restrictions Imposed on Certain Archaeological Material from China

(Source: Federal Register, 14 Jan 2019.) [Excerpts.]
 
84 FR 107-112: Extension of Import Restrictions Imposed on Certain Archaeological Material From China
* AGENCY: U.S. Customs and Border Protection; Department of Homeland Security; Department of the Treasury.
* ACTION: Final rule.
* SUMMARY: This document amends the U.S. Customs and Border Protection (CBP) regulations to reflect an extension of import restrictions on certain archaeological material from China. The restrictions, which were originally imposed by CBP Dec. 09-03 and last extended by CBP Dec. 14-02, are due to expire on January 14, 2019. The Assistant Secretary for Educational and Cultural Affairs, United States Department of State, has made the requisite determination for extending the import restrictions that previously existed and entering into a new Memorandum of Understanding (MOU) with China to reflect the extension of these import restrictions. The new MOU supersedes the existing agreement that became effective on January 14, 2009. Accordingly, these import restrictions will remain in effect for an additional five years, and the CBP regulations are being amended to reflect this further extension through January 14, 2024. This document also contains the amended Designated List that describes the types of archaeological material to which the restrictions apply, including a new subcategory of glass objects from the Zhou period through the Tang period.
* DATES: Effective January 14, 2019.
* FOR FURTHER INFORMATION CONTACT: For regulatory aspects, Lisa L. Burley, Branch Chief, Cargo Security, Carriers and Restricted Merchandise Branch, Regulations and Rulings, Office of Trade, (202) 325-0215, ot-otrrculturalproperty@cbp.dhs.gov. For operational aspects, Christopher N. Robertson, Branch Chief, Commercial Targeting & Analysis Center, Trade Policy and Programs, Office of Trade, (202) 325-6586, CTAC@cbp.dhs.gov.
* SUPPLEMENTARY INFORMATION: …
   Import restrictions listed at 19 CFR 12.104g(a) are effective for no more than five years beginning on the date on which the agreement enters into force with respect to the United States. This period may be extended for additional periods of not more than five years if it is determined that the factors which justified the initial agreement still pertain and no cause for suspension of the agreement exists. …
     The Assistant Secretary for Educational and Cultural Affairs, United States Department of State, after consultation with and recommendations by the Cultural Property Advisory Committee, determined that the cultural heritage of China continues to be in jeopardy from pillage of certain archaeological material and that the import restrictions should be extended for an additional five years. Subsequently, a new MOU was concluded between the United States and China. The new MOU supersedes and replaces the prior MOU, extends the import restrictions that went into effect under the prior MOU for an additional five years and adds a new subcategory of glass objects from the Zhou period through the Tang period. This new MOU is titled: “Memorandum of Understanding Between the Government of the United States of America and the Government of the People’s Republic of China Concerning the Imposition of Import Restrictions on Categories of Archaeological Material of China.” The new MOU revises the Designated List of cultural property described in CBP Dec. 14-02, as set forth below. Accordingly, CBP is amending 19 CFR 12.104g(a) to reflect the extension of these import restrictions.
   The restrictions on the importation of archaeological material from China are to continue in effect through January 14, 2024. Importation of such material from China continues to be restricted through that date unless the conditions set forth in 19 U.S.C. 2606 and 19 CFR 12.104c are met. …
 
  Kevin K. McAleenan, Commissioner, U.S. Customs and Border Protection.
Approved: January 9, 2019.
  David J. Kautter, Assistant Secretary of the Treasury.

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

OGSOTHER GOVERNMENT SOURCES

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

 

[No items of interest noted today.]  

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

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

(Source: 
Commerce/BIS)

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

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

(Source:
Official Journal of the European Union, 14 Jan 2019.)
 
Regulations:
* Commission Implementing Regulation (EU) 2019/51 of 11 January 2019 amending Council Regulation (EC) No 1210/2003 concerning certain specific restrictions on economic and financial relations with Iraq

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

NWSNEWS

NWS_a17. Defense News: “France, Germany Aim to Unify Their Clashing Weapons-Export Rules”
(Source: Defense News, 12 Jan 2019.)
 
A new, high-level pact with France that calls for a common approach to weapons exports in all joint programs.  
The objective is included in the so-called Aachener Vertrag, slated to be signed by French President Emmanuel Macron and German Chancellor Angela Merkel in the German city of Aachen on Jan. 22. The document is meant to be a milestone agreement complementary of the Élysée Treaty, signed 56 years ago, further cementing ties on all levels between the former World War II foes.
 
Berlin and France previously clashed over the question of export limitations for the Future Combat Air System, a sixth-generation warplane envisioned to take flight sometime around 2040, Germany’s Der Spiegel reported last fall. France generally is open to exporting arms to many governments willing to pay for them. German leaders profess to take a more cautious approach when human rights concerns crop up, though the government has a history of making arms deals through the back door anyway.
 
The different philosophies came to a head following the death of Saudi journalist Jamal Khashoggi on Oct. 2, which some have alleged was orchestrated by Saudi Arabian Crown Prince Mohammed bin Salman. The Saudi ruling family has denied the allegations, buoyed by the Trump administration’s decision to play down the matter.
 
The allegations led Merkel to publicly call for halting weapons exports to Saudi Arabia, a move that drew a sharp rebuke from Paris, where officials fumed about what they perceived as German sanctimoniousness.
 
France and Germany’s diverging export policies are based on their respective “strategic cultures,” said Wolfgang Rudischhauser, vice president of the Federal Academy for Security Policy in Berlin. Germany considers itself a “peace power,” whereas France models its policies on the premise of an “intervention army,” he said.
 
Asked whether the section on harmonizing export policies in the Aachener Vertrag was aimed at least in part at the future combat aircraft program, a spokesman for the German foreign ministry pointed out that no projects were explicitly mentioned in the draft treaty text.
 
That program, together with a future main battle tank and a future combat drone, forms the backbone of Franco-German defense ambitions, with tens of billions of dollars at stake.
 
With a concrete objective toward harmonizing arms-export rules now on the books between Paris and Berlin, Rudischhauser argued that a European Union-wide regime would be needed in the end.  
“That would require ceding certain authorities to the EU, for which neither Germany nor France have shown an appetite,” he told Defense News.
 
To oversee the the new treaty’s defense provisions, the pact establishes a bilateral defense and security council, which would “convene regularly at the highest level.”

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

NWS_a28. ST&R Trade Report: “Export Services on Hold During Shutdown but Enforcement Continues”

 
The ongoing federal government shutdown has halted a number of activities related to controlled exports, although enforcement actions are said to be continuing. Following is an update on the current status of these services.
 
Bureau of Industry and Security
 
  – The SNAP-R system that allows users to electronically submit export and reexport license applications and commodity classification requests is inaccessible.
  – Other services are significantly curtailed, including processing voluntary self-disclosures, except those in direct support of the U.S. military or humanitarian aid.
 
Directorate of Defense Trade Controls
 
  – Services are significantly curtailed, including processing requests for licenses, advisory opinions, commodity jurisdiction requests, voluntary self-disclosures, and retransfers, except for those that provide direct support to the military, humanitarian aid, or other similar emergencies.
  – All D-Trade electronic submissions will be rejected by the system and returned to the applicant.
 
Office of Foreign Assets Control
 
  – Online licensing services are inaccessible.
  – There are significant delays for pending license applications and voluntary disclosures.

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

COMMCOMMENTARY

(Source:  
European Sanctions Blog, 14 Jan 2019.)
 
* Author: Maya Lester, Esq., Brick Court Chambers,
maya.lester@brickcourt.co.uk, +44 20 7379 3550.
Australia, Belgium, Germany, the Netherlands and Sweden have come together to create a 
Best Practices Guide for Chairs and Members of UN Sanctions Committees.
 
The Guide (inter alia) outlines the roles and interrelationship of key sanctions actors (e.g. UN Security Council); describes the standard practices by which Chairs and Members of Sanctions Committees operate; provides a list of sanctions currently in force, including a description of the types of sanctions, how they work, and the compliance obligation standards that apply; and outlines the activities and endeavours by sanctions committees that enhance effective sanctions implementation, such as thematic sanctions, designations and due process, and sanctions and human rights.
 
The Guide in its present form will be subject to further consultations and refinements when the project enters its second phase, during which a Best Practices Guide for UN sanctions monitoring expert groups and their coordinators will be developed.

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

(Source:
Volkov Law Group Blog, 13 Jan 2019. Reprinted by permission.)
 
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
 
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) had a busy year – the first half of 2018 was dedicated to re-imposing the Iran Sanctions Program and updating the Russia Sanctions Program. In the second half of the year, OFAC resumed its pace for enforcement actions.
 
In this episode, Michael Volkov reviews OFAC enforcement actions and sanctions regulations for 2018.

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

(Source:
Squire Patton Boggs, 4 Jan 2019.)
 
Due to the vacillating political developments in the UK, a “hard Brexit” scenario (meaning, no withdrawal agreement reached between the EU and UK by the withdrawal date of March 30, 2019) is likely to happen. In preparation for a no-deal withdrawal, which would affect the trade of dual-use items between the EU and the UK, the European Commission (the Commission) adopted on December 19, 2018 a
contingency plan that provides a number of mitigating measures in an effort to minimize the disruptions that would be caused by a hard Brexit, while protecting EU interests.
 
Within these measures, the Commission proposed an amendment to the EU Dual-Use Regulation –
Council Regulation (EC) No 428/2009 – to allow the inclusion of the UK in the list destinations covered by the Union General Export Authorisation No. EU001 in the event of a hard Brexit. This amendment,
as proposed, permits the export of most dual-use goods to “safe” countries like the US or Canada, but exporters are subject to certain compliance obligations (e.g., registration or notification of first exports). The amendment is subject to the normal legislative process and is expected to be adopted by the European Parliament and the Council of the EU. The Commission expects that these institutions will proceed with this amendment as quickly as possible to have it in place before March 30, 2019.
 
Simultaneously, the UK Export Control Joint Unit confirmed
its intention to issue a general license authorizing export of dual-use goods from the UK to the EU in case of hard Brexit.

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


MSEX/IM MOVERS & SHAKERS

(Source: Editor)
 

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

MS_a113. Monday List of Ex/Im Job Openings: 147 Openings Posted This Week, Including 16 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; Internship within Procurement Compliance, Regulations & Risks; Requisition ID: 10438469 NU EN EXT 1;

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

*
 
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; 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;

* 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; Flexible location, U.S.; Associate Manager, Customs & Trade; Requisition ID: JR0000536

#
DHL; Detroit, MI; Ocean Export Agent;

* 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 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 Analyst;
#
EnerSys; Reading, PA; International Transportation Analyst; Requisition ID: 20180807;

*
 
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;

* 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;

#
Fortive – Tektronix; Beaverton, OR; Chief Compliance Counsel;
#
Fortive – HealthNewCo; Irvine, CA; Global Trade Compliance Manager;

* 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;

#
IGT; Reno, NV; Global Trade Compliance Specialist; Requisition ID: 291;
 


* 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;

* Kohler Co; Kohler, WI; Analyst, International Trade Compliance; Requisition ID: 18105; 

* 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

#
Luminex; Austin, TX; Global Logistics & Trade Compliance Analyst – US; Requisition ID: 561

* 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;

#
Panasonic Avionics; Houston, TX; Import/Export Analyst;

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


Philips; Eindhoven, The Netherlands; 
Export Control Officer
;

#
PPD; Morrisville, NC; Trade Compliance Manager;

* PwC; Houston, TX; Customs and International Trade Director; Requisition ID: 38150WD;

#
Rawlings Sporting Goods, St. Louis, MO, Trade Compliance Analyst

*
 
Raytheon; Dulles, VA; 
Principal Global Trade License;


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

* 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;


#
Spencer Gifts & Spirit Halloween; Egg Harbor Twp. NJ; Customs Compliance Classification Analyst;
kelly.talis@spencergifts.com
;

*
 
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
;

* 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;

#
United Technologies – Pratt & Whitney; East Hartford, CT; International Trade Compliance Manager; Requisition ID: 01279346;

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

#
Wealth Ocean; Newport Beach, CA; Marketing & International Trade Specialist;

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

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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a114. “18th Annual ‘Partnering for ComplianceTM‘ Export/Import Control Conference” on 5-7 Mar; “Customs/ Import Boot Camp” on 8 Mar; Both in Orlando, FL

(Source: A.E. NicPhaidin, Info@PartneringForCompliance.org)
 
* What: The 18th Annual “Partnering for Compliance
TM” will focus intensely on a broad spectrum of export/import regulatory and compliance matters of current relevance to companies and individuals involved in global trading. Senior-level government officials and trade experts will provide first-class training.
* Where: Holiday Inn Orlando International Airport Hotel (completely renovated)  
* When:
  – Tue – Thu, 5-7 Mar: “18th Annual ‘Partnering for Compliance
TM‘ Export Control Program”
  – Fri, 8 Mar: 1-Day Program “Customs/Import Boot Camp”
* Speakers confirmed: DoS/DDTL: Terry Davis; DoS/DDTC: Daniel Cook (Invited); DoC/BIS: Sharron Cook & OEE speaker confirmed (TBD); DoD/DTSA: Ken Oukrop; OFAC: Kerri Bitsoff, Enforcement (Confirmed) & Anthony Musa, Licensing: (Invited); Census Bureau: Omari Wooden; DHS/CBP: Eric LaRoche; ICE: Timothy Dwyer; USMCA: Candace Sider (Invited); Imports: Braumiller Law Group PLLC: Adrienne Braumiller & Bruce Leeds; and U.S. trade.
* Opening Keynote Address: Delegation of the E.U. to the U.S., BREXIT (Invited) * Cost: Export 3-day program: $650. Customs/Import 1-day program: $250. Both programs: $900.
* Remarks: Maximum capacity is 200 participants to maintain informal and collaborative environment.
* As time permits, all Government and trade speakers will informally hold short “one-to-one” meetings with participants on a “first-come, first-served” basis.
* Certificates of Completion granting: 4.5 IIEI CEUs and 20
CES NCBFAA Credits for 3-day Exports program, and 6.5 CCS NCBFAA Credits for 1-day Customs/Import Boot Camp will be awarded for each program.
* More information: Here.

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TE_a215FCC 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!

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ENEDITOR’S NOTES

*
LL Cool J (James Todd Smith; born January 14, 1968; known professionally as “LL Cool J” (short for Ladies Love Cool James), is an American hip hop recording artist, record producer, actor, author and entrepreneur from Queens, New York. A two-time Grammy Award winner, LL Cool J has released 13 studio albums and two greatest hits compilations. His twelfth album Exit 13 (2008), was his last for his long-tenured deal with Def Jam Recordings. In 2010, VH1 has placed him on their “100 Greatest Artists Of All Time” list.)
– “Once the referee throws the ball in the air, it’s either your ball or their ball and you have to just take your shot.”


* Albert Schweitzer (14 Jan 1875 – 4 Sep 1965; was an Alsatian theologian, organist, writer, humanitarian, philosopher, and physician. He received the 1952 Nobel Peace Prize for his philosophy of “Reverence for Life”, becoming the eighth Frenchman to be awarded that prize.)
  – “Do something wonderful, people may imitate it.”
  – “Constant kindness can accomplish much. As the sun makes ice melt, kindness causes misunderstanding, mistrust, and hostility to evaporate.”
 
* John Dos Passos (John Roderigo Dos Passos; 14 Jan 1896 – 28 Sep 1970; was an American novelist, most notable for his U.S.A. trilogy, written in experimental ‘non-linear’ form, blending elements of biography and news reports to paint a landscape of early 20th-century American culture.  His U.S.A. trilogy, consisting of the novels The 42nd Parallel1919, and The Big Money, was ranked by the Modern Library in 1998 as ranking 23rd in the 100 best English-language novels of the 20th century.
  – “It’s almost worth having been in the army for the joy your freedom gives you.”
 
Monday is pun day:
* Did you hear about the man who jumped off a bridge in Paris? He was in Sein.
* Trying to write with a broken pencil is pointless.
* Cleaning mirrors is a job I could really see myself doing.
* * * * * * * * * * * * * * * * * * * *

EN_a318
. 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: 14 Jan 2019: 84 FR 112-116: Extension of Import Restrictions Imposed on Certain Archaeological and Ecclesiastical Ethnological Material from Bulgaria; and 84 FR 107-112: Extension of Import Restrictions Imposed on Certain Archaeological Material From China 
 

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_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

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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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