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19-0325 Monday “Daily Bugle'”

19-0325 Monday “Daily Bugle”

Monday, 25 March 2019

  1. Commerce/BIS Seeks Comments Concerning Special Priorities Assistance (Form BIS-999
  2. USTR Announces Annual GSP Product and Country Review, Considers Petitions from Interested Parties
  3. USTR Grants Additional Exclusion Requests as Part of Section 301 Investigation Concerning China
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS (No new postings.)
  3. DHS/ICE Removes Iranian Man Convicted of Violating IEEPA
  4. State/DDTC Seeks Attorney Candidates
  5. Treasury/OFAC Publishes Updated Advisory Highlighting Risks for Maritime Petroleum Shipping Community in Syria 
  6. EU Commission’s Directorate-General Trade Publishes Notice Concerning Dual-Use Export Control Regulations Related to UK
  7. UK OFSI Publishes Concerning Chemical Weapons Sanctions Guidance in Case of No-Deal Brexit
  1. Expeditors News: “European Council Extends the UK Withdrawal from the EU”
  2. Human Rights Watch: “Why Germany Shouldn’t Yield on Arms Sales to the Saudis”
  3. Llyod’s List: “Polish Register Defies U.S. Sanctions to Class Iranian Tankers”
  4. Sputnik News: “NASA Digitally Alters Pictures of NASA’s Space Launch System”
  1. A.H. Linning, S.J. Harris & Z.A. Keane: “Implementation of UN Security Council Sanctions by the Hong Kong Authorities”
  2. P. Demetriou: “Sanctions Lists: The Effects in Cyprus”
  1. Monday List of Ex/Im Job Openings: 147 Openings Posted This Week, Including 15 New Openings 
  1. FCC to Provide Awareness Training on Export Controls & Compliance, 2 Apr at NAG, Delft, the Netherlands
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (12 Mar 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 (14 Mar 2018), DOS/ITAR (19 Mar 2018), DOT/FACR/OFAC (15 Mar 2018), HTSUS (7 Mar 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1
1.
Commerce/BIS Seeks Comments Concerning Special Priorities Assistance (Form BIS-999)
(Source:
Federal Register, 25 Mar 2019.) [Excerpts.]

 
84 FR 11048-11049: Proposed Information Collection; Comment Request; Special Priorities Assistance
 
* AGENCY: Bureau of Industry and Security.
* ACTION: Notice.
* SUMMARY: The Department of Commerce, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995.
* DATES: To ensure consideration, written comments must be submitted on or before May 24, 2019.
* ADDRESSES: Direct all written comments to Jennifer Jessup, Departmental Paperwork Clearance Officer, Department of Commerce, 1401 Constitution Avenue NW, Room 6616, Washington, DC 20230 (or via the internet at docpra@doc.gov.)
* FOR FURTHER INFORMATION CONTACT: Requests for additional information or copies of the information collection instrument and instructions should be directed to Mark Crace, BIS ICB Liaison, (202) 482-8093 or at mark.crace@bis.doc.gov.
* SUPPLEMENTARY INFORMATION: … The information collected from defense contractors and suppliers on Form BIS-999, Request for Special Priorities Assistance, is required for the enforcement and administration of special priorities assistance under the Defense Production Act, the Selective Service Act and the Defense Priorities and Allocation System regulation. Contractors may request Special Priorities Assistance (SPA) when placing rated orders with suppliers, to obtain timely delivery of products, materials or services from suppliers, or for any other reason under the DPAS, in support of approved national programs. The Form BIS-999 is used to apply for such assistance. …
 
– OMB Control Number: 0694-0057.
– Form Number(s): BIS-999.
– Type of Review: Regular submission.
– Affected Public: Business or other for-profit organizations. …
– Legal Authority: Title I of the Defense Production Act. …
 
  Comments submitted in response to this notice will be summarized and/or included in the request for OMB approval of this information collection; they also will become a matter of public record.
 
Sheleen Dumas, Departmental Lead PRA Officer, Office of the Chief Information Officer, Commerce Department.

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

EXIM_a2
2.
USTR Announces Annual GSP Product and Country Review, Considers Petitions from Interested Parties
(Source:
Federal Register, 25 Mar 2019.) [Excerpts.]

 
84 FR 11150-11152: 2019 Generalized System of Preferences (GSP): Notice of Annual GSP Product and Country Review; Deadline for Filing Petitions
 
* AGENCY: Office of the United States Trade Representative.
* ACTION: Notice of statistics availability and announcement of annual GSP review.
* SUMMARY: The Office of the United States Trade Representative (USTR) will consider petitions to modify the GSP status of GSP beneficiary developing countries (BDCs) because of country practices; add products to GSP eligibility; remove products from GSP eligibility for one or more countries; waive competitive need limitations (CNLs); deny de minimis waivers for products eligible for de minimis waivers; and redesignate currently excluded products. This review will include separate hearings on product petitions and country eligibility reviews, which USTR will announce in the Federal Register at a later date.
* DATES: April 18, 2019 at midnight EST: Deadline for petitions to modify the GSP status of certain GSP beneficiary developing countries because of country practices; petitions requesting waivers of CNLs; petitions on GSP product eligibility additions or removals; petitions to deny de minimis waivers; petitions to redesignate an excluded product; and petitions for continuation of CNLs that have exceeded certain thresholds. USTR will not consider petitions submitted after the April 18, 2019 deadline. USTR will announce the petitions accepted for review, along with a schedule for any related public hearings and the opportunity for the public to provide comments, at a later date.
* ADDRESSES: USTR strongly prefers electronic submissions made through the Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments in section III below. The docket number is USTR-2019-0001. For alternatives to on-line submissions, please contact Lauren Gamache at gsp@ustr.eop.gov, or 202-395-2974.
* FOR FURTHER INFORMATION CONTACT: Lauren Gamache at gsp@ustr.eop.gov, or 202-395-2974.
* SUPPLEMENTARY INFORMATION:
 
(I) 2018 Import Statistics Related to CNLs, De Minimis Waivers, and Product Redesignations
 
The GSP program provides for the duty-free treatment of designated articles when imported from designated beneficiary developing countries. The GSP program is authorized by Title V of the Trade Act of 1974, as amended (Trade Act) (19 U.S.C. 2461-2467), and is implemented in accordance with Executive Order 11888 of November 24, 1975, as modified by subsequent Executive Orders and Presidential Proclamations.
  USTR posted the 2018 import statistics relating to CNLs, de minimis waivers, and product redesignations on the USTR website here. These statistics include four lists.
   I. List I identifies GSP-eligible articles from BDCs that exceeded a CNL by having been imported into the United States in 2018 in excess of $185 million, or in a quantity equal to or greater than 50 percent of the total U.S. import value for this product in 2018. Unless the President grants a waiver in response to a petition filed by an interested party, these products will be removed from GSP eligibility on November 1, 2019.
   II. List II identifies GSP-eligible articles from BDCs that are above the 50 percent CNL but that are eligible for a de minimis waiver since total U.S. imports of the product are less than $24 million. Articles eligible for de minimis waivers automatically are considered in the GSP annual review process without the filing of a petition. As described below, USTR will only accept petitions in opposition to a potential de minimis waiver for a particular product.
  III. List III identifies GSP-eligible articles from certain BDCs that currently are not receiving GSP duty-free treatment but may be considered for GSP redesignation based on 2018 trade data and consideration of certain statutory factors. Note that products exceeding the 50 percent CNL may be considered for redesignation if there was no U.S. production of a like or directly competitive product in the last three years.
  IV. List IV identifies GSP-eligible articles from BDCs that
currently have a CNL waiver but have exceeded 150 percent of the CNL
threshold. Unless the President grants a continuation of the waiver in
response to a petition filed by an interested party, these products
will be removed from GSP eligibility on November 1, 2019.
 
(II) 2019 Annual GSP Review
 
(A) Country Practice Review Petitions
 
An interested party may submit a petition to review the GSP
eligibility of any beneficiary developing country with respect to any
of the designation criteria listed in sections 502(b) and 502(c) of the
Trade Act (19 U.S.C. 2462(b) and (c)).
 
(B) GSP Product Review Petitions
 
An interested party may submit the following petitions:
  – Product addition petitions: …
  – Product withdrawal petitions: …
  – Competitive need limitation waiver petitions: …
  – Petitions for denial of de minimis waivers: …
  – Petitions for redesignation: …
  – Petitions for continuation of CNL waiver: …
 
(III) Requirements for Submissions
 
(A) General Requirements …
 
(B) Business Confidential Petitions …
 
(C) Public Viewing of Review Submissions …
 

Erland Herfindahl, Deputy Assistant U.S. Trade Representative for the Generalized System of Preferences Office of the U.S. Trade Representative. 

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

EXIM_a3
3.
USTR Grants Additional Exclusion Requests as Part of Section 301 Investigation Concerning China
(Source:
Federal Register, 25 Mar 2019.) [Excerpts.]

 
84 FR 11152-11157: Notice of Product Exclusions: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation
 
* AGENCY: Office of the United States Trade Representative.
* ACTION: Notice of product exclusions.
* SUMMARY: Effective July 6, 2018, the U.S. Trade Representative (Trade Representative) imposed additional duties on goods of China with an annual trade value of approximately $34 billion (the $34 billion action) 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 Trade Representative’s determination included a decision to establish a product exclusion process. The Trade Representative initiated the exclusion process in July 2018, and stakeholders have submitted requests for the exclusion of specific products. In December 2018, the Trade Representative granted an initial set of exclusion requests. This notice announces the Trade Representative’s determination to grant additional exclusion requests, as specified in the Annex to this notice. The Trade Representative will continue to issue decisions on pending requests on a periodic basis.
* DATES: The product exclusions announced in this notice will apply as of the July 6, 2018 effective date of the $34 billion action, and will extend for one year after the publication of this notice. U.S. Customs and Border Protection will issue instructions on entry guidance and implementation.
* FOR FURTHER INFORMATION CONTACT: For general questions about this notice, contact Assistant General Counsels Philip Butler or Megan Grimball, or Director of Industrial Goods Justin Hoffmann at (202) 395-5725. For specific questions on customs classification or implementation of the product exclusions identified in the Annex to this notice, contact traderemedy@cbp.dhs.gov.
* SUPPLEMENTARY INFORMATION: … Effective July 6, 2018, the Trade Representative imposed additional
25 percent duties on goods of China classified in 818 8-digit subheadings of the Harmonized Tariff Schedule of the United States (HTSUS), with an approximate annual trade value of $34 billion. See 83 FR 28710. The Trade Representative’s determination included a decision to establish a process by which U.S. stakeholders may request exclusion of particular products classified within an 8-digit HTSUS subheading covered by the $34 billion action from the additional duties. The Trade Representative issued a notice setting out the process for the product exclusions, and opening a public docket. See 83 FR 32181 (the July 11 notice).
   Under the July 11 notice, requests for exclusion had to identify the product subject to the request in terms of the physical characteristics that distinguish the product from other products within the relevant 8-digit subheading covered by the $34 billion action. Requestors also had to provide the 10-digit subheading of the HTSUS most applicable to the particular product requested for exclusion, and could submit information on the ability of U.S. Customs and Border Protection to administer the requested exclusion. Requestors had to provide the quantity and value of the Chinese-origin product that the requestor purchased in the last three years. With regard to the rationale for the requested exclusion, requests had to address the following factors:
   – Whether the particular product only is available from China and specifically whether the particular product and/or a comparable product is available from sources in the United States and/or third countries.
  – Whether the imposition of additional duties on the particular product would cause severe economic harm to the requestor or other U.S. interests.
  – Whether the particular product is strategically important or related to “Made in China 2025” or other Chinese industrial programs.
 
The July 11 notice stated that the Trade Representative would take into account whether an exclusion would undermine the objective of the Section 301 investigation.
   The July 11 notice required submission of requests for exclusion from the $34 billion action no later than October 9, 2018, and noted that the Trade Representative would periodically announce decisions. In December 2018, the Trade Representative granted an initial set of exclusion requests. See 83 FR 67463. The Trade Representative regularly updates the status of each pending request and posts the status at https://ustr.gov/issue-areas/enforcement/section-301-investigations/request-exclusion.
 
(B) Determination To Grant Certain Exclusions
 
Based on the evaluation of the factors set out in the July 11 notice, which are summarized above, pursuant to sections 301(b), 301(c), and 307(a) of the Trade Act of 1974, as amended, and in accordance with the advice of the interagency Section 301 Committee, the Trade Representative has determined to grant the product exclusions set out in the Annex to this notice. The Trade Representative’s determination also takes into account advice from advisory committees and any public comments on the pertinent exclusion requests.
   As set out in the Annex to this notice, the exclusions are established in two different formats: (1) As an exclusion of an existing 10-digit subheading from within an 8-digit subheading covered by the $34 billion action, or (2) as an exclusion reflected in specially prepared product descriptions. In particular, the exclusions take the form of three 10-digit HTSUS subheadings, and 30 specially prepared product descriptions.
   In accordance with the July 11 notice, the exclusions are available for any product that meets the description in the Annex, regardless of whether the importer filed an exclusion request. Further, the scope of each exclusion is governed by the scope of the 10-digit headings and product descriptions in the Annex to this notice, and not by the product descriptions set out in any particular request for exclusion.
   The exclusions in the Annex cover approximately 87 separate
exclusion requests: The excluded 10-digit subheadings cover 24 separate requests, and the 30 specially drafted product descriptions cover approximately 63 separate requests.
   Paragraph B of the Annex to this notice corrects a typographical error in U.S. note 20(h)(ix) to subchapter III of chapter 99 of the Harmonized Tariff Schedule of the United States, as set out in the Annex of the notice published at 83 FR 67463 (December 28, 2018).
   As stated in July 11 Notice, the exclusions will apply as of the July 6, 2018 effective date of the $34 billion action, and extend for one year after the publication of this notice. U.S. Customs and Border Protection will issue instructions on entry guidance and implementation.
   The Trade Representative will continue to issue determinations on pending requests on a periodic basis.
 
Stephen P. Vaughn, General Counsel, Office of the U.S. Trade Representative.

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OGSOTHER GOVERNMENT SOURCES

OGS_a14. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

 
[No items of interest noted today.]
* * * * * * * * * * * * * * * * * * * * 

OGS_a2
5.
Commerce/BIS (No new Postings.)

(Source:
Commerce/BIS)

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OGS_a36.
DHS/ICE Removes Iranian Man Convicted of Violating IEEPA

(Source:
DHS/ICE
, 22 Mar 2019.)
 
On Thursday, March 21, U.S. Immigration and Customs Enforcement’s (ICE) Enforcement and Removal Operations (ERO) officers removed a Iranian citizen convicted in U.S. District Court for the Southern District of Florida (SDFL) of conspiracy to violate the International Emergency Economic Powers Act (IEEPA) for illegally exporting aviation parts and equipment to Syria without obtaining a license or authorization, following an investigation by ICE’s Homeland Security Investigations (HSI), FBI, Department of Commerce, the Defense Criminal Investigative Service, U.S. Customs and Border Protection, and the South Florida Joint Terrorism Task Force.
 
Ali Caby, aka “Alex Caby”, 41, entered the United States on an unknown date and at an unknown location without admission or parole by an immigration officer.
 
On Dec. 19, 2017,
SDFL convicted Ali Caby of conspiracy to violate IEPPA and to defraud the United States. SDFL sentenced him to 24 months in prison, followed by two years of supervised release. Co-defendant Arash Caby, aka “Axel Caby”, 43, was sentenced to 24 months in prison, followed by two years of supervised release and a $10,000 fine. Co-defendant Marjan Caby, 34, was sentenced to 12 months and one day in prison, followed by two years of supervised release. The defendants had previously pled guilty to the charged conspiracy to violate IEEPA by exporting dual-use goods, that is, articles that have both civilian and military application, without a license to Syrian Air, the Syrian government’s airline, which is an entity designated and blocked by OFAC for transporting weapons and ammunition to Syria in conjunction with Hizballah, a terrorist organization, and the Iranian Revolutionary Guard Corps (IRGC).
 
Ali Caby ran the Bulgaria office of AW-Tronics, a Miami export company that was managed by Arash Caby, which shipped and exported various aircraft parts and equipment to Syrian Arab Airlines. Ali Caby and Arash Caby closely supervised and encouraged subordinate employees of AW-Tronics in the willful exportation of the parts and equipment to SDN Syrian Air, whose activities have assisted the Syrian government’s violent crackdown on its people. Marjan Caby, as AW-Tronics’ export compliance officer and auditor, facilitated these exports by submitting false and misleading electronic export information to federal agencies.  . . .
 
On Jan. 15, 2019, an immigration judge ordered Ali Caby removed from the United States to Bulgaria, or Iran as an alternative. Caby is a citizen of Iran with lawful permanent resident status in Bulgaria.  
On Friday, March 22, Ali Caby was turned over to Bulgarian authorities without incident.

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OGS_a47.
State/DDTC Seeks Attorney Candidates

(Source:
State/DDTC, 25 Mar 2019.)
 
The Office of the Legal Adviser of the Department of State seeks attorneys with at least 3 years of relevant experience to provide counsel to the Bureau of Political-Military Affairs Directorate of Defense Trade Controls (DDTC), handling issues related to export controls and administrative law.  This advertisement is for two non-rotational specialist positions within the Office of the Legal Adviser.  Salary: GS Level 12-15, commensurate with experience. Applicant must be a U.S. citizen, and have a J.D. degree.
 
Applicants should have significant legal experience in the area of export control law, including with the Arms Export Control Act and International Traffic in Arms Regulations, and/or significant legal experience in administrative law, including the promulgation and civil and/or criminal enforcement of federal regulations.  Applicants must have an outstanding record of academic and professional achievement.  They must be able to handle a wide variety of assignments with short, time-critical deadlines, as well as design and execute substantial analytical projects.  They must also possess exceptional analytical, writing, organizational, and interpersonal communications skills, suitable for successfully working with policy makers and senior-level officials as well as licensing officers and compliance personnel.
 
Preferred:

  – At least 3 years of relevant experience.  Ideally 5+.


  – Experience and ability to work in a regulatory environment is key (e.g. knowledge of administrative law, self-starter, limited support).
  – Experience with enforcement/criminal law.
 
Ability to obtain security clearance is required. Applicants should send a current detailed resume, law school transcript, and reference information by email to the attention of Barbara Barrett Spencer at
legaljobs@state.gov. Applications must be received by Friday, April 19, 2019.

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OGS_a58.
Treasury/OFAC Publishes Updated Advisory Highlighting Risks for Maritime Petroleum Shipping Community in Syria

(Source:
Treasury/OFAC, 25 Mar 2019.)
 
Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated its Advisory to the Maritime Petroleum Shipping Community to highlight risks associated with shipments to Syria.  This advisory updates Treasury’s November 20, 2018 Advisory to include additional guidelines and risks associated with facilitating the shipment of petroleum destined for Syrian Government-owned and -operated ports, to include petroleum of Iranian origin.  It adds dozens of new vessels involved in illicit oil shipments, including 16 shipping to Syria and more than 30 engaging in ship-to-ship transfers, and highlights concerns with shipments of petroleum from Iran.
 
  “Treasury has previously exposed a far-reaching oil for terror network involving Iran and Syria, and continues to target ships and companies facilitating illicit trade.  The United States has made it clear to the maritime shipping community that we will not tolerate the use of petroleum as a mechanism to finance rogue regimes in Iran and Syria.  As Iran and Syria attempt to adapt their illicit tactics and shift to new vessels, we will continue to provide these updates to the shipping community,” said Under Secretary for Terrorism and Financial Intelligence, Sigal Mandelker.  “Shipping companies, insurers, vessel owners, managers, and operators must aggressively counter the ongoing deceptive shipping practices deployed by Iran and Syria and other questionable jurisdictions.  Any violations of prohibitions or weaknesses in compliance that result in sanctionable conduct exposes the shipping community to significant risks and can trigger severe consequences.”
 
The new iteration of the Advisory includes major updates to its annex, which lists vessels that have delivered petroleum to Syria since 2016.  The annex also includes vessels that have engaged in ship-to-ship (STS) transfers of petroleum likely destined for Syria, as well as vessels which have exported Syrian petroleum.  Many of the names of the vessels have also been updated to reflect name changes.
 
  – View Updated
Syria Advisory to the Maritime Petroleum Shipping Community

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OGS_a69.
EU Commission’s Directorate-General Trade Publishes Notice Concerning Dual-Use Export Control Regulations Related to UK


 
The United Kingdom submitted on 29 March 2017 the notification of its intention to withdraw from the Union pursuant to Article 50 of the Treaty on European Union. This means that as from 30 March 2019, 00:00h (CET) (‘the withdrawal date’) [FN/1] the United Kingdom will be a ‘third country’. [FN/2] Preparing for the withdrawal is not just a matter for EU and national authorities but also for private parties. In view of the uncertainties surrounding the ratification of the Withdrawal Agreement, all interested parties, and especially economic operators, are reminded of legal repercussions, which need to be considered when the United Kingdom becomes a third country. Subject to the transition period provided for in the Withdrawal Agreement, [FN/3] as of the withdrawal date, the EU rules on dual-use export controls, and in particular, Regulation (EC) No 428/2009 setting up a Community regime for the control of exports, transfer, brokering and transit of dual-use items [FN/4] (the “Regulation”) will no longer apply to the United Kingdom. This has in particular the following consequences
 
(1) Dual-Use Exports to The United Kingdom
 
The Regulation provides for the control of the export, brokering and transit of dual-use items. As of the withdrawal date, controls under the Regulation will apply in relation to the United Kingdom as third country
 
(2) Export Licenses Issued by The United Kingdom as an EU Member State
 
As of the withdrawal date, export licenses issued by the United Kingdom as an EU Member State under the Regulation are no longer valid for exports of dual-use items from the EU-27 to third countries. [FN/7] Rather, such exports of dual-use items from the EU-27 to third countries are going to require, as of the withdrawal date, a license issued by a competent authority of one of the EU-27 Member States, in accordance with Article 9 of the Regulation.
 
(3) Intra-EU Transfer Licenses To The United Kingdom Issued Before The Withdrawal Date
 
According to Article 22 of the Regulation, certain very sensitive dual-use items, listed in Annex IV to the Regulation, are subject to intra-EU transfer controls. As of the withdrawal date, the export of these items will be subject to authorization under the terms and conditions of the Regulation. However, intra-EU transfer licenses issued by one of the EU27 Member States for transfers to the United Kingdom issued before the withdrawal date should be considered as valid licenses for exports to the United Kingdom as of the withdrawal date, and until the validity of the license expires. The website of the Commission (
here) provides general information concerning dual-use export control. These pages will be updated with further information, where necessary.
 
  European Commission
  Directorate-General Trade
 
Please note: Considering that the United Kingdom is a party to relevant international treaties and a member of international non-proliferation regimes, and applies proportionate and adequate controls, the European Commission adopted on 19 December 2018 a proposal for an amendment to the Regulation adding the United Kingdom to the list of destinations covered by EU General Authorization (EU001). [FN/6] The proposal, once adopted by the co-legislators, will simplify exports of most dual-use items to the United Kingdom, while ensuring a uniform and consistent application of controls throughout the EU and preserving international and EU security.
 
———-
  [FN/1] In accordance with Article 50(3) of the Treaty on European Union, the European Council, in agreement with the United Kingdom, may unanimously decide that the Treaties cease to apply at a later date.
  [FN/2] A third country is a country not member of the EU.
  [FN/3] Cf. Part four of the Agreement on the withdrawal of the United Kingdom of Great Britain and Northern Ireland from the European Union and the European Atomic Energy Community (OJ, C 66 I, 19.2.2019, p. 1).
  [FN/4] OJ L 134, 29.5.2009, p. 1.
  [FN/5] This notice complements the “Notice to stakeholders – Withdrawal of the United Kingdom and EU rules in the field of import/export licenses for certain goods” of 25 January 2018
  [FN/6] COM (2018) 891 final.
  [FN/7] See also section 2 of the “Notice to stakeholders -Withdrawal of the United Kingdom and EU rules in the field of import/export licenses for certain goods” of 25 January 2018.


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OGS_a710.
UK OFSI Publishes Concerning Chemical Weapons Sanctions Guidance in Case of No-Deal Brexit

(Source:
UK OFSI, 25 Mar 2019.)


 
The UK Office of Financial Sanctions Implementation (OFSI) published guidance on the UK’s sanctions regime on chemical weapons, if the UK leaves the EU without a deal.
 

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NWSNEWS

NWS_a1
11.
Expeditors News: “European Council Extends the UK Withdrawal from the EU”
(Source:
Expeditors News, 21 Mar 2019.)
 
On March 21, 2019, the European Council agreed to an extension on the United Kingdom (UK) withdrawing from the European Union (EU).
 
The European Council extended the withdrawal date to April 12, 2019, unless the UK’s House of Commons approves the withdrawal agreement by next week. In that instance, the European Council has agreed to an extension until May 22, 2019.
 
The European Council’s press release may be found
here.

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

NWS_a1
12.
Human Rights Watch: “Why Germany Shouldn’t Yield on Arms Sales to the Saudis”
(Source:
Human Rights Watch, 25 Mar 2019.) [Excerpts.]
 
On the fourth anniversary of the war in Yemen, Germany has come under pressure from the French and British governments to resume its arms sales to Saudi Arabia. But Germany’s arms embargo is the right decision, and the countries still selling weapons to Saudi Arabia should follow suit.
 
For EU member states, a decision about arms sales to Saudi Arabia should be about complying with an EU Common Position adopted in 2008, which states that there should be no arms exports if there is a “clear risk” that such weapons will be used to commit “serious violations of international humanitarian law.”
 
Human Rights Watch has documented dozens of Saudi and Emirati-led coalition attacks in Yemen in violation of the laws of war, many of which amount to war crimes. Scores of indiscriminate and disproportionate airstrikes have killed and wounded thousands of civilians, including many children, and hit civilian areas, including markets, homes, schools and hospitals. …

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NWS_a3
13.
Llyod’s List: “Polish Register Defies U.S. Sanctions to Class Iranian Tankers”
(Source:
Llyod’s List, 22 Mar 2019.) [Excerpts.]
 
Most maritime service providers have distanced themselves from sanctioned Iranian companies, fearing secondary US sanctions could impede their ability to conduct business in US dollars.
 
Polish class society takes in US-sanctioned NITC tankers, arguing that political goals should not compromise maritime safety and environmental protection.
 
The Polish Register of Shipping has defied the US to class six Iranian tankers, saying the decision by the White House administration to sanction the vessels compromises international maritime safety and the marine environment. …

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NWS_a4
14.
Sputnik News: “NASA Mysteriously Digitally Alters Pictures of NASA’s Space Launch System”
(Source:
Sputnik News, 24 Mar 2019.) [Excerpts.]
 
NASA’s Space Launch System (SLS) super heavy rocket program, under development by Boeing since 2011, is already nearly two years behind schedule, with the space agency concerned that it may have to consider the use of commercial rockets for an important series of Moon missions in the coming decade if the new rocket isn’t created in time.
 
NASA has mysteriously decided to digitally alter some pictures of SLS system components, independent space news website NASA Watch has discovered.
 …
 
More concerning to the site than the blurring was the fact that some images of the component were altered, while others weren’t. When one user suggested that the blurring was a “pretty common” measure to prevent the leak of defence and military-related technologies known as International Traffic in Arms Regulations (ITAR) compliance, NASA Watch pointed out that if that were the case, all of the photos should have been blurred. …

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COMMCOMMENTARY

COM_a1
15.
A.H. Linning, S.J. Harris & Z.A. Keane: “Implementation of United Nations Security Council Sanctions by the Hong Kong Authorities”

(Source:
Mayer Brown, 25 Mar 2019.)
 
* Authors: Alan H. Linning, Esq.,
alan.linning@mayerbrown.com, +852 2843 2231; Susanne J. Harris, Esq.,
susanne.harris@mayerbrown.com, +852 2843 4522; and Zoe A. Keane, Esq.,
zoe.keane@mayerbrown.com, +852 2843 4229. All of Mayer Brown LLP.
 
The Hong Kong government, via Acting Secretary for Commerce and Economic Development Dr Bernard Chan and in response to a query from lawmaker, the Hon. Kenneth Leung, issued a press release on 23 January 2019, publishing figures on the number of sanctions investigations and related enforcement actions undertaken by the Hong Kong government on potential breaches of United Nations Security Council (UNSC) sanctions over the past five years, as well as detailing staffing levels dedicated to such investigations.
 
The press release confirms that the governmental departments enforcing the United Nations Sanctions Ordinance (Cap 537) (the “Ordinance”), comprise i) the Hong Kong Police Force (HKPF) and ii) the Customs and Excise Department (C&ED”). It states the workload of 69 staff in HKPF and 47 staff in C&ED includes enforcement review and action arising out of the Ordinance. A more detailed breakdown of manpower for each duty concerned was not available, however.
 
In terms of the investigation’s figures, investigations by HKPF are confirmed to be up from three in 2014 to 201 in 2018, and those by the C&ED increased from 10 to 99 during the same period. Whilst there has been a clear rise in the number of sanctions investigations, the figures do not explain why there has been such an increase in investigations. The press release also confirms that there have no prosecution cases brought under the Ordinance to date.
 
Notwithstanding the lack of prosecutions, the press release confirms that ‘
Hong Kong has a robust system to implement sanctions imposed by the UNSC‘and that the agencies’ investigation efforts act as a deterrent to potential violators. In that regard, the press release notes that a number of Hong Kong-registered companies have been struck off and certain vessels have been denied entry into Hong Kong waters, and that these actions are deterrents to those considering using Hong Kong as a base to violate UNSC sanctions. The press release also confirms the agencies actively investigate all suspected violations of UNSC sanctions, following up ‘
without fear or favour‘ and would institute prosecution where there were sufficient evidence.
 
The press release stresses that it is the Hong Kong government’s job to uphold the sanctions imposed by UNSC, namely in respect of the 14 places and two organisations as denoted by the UNSC, and flagged that, whilst countries are able to impose unilateral sanctions against certain places, the Hong Kong government ‘
does not have the responsibility nor the authority to enforce these unilateral sanctions or investigate related cases‘ [FN/1].
 
These comments are particularly pertinent in light of the recent arrest of Huawei’s Chief Financial Officer Sabrina Meng Wanzhou at the request of US authorities on allegations of the company’s dealings with UNSC-sanctioned Iran, through a Hong Kong shell company. Hong Kong’s Deputy Secretary of Commerce and Economic Development Bureau Vivian Sum Fong-Kwang recently told legislators that ‘
Hong Kong is not obliged to enforce sanctions imposed by the United States‘, and ‘
the city government would only act on sanctions ordered by the UN Security Council, and would not enforce unilateral sanctions by individual jurisdictions, including the US or the European Union [FN/2]’. It is not yet clear whether the allegations against Meng Wanzhou and Huawei could fall under the UNSC restrictions.
 
Additional sanctions-related media coverage for the Hong Kong government came in the form of a Hong Kong-registered vessel having been detained by South Korean authorities in November 2017 for alleged transfer of oil to the Democratic People’s Republic of Korea, also subject to the UNSC-sanctions regime. The case is now the subject of judicial review proceedings, due to be heard in early 2019. [FN/3]
 
Evidently there has been an increasing effort by the Hong Kong government to tackle potential breaches of UNSC sanctions over the past five years. Given the increased focus on sanctions enforcement, both at home and internationally, and particularly in light of the ongoing case involving Huawei, there will no doubt continue to be increased scrutiny on the Hong Kong government’s actions in the sanctions space. It is likely the government will continue to increase its efforts in deploying deterrent tactics and strengthening its enforcement capabilities and, given the number of UNSC sanctions investigations has been significantly trending upwards, Hong Kong could at some point also see the first prosecution case brought under the Ordinance.
 
—————
  [FN/1]
here.
  [FN/2]
here.
  [FN/3]
here.

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

(Source:
Michael Kyprianou & Co LLC
, 24 Jan 2019.)
* Author: Pariana Demetriou, Associate, Michael Kyprianou & Co. LLC, 
pariana.demetriou@kyprianou.com.
 
“Sanctions”, or “Restrictive Measures”, are imposed on natural and legal persons in order to prevent and limit violation of International Law, human rights and politics.
 
The Republic of Cyprus, as a member of the United Nations (UN) and the European Union (EU) has the obligation to implement and enforce:
  – The International Sanctions issued via a relevant Resolution or Decision adopted by the Security Council of the UN under Chapter VII of the Charter of the United Nations; and
  – The Restrictive Measures adopted by the Council of the EU via relevant Decisions and Regulations, within the framework of the Common Foreign and Security Policy.
 
Article 215 of the Treaty on the Functioning of the EU allows the European Council to adopt Restrictive Measures against natural or legal persons and groups or non-State entities. The Decisions and Regulations of the Council of the EU constitute in their entirety part of EU Law and therefore, supersede the national legislation of EU member states such as Cyprus.
 
Article 41 of the UN Charter allows the Security Council of the UN to issue sanctions, such as complete or partial interruption of economic relations and means of communications, and severance of diplomatic relations. All Members of the UN must comply with these sanctions, according to Article 25 of the UN Charter. 
 
In 2016 the Cyprus Parliament enacted a legislation relating to the Implementation of the Decisions of the Security Council of the UN (Sanctions) and the Decisions and Regulations of the Council of the European Union (Restrictive Measures) Law of 2016 (58(I)/2016). The Law states the obligation of the Republic of Cyprus to enforce and implement UN Sanctions and EU Restrictive Measures. Further, the Law provides that any person who violates such sanctions or measures is guilty of an offence. The sentence of such conviction may either be imprisonment or a fine.
  – If a natural person, imprisonment for up to 2 years or fine up to €100.000 or both.
  – If legal entity, a fine of up to €300.000.
 
Consequently, both natural and legal persons in Cyprus must be aware of the UN and EU lists, and refrain from acting against the sanctions and measures imposed.
 
Apart from UN Sanctions and EU Restrictive Measures, Cyprus has no legal obligation to enforce or implement any other sanctions.
 
With regard to measures issued by the Office of Foreign Asset Control of the US Department of Treasury (OFAC) and the Financial Crimes Enforcement Network, it appears that bypassing these measures does not give rise to an apparent offence in Cyprus.
 

However, the need for compliance arises from the corresponding relationship between Cypriot financial institutions and financial institutions of the United States, as well as from the possible implications for Cypriot individuals and legal entities. Persons who override or assist in the override of such measures may find themselves included in restrictive measures issued by OFAC.

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

MSEX/IM MOVERS & SHAKERS

MS_a117. Monday List of Ex/Im Job Openings: 147 Openings Posted This Week, Including 15 New Openings

(Source: Events & Jobs Editor) 
 

Published every Monday or first business day of the week. Please, send job openings in the following format to 
jobs@fullcirclecompliance.eu
.

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

#
” New or amended listing this week

 

* Adient; Plymouth, MI;
Director Americas Regional Compliance
; Requisition ID: R-03478
*
 
AeroVironment; Simi Valley, CA; Trade Compliance Specialist II; Requisition ID: 333;

* Agility; Atlanta, GA; 
Export Compliance Administrator


Agility; Dallas, TX; 
Ocean Export Coordinator
;

*
Agility; Houston, TX; Ocean Export Team Leader;


#
* Airbus; Manching, Germany;
Export Compliance Officer (d/m/w)
; Requisition ID: 10434415 NK DE EXT 3
#
* Airbus; Marignane, France;
Customer Risk & Compliance Analyse
; Requisition ID: 10441677 FW EN EXT 3
#
* Airbus; Munich, Germany;
Internship within Legal & Compliance: Data Protection Mapping
; Requisition ID: 10436096 NK EN EXT 3

* Ajilon; High Point, NC; Director of Trade and Compliance (Supply Chain); Requisition ID: US_EN_7_849133_2637004

#
* Albemarle; Charlotte, NC or Amsterdam, the Netherlands;
International Trade Compliance Manager
; Requisition ID: REQ-5382

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

* Amgen; Breda, the Netherlands; 
Trade Compliance Manager
; Requisition ID: R-72350

*
 
Amazon Web Services; Seattle, WA; Trade Compliance Manager, Export Controls & Classification; Requisition ID: 787194;

* Analog Devices, Inc.; Singapore; 
Asia Trade Compliance Manager
; Requisition ID: 12456
* Ansys; Pittsburgh, PA;
Paralegal – Compliance and Trade Compliance
; Requisition ID: 7535

* Autodesk; San
Rafael, CA (SF Bay Area) or Portland, OR; 
Export Compliance Officer
; Requisition ID: 19WD31812
* Avalara; Seattle, WA or Toronto, Canada;
HS Classification Product Manager
#
* Axis Communications; Lund, Sweden;
Export Control Advisor – Operations
; Requisition ID: 2629

* BAE Systems; Minneapolis, MN; Export Compliance Officer/Empowered Official 


*
 
BAE Systems; Nashua, NH; 
Procurement Compliance
; Requisition ID: 44996BR

* BAE Systems; Poznan, Poland; 
Export Control Officer
; Requisition ID: 68780

*
 
BAE Systems; Sterling Heights, MI; 
Senior Procurement Compliance Analyst
; Requisition ID: 43034BR


*
 
Beiersdorf; Hamburg, Germany; International Trade Expert;

* Bell Flight; Fort Worth, TX;
Trade Classification Specialist I
; Requisition ID: 270536;

* Bloomberg; London, United Kingdom; 
Trade Compliance Specialist
; Requisition ID: 71755

* Boeing; Arlington or Fairfax, VA; Sr. Trade Control Specialist; Requisition ID: 1900034991

* Bosch USA; Owatonna, MN; Import/Export Compliance Analyst

* Bristol-Myers Squibb; New Brunswick, NJ; 
Director Global Customs & Trade
; Requisition ID: R1509390_EN

* Carnegie Mellon University; Pittsburgh, PA; Export Compliance Manager;

#
* Danaher – Beckman Coulter Diagnostics; Brea, CA;
Global Export Compliance Manager
; Requisition ID: BEC014282

* Danaher – VIQUA; Kitchener, Canada; 
Trade Compliance and Logistics Specialist
; Requisition ID: VIQ000105

* DB Schenker; Düsseldorf, Germany; Head of Ocean Freight Import; Requisition ID: 201811140002;

* DHL Express; Washington D.C.; 
VP of Customs & Export Controls Americas
; Requisition ID: req74765

* Eaton; Titchfield, United Kingdom; 
UK Export Licensing Officer
; Requisition ID: 056506


EDCO; Eindhoven, the Netherlands; Customs & Trade Compliance Coordinator

* Elbit Systems of America; Merrimack, NH; 
Licenses & Agreements Officer
; Requisition ID 2019-6948
* Element; Edinburgh, United Kingdom; 
Group Compliance and Communications Assistant
; Requisition ID: 2019-3094

* Engenium; Orlando, FL;
Import/Export Compliance Specialist 

*
 
Erickson Inc.; Portland or Central Point, OR; 
Import Specialist

Susan Colletto
; Requisition ID 927130;

* Ericsson; Mexico City, Mexico; Trade Compliance Operations 

* Esri; Redlands, CA; Export Compliance Specialist;

* European Central Bank; Frankfurt, Germany; 
Principal Supervisor (Enforcement & Sanctions)
; Requisition ID: 2019-035-EXT

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

* Expeditors; Sunnyvale, CA, USA; Customs Compliance Specialist;

* 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; multiple locations in the U.S.; 
Project Coordinator OCR EASE Global Trade Compliance
; Requisition ID: REQ11768
* FLIR; Richmond, BC, Canada; 
Global Trade Compliance – Site Trade Compliance Operations Leader
; Requisition ID: REQ11591

* Forcepoint; Herndon, Virginia; 
Sr. Trade Compliance Specialist
; Requisition ID: JR460234

* Fortive – Tektronix; Beaverton, OR; Chief Compliance Counsel;

* Fourstar Group USA; Milford, MA; 
Import Manager/Customs Compliance/Classification Specialist
;


GCP Applied Technologies; Cambridge, MA; 
Trade Compliance Manager

* General Atomics; San Diego, CA; 
Compliance Specialist
; Requisition ID: 22119BR

* General Atomics; San Diego, CA; 
Trade Compliance Classification Leader
; Requisition ID: 22671BR

* General Atomics; San Diego, CA; 
Export Controls Leader – Technology
; Requisition ID: 22644BR

* General Atomics; San Diego, CA; Import/Export Compliance Specialist; Requisition ID: 23069BR

* Gowan Company; Yuma, AZ; Global Import/Export Specialist 

* Gulfstream Aerospace; Savannah, GA;
Trade Compliance Project Manager Sr
; Requisition ID: 142611 

* Harley-Davidson; Milwaukee, WI; Logistics Lead – Trade Compliance; Requisition ID: 826 
* Henderson Group Unlimited, Inc; State Dept, DDTC; Washington, DC; 
Defense Trade Control Compliance Analyst
;
* Henderson Group Unlimited, Inc; State Dept, DDTC; Washington, DC; 
Commodities Jurisdiction Analyst
;

#
* Henkel; Rocky Hill, CT;
Global Trade Manager
; Requisition ID: 190001EB

* Honeywell; multiple locations, United States; Export Compliance Manager (North America); Requisition ID: HRD45798;
* Honeywell; Prague, Czech Republic; Export Compliance Officer; Requisition ID: req179383;

* Honeywell International Inc.; Sunnyvale, CA or Lincolnshire, IL; Sr. Import/Export Analyst; HRD32371
 

* Illumina; Great Abington, United Kingdom; 
Trade Compliance Manager
; Requisition ID: 16204-JOB 
* Illumina; San Diego, CA; 
Associate Director, Global Trade Compliance
; Requisition ID: 16094-JOB
* Illumina; Woodlands, Singapore; Manager, Trade Compliance; Requisition ID: 16361-JOB

*
 Infineon; El Segundo, CA; 
Manager, Export Control
; Requisition ID: 33841

* Infineon Technologies; Tijuana, Mexico; Import-Export Manager;

* Invista; Wichita, KS; 
International Trade Compliance Manager
; Requisition ID: 060999

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

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

*
 
Keeco Home; Hayward, CA; Director Customs and Compliance

* Kirkland’s; Brentwood, TN; 
Customs Compliance Program Manager
; Requisition ID: 2019-8158

#
* KPMG; Chicago, IL or New York, NY or Washington D.C.;
Export and Sanctions Compliance Manager
; Requisition ID: 41146

* Kubota; Grapevine, TX; 
Manager, Import & Export Compliance
; Requisition ID: 228

*
 
Leidos; Columbia, MD; International Trade Manager / Export Compliance; Req. ID: R-00005745;

* Leonardo DRS; Melbourne, FL; 
Senior Supply Chain Analyst – Small Business Compliance
; Requisition ID: 91669

* Lockheed Martin; Arlington, VA; International Licensing Analyst; Requisition ID: 468160BR;

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


*
 
Lockheed Martin; 
Grand Prairie, TX; 
International Trade Compliance Specialist / International Licensing Analyst
; Requisition ID: 469631BR

* Lockheed Martin; Orlando, FL; 
International Trade Compliance Specialist / International Licensing Analyst
; Requisition ID: 467458BR

* Lockheed Martin Missile and Fire Controls; Orlando, FL;
International Trade Compliance Staff
; Contact: Marjorie Alquist, +1 407-356-9061; Requisition ID: 473481BR
* Lockheed Martin Missile and Fire Controls; Orlando, FL or Dallas, TX;
International Trade Compliance Engineer Staff
; Contact: Brian Taylor, +1 407-356-3833; Requisition ID: 462509BR

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

#
* Masonite; Charlotte, NC;
Customs Compliance Specialist
; Requisition ID: 2019-16989

* Meggitt; Miami, FL; 
Trade Compliance Coordinator
; Requisition ID: 37514
* Meggitt; Rockmart, GA; 
Trade Compliance Coordinator
; Requisition ID: 37846

* Metso; Waukesha, WI or York, PA or Columbia, SC;
Logistics Trade Compliance Manager
; Requisition ID: 83793

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

*
 Newell Brands; Norwalk, CT; 
Manager of Trade Operations

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

#
* Northrop Grumman; Herndon, VA;
Principal International Trade Compliance Analyst Level 3 or 4
; Requisition ID: 19007160  

* Northrop Grumman; Rancho Bernardo, CA; Sr. Manager, International Trade Compliance; Contact: Fred Czarske at 310-332-7606, fred.czarske@ngc.com; Requisition ID: 19008010

* NXP Semiconductors; Eindhoven, The Netherlands; (Senior) Manager Customs Compliance; Requisition ID: R-10013630;


*
 
Palomar Products; Rancho Santa Margarita, CA; Contracts & Compliance Manager;

* PCC Forged Products – Wyman-Gordon; Houston, TX;
Division Trade Compliance Manager
; Requisition ID: 20961
* PerkinElmer; Shelton, CT or Boston, MA or Hopkinton, MA or Waltham, MA;
Senior Director Global Transportation and Logistics
; Requisition ID: JR-004907

#
* Philips; Best, the Netherlands;
Head of Trade Compliance
; Requisition ID: 308818

* Pinpoint Pharma; Lincolnshire,IL; Export Compliance Specialist; Requisition ID: 351;

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

*
 
Ralph Lauren; New York, NY; Director, Trade Compliance Analyst; Requisition ID: 5567761;

#
* Raytheon; Tuscon, AZ;
Manager Export-Import Control
; Requisition ID: 134614BR


* Raytheon; Tuscon, AZ;
Senior Export Licensing and Compliance Specialist
; Requisition ID: 135002BR;

* Raytheon; Tucson, AZ; 
Trade Compliance Empowered Official

ryan.murphy@raytheon.com
; Requisition ID: 
121105BR
;  

* ReNuke; Newport News, VA; 
Regulatory Compliance Analyst
; Requisition ID: 4001

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

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

*
 SABIC; Houston TX; 
Senior Analyst, Trade Compliance
;
Danielle.Cannata@sabic.com
; Requisition ID: 8411BR

* Scania; Sodertalje, Sweden; Export Control Officer; Requisition ID: 20190885

* Shell; Krakow, Poland; Trade Compliance Manager; Requisition ID: 100384BR;
* Siemens; München, Germany; Director (m/f) Compliance Audit – Export Controls and Customs (ECC); Requisition ID: 104465 

* Sierra Nevada Corporation; Arlington, VA;
International Trade Compliance Analyst II
; Requisition ID: R0007508
* Signify; Eindhoven or Amsterdam, the Netherlands;
Legal Export Control Officer
; Requisition ID: 289784
* Spirit AeroSystems Inc; Wichita, KS;
Import/Export Administration
; Requisition ID: 2019-3798
* StanleyBlack&Decker; Southington, CT; 
Trade Compliance Specialist/Analyst
; Requisition ID: 58390BR


TE Connectivity; El Cajon, CA or Middletown, PA; Licensing Specialisttbaker@te.com; Requisition 40514 

* Teledyne Semiconductors; Saint-Egrève/Grenoble, France; Trade Compliance Manager; Requisition ID: 2019-8459;

* Textron Aviation; Wichita, KS; 
Trade Compliance Analyst
; Requisition ID: 269127

#
* Thales; Stuttgart, Germany;
Trade Compliance Spezialist (M/W/D)
; Requisition ID: R0054290

* ThermoFisher Scientific; Monza, Italy; Trade Compliance Specialist – Pharma; Requisition ID: 88807BR

#
* ThermoFisher Scientific; Loughborough, United Kingdom;
Global Trade Compliance Manager
; Requisition ID: 90337BR

* Trek Bicycle; Waterloo, WI;
Trade Compliance Manager 

* U.S. Bureau of Industry and Security; Washington D.C.; Export Compliance Specialist; Requisition ID: BIS-OASEE-2019-0006
* U.S. Department of State; Washington D.C.; Compliance Specialist; Requisition ID: PM-2019-0011
* U.S. Department of State; Washington D.C.; Compliance Specialist; Requisition ID: PM-2019-0012

* U.S. Department of the Army – U.S. Army Security Assistance Command; Redstone Arsenal, AL; Security Assistance Policy Specialist; Requisition ID: 60590  
#
* United Technologies – Collins Aerospace; Danbury, CT;
Fall CO-OP, International Trade Compliance
; Requisition ID: 01295830

* United Technologies – Pratt & Whitney; East Hartford, CT; 
ITC Licensing Specialist
; Requisition ID: 01289652

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

* University of Michigan; Ann Arbor, MI;
Export Controls Research Compliance Specialist Associate
; Requisition ID: 169019

* University of Missouri; Columbia, MO; 
Compliance Manager
; Requisition ID: 29426

* Velocity Electronics; Austin, TX; 
Director of Global Trade Compliance 
* Veridos GmbH; München, Germany; 
Ausfuhrbeauftragter (Export Control Officer m/w/d
; Requisition ID: 1677

* Volt; Rogers, MN; Trade Compliance Specialist; Requisition ID: 167100
* VT iDirect; Herndon, VA;
 
Manager, Global Logistics
; Requisition ID: 2018R-3120-1;
 
psingh@idirect.net 
* Walt Disney; Kissimmee, FL; Export Compliance Analyst; Requisition ID: 634260BR

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

* Wellesley Asset Management; Wellesley, MA; Chief Compliance Officer;

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

* Xpand Group: Hong Kong, China; 
Compliance Analyst
; Requisition ID: G-REQ-00169936

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

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

TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a118. FCC to Provide Awareness Training on Export Controls & Compliance, 2 Apr at NAG, Delft, the Netherlands 

(Source: Editor) 
 
* What: Export Compliance Training, including the following topics:

  – Setting the Scene: International relations and developments in the export control arena.

  – Regulatory framework and basics of U.S. (ITAR/EAR) and EU / Dutch dual-use and military export controls

  – Tips for designing / enhancing an Internal Compliance Program (ICP).

* When: Tuesday, 2 Apr 2019, 9.30 am – 1.30 pm (CET)
* Where: Netherlands Aerospace Group (“NAG”), Molengraaffsingel 10, Delft, the Netherlands. 
* Sponsor: NAG and Full Circle Compliance (“FCC”)
* Instructors: Drs. Ghislaine C.Y. Gillessen RA & Drs. Vincent Goossen (both of FCC)

* Registration & Information: 
here
 or send an email to 
events@fullcirclecompliance.eu
.

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

ENEDITOR’S NOTES


Fanny Crosby (Frances Jane van Alstyne, née Crosby; 24 Mar 1820 – 12 Feb 1915; was an American mission worker, poet, lyricist, and composer. She is the most prolific hymnist in history, writing more than 8,000 hymns and gospel songs, despite being blind from shortly after birth.  Some of Crosby’s best-known songs include
“Pass Me Not, O Gentle Savior”, “Blessed Assurance”, “Jesus Is Tenderly Calling You Home”, “Praise Him, Praise Him”, “Rescue the Perishing”, and
“To God Be the Glory”. Some publishers were hesitant to have so many hymns by one person in their hymnals, so Crosby used nearly 200 different pseudonyms during her career.)
  – 
“It seemed intended by the blessed providence of God that I should be blind all my life, and I thank him for the dispensation. If perfect earthly sight were offered me tomorrow I would not accept it. I might not have sung hymns to the praise of God if I had been distracted by the beautiful and interesting things about me.”
 
*
Arturo Toscanini (25 Mar 1867 – 16 Jan 1957; was an Italian conductor. He was one of the most acclaimed musicians of the late 19th and of the 20th century, renowned for his intensity, his perfectionism, his ear for orchestral detail and sonority, his eidetic memory, and his absolute pitch. He was at various times the music director of La Scala in Milan, the Metropolitan Opera in New York, and the New York Philharmonic.)

  
– “Can’t you read? The score demands ‘con amore’, and what are you doing? You are playing it like married men!”
 
Monday is pun day:
* Did you hear about the guy who lost the left side of his body? He’s alright now.
* I did a theatrical performance on puns. It was a play on words.
* What does a clock do when it’s hungry? It goes back for seconds

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

EN_a320
. 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: 12 Mar 2019: 84 FR 8807-8809: Extension of Import Restrictions Imposed on Archaeological and Ecclesiastical Ethnological Material From Honduras
 

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: 14 Mar 2019: 84 FR 9239-9240: Bump-Stock-Type Devices 

 

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: 19 Mar 2019: 84 FR 9957-9959: Department of State 2019 Civil Monetary Penalties Inflationary Adjustment. 
  – The only available fully updated copy (latest edition: 19 Mar 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 Mar 2019: 84 FR: 9456-9458: List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List) 
  
* USITC HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA), 1 Jan 2019: 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: 7 Mar 2019: H
armonized System Update (HSU) 1903  
[contains 67 ABI records and 13 harmonized tariff records].

  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

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EN_a0321
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 7,000 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOE/NRC, DOJ/ATF, DoD/DSS, DoD/DTSA, FAR/DFARS, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations.  Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items.

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