19-0422 Monday “Daily Bugle'”

19-0422 Monday “Daily Bugle”

Monday, 22 April 2019

  1. State Seeks Comments Concerning Application for the Permanent Export, Temporary Export, Temporary Import, or Brokering of Defense Articles, Defense Services, and Related Technical Data 
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. Commerce/Census: “Tips on How to Resolve AES Response Messages”
  4. State/DDTC: (No new postings.)
  5. White House Decides Not to Reissue Waivers for Iran Oil Imports, Aims to “Bring Iran’s Oil Exports to Zero”
  6. Canadian Government Amends Export Control List
  1. France24: “France Under Pressure to Come Clean Over Arms Exports in Yemen War”
  2. South China Morning Post: “Science Body VKI Reassesses Its Ties to Chinese Developer Of ‘Guam Killer’ Hypersonic Missile”
  3. The Washington Post: “Microsoft Worked With a Chinese Military University on AI. Does That Make Sense?”
  1. D.H. Pearson, L. Caylor & J.B. Horwitz: “Canadians to Face U.S. Liability under Helms-Burton as of May 2, 2019”
  2. M. Volkov: “Episode 86 – Standard Chartered Bank Pays Over $1 Billion for Sanctions Violations”
  3. The FAQ of the Day: Jurisdiction and Classification Determinations
  1. Monday List of Ex/Im Job Openings: 150 Openings Posted This Week, Including 18 New Openings 
  1. FCC Presents “Designing an Internal Compliance Program for Export Controls & Sanctions”, 1 Oct in Bruchem, the Netherlands
  2. ICPA Presents “2019 EU Conference”, 15-17 May in London
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Latest Amendments: DHS/Customs (5 Apr 2019), DOC/EAR (11 Apr 2019), 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 Apr 2018), DOT/FACR/OFAC (15 Mar 2018), HTSUS (18 Apr 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


State Seeks Comments Concerning Application for the Permanent Export, Temporary Export, Temporary Import, or Brokering of Defense Articles, Defense Services, and Related Technical Data 

Federal Register, 19 Apr 2019.) [Excerpts.]
84 FR 16554-16555: 60-Day Notice of Proposed Information Collection: Application for the Permanent Export, Temporary Export, Temporary Import, or Brokering of Defense Articles, Defense Services, and Related Technical Data
* ACTION: Notice of request for public comment.
* SUMMARY: The Department of State is seeking Office of Management and Budget (OMB) approval for the information collection described below. In accordance with the Paperwork Reduction Act of 1995, we are requesting comments on this collection from all interested individuals and organizations. The purpose of this notice is to allow 60 days for public comment preceding submission of the collection to OMB.
* DATES: The Department will accept comments from the public up to June 18, 2019.
* ADDRESSES: You may submit comments by any of the following methods:
– Web: Persons with access to the internet may comment on
this notice by going to
www.Regulations.gov. You can search for the document by entering “Docket Number: DOS-2019-0005” in the Search field. Then click the “Comment Now” button and complete the comment form.
  – Regular Mail: Send written comments to: Directorate of Defense Trade Controls, Attn: Andrea Battista, 2401 E St. NW, Suite H-1205, Washington, DC 20522-0112
  You must include the subject (PRA 60 Day Comment), information collection title (Application for the Permanent Export, Temporary Export, Temporary Import, or Brokering of Defense Articles, Defense Services, and Related Technical Data), and OMB control number (1405-XXXX) in any correspondence.
* FOR FURTHER INFORMATION CONTACT: Direct requests for additional information regarding this collection to Andrea Battista, who may be reached at
BattistaAL@state.gov or 202-663-3136.
  – Title of Information Collection: Application for the Permanent Export, Temporary Export, Temporary Import, or Brokering of Defense Articles, Defense Services, and Related Technical Data.
  – OMB Control Number: 1405-XXXX.
  – Type of Request: New Collection.
  – Originating Office: Directorate of Defense Trade Controls (DDTC).
  – Form Number: DS-7788.
  – Respondents: Respondents are any person/s who engages in the United States in the business of exporting, temporarily importing, or brokering defense articles or defense services. …
  – Obligation to Respond: Required to Obtain or Retain a Benefit. …
Abstract of Proposed Collection
This information collection is pursuant to ITAR parts 120–130 which set forth DDTC’s licensing and agreements guidelines and requirements. This collection will make applicant submissions available via an online case management system. DDTC will utilize the collected information to fulfill its statutorily mandated function of reviewing and adjudicating requests to export or temporarily import defense articles, defense services, and related technical data. Upon approval and implementation of the DS-7788 (1405-XXXX), the Department will discontinue the use of the following forms and associated Information Collections as the DS-7788 consolidates the existing DDTC Licensing Forms into one single form; DSP-5 (1405-0003), DSP-61 (1405-0013), DSP-85 (1405-0022), DSP-73 (1405-0023), DSP-6, 62, & 74 (1405-0092), DS-6004 (1405-0173), DS-4294 (1405-0142), 1405-0093 (no form).
License and other authorization application submissions are made via a completed DS-7788, which may be accessed from DDTC’s website and submitted electronically.
Anthony M. Dearth, Chief of Staff, Directorate of Defense Trade Controls, U.S. Department of State.

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OGS_a12. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

[No items of interest noted today.]
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OGS_a34. Commerce/Census: “Tips on How to Resolve AES Response Messages”

census@subscriptions.census.gov, 22 Apr 2019.)
When a shipment is filed to the AES, a system response message is generated and indicates whether the shipment has been accepted or rejected. If the shipment is accepted, the AES filer receives an Internal Transaction Number (ITN) as confirmation. Though the shipment is accepted, the filer may still receive a Verify Message, Compliance Alert, Informational Message or Warning Message along with their ITN. However, if the shipment is rejected, a Fatal Error notification is received and must be corrected to receive a valid ITN.
To help you take the appropriate action for the different AES Response Messages, here are some tips on how to address the most frequent messages that were generated in AES for this month.
Response Code: 123
– Narrative: Conveyance Name Missing
– Severity: Fatal
– Reason: The Conveyance Name/Carrier Name is missing when the Mode of Transportation is one that requires the Conveyance Name/Carrier Name to be reported.
– Resolution: The name of the transport conveyance must be declared on an EEI for the major modes of transportation (i.e., vessel, air, rail, truck). For Vessel shipments, declare the name of the vessel; for Air, Rail, or Truck shipments declare the carrier name. 
Verify the Mode of Transportation and the Conveyance Name/Carrier Name, correct the shipment and resubmit.
Response Code: 8W1
– Narrative: Shipping Weight/Quantity 1 Out of Range
– Severity: Verify
– Reason: For the reported Schedule B/HTS Number, the Shipping Weight/Quantity (1) ratio is outside of the expected range.
– Resolution: For a particular Schedule B/HTS Number declared, the shipping weight divided by the first quantity should fall within a certain parameter based on historical statistical averages for that commodity. Ratios outside this pre-determined parameter might indicate either a keying error or misclassification of the product. 
Verify the Shipping Weight, Quantity 1 and Schedule B/HTS Number, correct the shipment and resubmit (if necessary). If the line item is verified correct as reported, no action is necessary.

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White House Decides Not to Reissue Waivers for Iran Oil Imports, Aims to “Bring Iran’s Oil Exports to Zero”
The White House, 21 Apr 2019.)
Statement from the Press Secretary on Cooperation between the United States, Saudi Arabia, and the United Arab Emirates on Energy and Iran Policies
President Donald J. Trump has decided not to reissue Significant Reduction Exceptions (SREs) when they expire in early May. This decision is intended to bring Iran’s oil exports to zero, denying the regime its principal source of revenue. The United States, Saudi Arabia, and the United Arab Emirates, three of the world’s great energy producers, along with our friends and allies, are committed to ensuring that global oil markets remain adequately supplied. We have agreed to take timely action to assure that global demand is met as all Iranian oil is removed from the market.
The Trump Administration and our allies are determined to sustain and expand the maximum economic pressure campaign against Iran to end the regime’s destabilizing activity threatening the United States, our partners and allies, and security in the Middle East. The President’s decision to eliminate all SREs follows the designation of the Islamic Revolutionary Guard Corps as a Foreign Terrorist Organization, demonstrating the United States commitment to disrupting Iran’s terror network and changing the regime’s malign behavior. We welcome the support of our friends and allies for this effort.

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OGS_a67. Canadian Government Amends Export Control List
Global Affairs Canada, 17 Apr 2019.)
On April 5, 2019, the Government of Canada finalized the regulatory process to amend the 
Export Control List. This amendment serves to add controls, clarify controls and remove controls over specific items as agreed upon in the various multilateral export control regimes.
The current December 2015 version of ”
A Guide To Canada’s Export Control List” remains in effect until May 16, 2019. On May 17, 2019, the December 2016 version of the ”
A Guide To Canada’s Export Control List” (
Guide) will formally come into effect. Exporters will be advised once the December 2016 version of the Guide becomes available on the Export Controls Division website.
The new version of the 
Guide will incorporate Canadian commitments and obligations to the various multilateral export control regimes up to December 31, 2016. A table identifying the date of Canadian commitments to each regime appears below.
Export Control Regime
Latest Controls Incorporated into ECL
Wassenaar Arrangement
December 2016
Nuclear Suppliers Group
June 2016
Missile Technology Control Regime
October 2016
Australia Group
June 2016
A brief overview of
key changes are provided on the Export Controls Division website.
The regulation and the Regulatory Impact Analysis Statement were published on the 
Canada Gazette website on April 17, 2019. Please contact the Export Controls Policy Division for more details.
If you have any questions, please contact us via e-mail at

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France24: “France Under Pressure to Come Clean Over Arms Exports in Yemen War”
France24, 20 Apr 2019.) [Excerpts.]
France’s lucrative arms exports to the Gulf came under renewed scrutiny this week following the release of a classified report showing that the Saudi-led coalition in Yemen has made much wider use of French arms than officials in Paris acknowledge.
On October 3, 2018, a day after journalist Jamal Khashoggi entered the Saudi consulate in Istanbul, never to be seen again, French President Emmanuel Macron received a highly classified intelligence note, detailing the position of French-made arms used by the Saudi-led coalition fighting a bloody war in Yemen. …
The sensitive issue has put France at odds with its key partner Germany, which imposed an embargo on arms exports to Riyadh in the wake of Khashoggi’s murder. The move sparked stinging criticism from Paris and London, with Macron accusing the German government of “demagoguery”.
In an
unusually strong-worded op-ed published on the website of Germany’s Federal Academy for Security Studies, Anne-Marie Descôtes, the French ambassador to Berlin, warned that the “unpredictability of German policy on arms export controls” carried “major consequences for [Franco-German] defense cooperation and the construction of European sovereignty”. …

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South China Morning Post, 22 Apr 2019.) [Excerpts.]
An aerospace institute in Brussels is investigating exchanges and collaboration between its scientists and a major Chinese defense contractor, but management at the Belgium-based non-profit did not reveal details.
Professor Herman Deconinck, deputy director of the von Karman Institute for Fluid Dynamics (VKI), said it was looking into staff members’ relations with China Aerospace Science and Industry Corporation (Casic), a state-owned developer of hypersonic weapons that include the DF-26 missile in service with the People’s Liberation Army. …
Casic is on a U.S. export control blacklist, but a German delegation with representatives from more than 40 space technology companies visited Beijing last month with a view to expanding their cooperation. …

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The Washington Post: “Microsoft Worked With a Chinese Military University on AI. Does That Make Sense?”
The Washington Post, 21 Apr 2019.) [Excerpts.]
Technology companies have been taking flak lately for collaborating with the U.S. military – but are they helping the Chinese government expand its surveillance state at the same time? The
revelation this month that Microsoft researchers collaborated with academics at a Chinese military-run university sparked outrage from China hawks. Careful consideration would be a more prudent response.
The Financial Times reported April 10 that specialists at Microsoft Research Asia published three papers over the past year with co-writers affiliated with China’s National University of Defense Technology, controlled by the country’s Central Military Commission. …
The Trump administration’s plan to restrict technological exports to China will almost certainly mean keeping some sensitive products and services away from that country, or at least imposing licensing rules. But it could also mean barring certain types of research. The Microsoft case is interesting because it falls in exactly the gray area officials will have to confront: The United States
benefits immensely from the open exchange of ideas in AI – including access to top talent found in the most prestigious Chinese universities. Stopping up that pipeline would be a mistake. But China is also an egregious human rights offender, and using AI research for military gains is at the
core of its stated strategy. …

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11. D.H. Pearson, L. Caylor & J.B. Horwitz: “Canadians to Face U.S. Liability under Helms-Burton as of May 2, 2019″

(Source: Bennett Jones, 17 Apr 2019.)
* Authors: Darrell H. Pearson, Esq.,
pearsond@bennettjones.com; Lincoln Caylor, Esq.,
caylorl@bennettjones.com; and Jessica B. Horwitz, Esq.,
horwitzj@bennettjones.com. All of Bennett Jones, Toronto.
In a reversal of long-standing U.S. policy, any person or entity with business operations or relationships in Cuba may soon face civil liability in the United States.
On April 17, 2019, the Trump administration announced that it would not extend the suspension of the right to bring an action under Title III of the
Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996, better known as the
Helms-Burton Act, beyond the end of the existing suspensions on May 1, 2019.
Following the expiry of the existing suspensions, any person who “traffics” in property that was confiscated by the Cuban government on or after January 1, 1959, may face liability for the full value of the confiscated property, in some cases times three. The definition of trafficking under Title III is very broad, and includes engaging in commercial activity using or otherwise benefitting from confiscated property; among other things, this could include using landing strips at airports, leasing hotels, and holding docking rights in ports. Actions under Title III of
Helms-Burton may be brought for two years after the trafficking giving rise to the action has ceased to occur.
High Potential for Recovery in U.S.
The right to bring an action under Title III of
Helms-Burton had been continuously suspended by U.S. Presidential administrations for successive six-month periods since 1996; the Trump administration began reducing the suspension periods in early 2019, with the latest suspension through May 1, 2019, being for only two weeks. Moreover, the most recent two suspensions included exceptions that allowed claims to proceed for the first time against certain entities, being those under the control of Cuban military, intelligence and security services on the U.S. State Department’s Cuba Restricted List.
Now that the general right to bring an action under Title III of
Helms-Burton will take effect as of May 2, 2019, much uncertainty lies ahead. While the boundaries of liability under
Helms-Burton remain to be determined by the courts, U.S. plaintiff law firms are likely to aggressively pursue these claims due to high potential recovery under the Act.
Canadian Protections Against Helms-Burton
Canadian law affords certain protections in response to
Helms-Burton. Under Canada’s
Foreign Extraterritorial Measures Act (
Helms-Burton judgments may not be recognized or enforced in Canadian courts. Moreover,
FEMA allows Canadians to counter-sue for losses sustained in relation to
Helms-Burton actions and judgments with the support of the Attorney General.
FEMA may also protect against disclosure of records in Canada for use in
Helms-Burton proceedings.
Canadians who have business operations in Cuba or relationships with Cuban entities should immediately contact Canadian legal counsel to assess their exposure and discuss strategies for mitigating potential liability.

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Volkov Law Group Blog, 21 Apr 2019. Reprinted by permission.)
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
Global banks are the poster children of sanctions violations and the importance of trade compliance. At the top of the heap is Standard Chartered Bank.
In a long-awaited resolution of a multi-year investigation, the Justice Department, the Treasury Department’s Office of Foreign Asset Control (OFAC), the New York District Attorney’s (DANY), the Federal Reserve, the New York State Department of Financial Services (DFS) and the United Kingdom’s Financial Conduct Authority (FCA) announced a number of settlement agreements in connection with SCB’s violations of Iran Sanctions Programs.
Under the agreements, SCB agreed with the:
  (1) Justice Department to forfeit $240 million, a fine of $480 million and to extend its existing deferred prosecution agreement (DPA) for an additional two years;
  (2) Department of Treasury’s Office of Foreign Asset Control (OFAC) to pay total penalties of $657 million; the Federal Reserve to pay penalties of $163 million; the New York Department of Financial Services to pay total penalties of $180 million; and the UK’s Financial Conduct Authority to pay total penalties of $133 million; and
  (3) New York District Attorney’s Office to pay a financial penalty of $292 million and extend its DPA with DA-NY for two years.
The Justice Department agreed to credit a portion of these payments and reduced its fine for SCB from $480 million to $52 million, along with the $240 million forfeiture.

In this episode, Mike Volkov reviews the Standard Chartered Bank enforcement action and the implications of the action.

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, 27 Apr 2018.)

Q: I am certain that my product is not subject to the ITAR because it is clearly not within the scope of any USML categories. I am, however, uncertain about which ECCN in the EAR”s CCL would apply to my product. Do I need to submit a CJ request to DDTC to get a determination that the product is not subject to the ITAR before I submit a classification request (a CCATS) to BIS asking for a determination regarding which ECCN applies to my product?
A: No. As described above, one may make jurisdictional and classification self-determinations. If there is doubt about the classification status (i.e., where it is controlled on the CCL) of an item that is clearly not within the scope of the USML, then one does not need to submit a CJ request to DDTC before submitting a classification request (a CCATS) to BIS.

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MS_a114. Monday List of Ex/Im Job Openings: 150 Openings Posted This Week, Including 18 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 


” New or amended listing this week


* Abbott; Alameda, CA; Customs, Trade and Compliance Analyst
* Abbott; Irving, TX; Customs and Trade Compliance Analyst

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

Agility; Houston, TX; Ocean Export Team Leader;

* Airbus; Blagnac, France; Internship Compliance et Export control; Requisition ID: 1819-X12

* Airbus; Getafe, Spain; Export Control Officer; Requisition ID: 10447448 XX EN EXT 1
* Airbus; Munich, Germany;
Internship within Legal & Compliance: Data Protection Mapping
; Requisition ID: 10436096 NK EN EXT 4
* Ajilon; Bedford Park, IL; Import / Export Logistics Coordinator; Requisition ID: US_EN_7_849116_2650289

Allnex; Drogenbos, Belgium; Head of Trade Compliance EMEA

AM General; Auburn Hills, MI; 
International Compliance Analyst

* American Showa, Inc.; Columbus, OH; Trade Compliance Specialist; LoAnn Burt  

* Ansys; Pittsburgh, PA;
Paralegal – Compliance and Trade Compliance
; Requisition ID: 7535

*Arrow Electronics; Arlington, TX or Centennial, CO or Phoenix, AZ or Reno, NV; Officer, Global Trade Management & Compliance; Requisition ID: R169517
* Arrow Electronics; Hong Kong, China; Global Trade Management & Compliance Officer; Requisition ID: R168802

* Autodesk; San
Rafael, CA (SF Bay Area) or Portland, OR; 
Export Compliance Officer
; Requisition ID: 19WD31812

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

* Bass Pro Shops; Springfield, MO; Global Trade Compliance Specialist; Requisition ID: R055089

Beiersdorf; Hamburg, Germany; International Trade Expert

Bell Flight; Fort Worth, TX; Trade Compliance Specialist; Requisition ID: 273691

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

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

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

* CACI International Inc.; Arlington, VA; Director, Trade Compliance; Requisition ID: 219396
* CACI International Inc.; Chantilly, VA; Director, Trade Compliance; Requisition ID: 

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

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

* Danaher – Leica Microsystems; Wetzlar, Germany; Trade Compliance Manager – EMEA (m/f/d); Requisition ID: LEI004901

* Dell; Bukit Mertajam, Malaysia; Analyst, Import/Export; Requisition ID: R60622

* Dell; Bukit Mertajam, Malaysia; Specialist, Import/Export; Requisition ID: R45267

* Dutch Ministry of Foreign Affairs/Ministerie van Buitenlandse Zaken; The Hague, the Netherlands; Stage bij Directoraat-Generaal Buitenlandse Economische Betrekkingen – afdeling Exportcontrole en Strategische Goederen

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

* Esri; Redlands, CA; Export Compliance Specialist

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

Five Below; Philadelphia, PA; Custom Trade & Compliance Analyst

* Flexport; Amsterdam, the Netherlands; Regional Compliance Manager

* FLIR; Arlington, VA, Elkridge, MD, and Nashua, NH;
Senior Manager, Global Export Licensing (Commercial); Requisition ID: REQ12110

* FLIR; several locations, Canada; Global Trade Compliance (GTC) Country Manager; Requisition ID: REQ12085

* 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: 22832BR

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

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

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

* Harley-Davidson; Milwaukee, WI; Logistics Lead – Trade Compliance; Requisition ID: 826  

Harris Corporation; Van Nuys, CA; Trade Compliance Senior Specialist; Richard Wellbrock; Requisition ID: ES20192103-30606

Harry Winston; New York, NY; Analyst, Logistics and Trade Compliance

HBM; Marlboro, MA; Export Compliance Manager

* 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; Prague, Czech Republic; Export Compliance Officer; Requisition ID: req179383

* IGT; Reno, NV; Global Trade Analyst; Requisition ID: 1171

* 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

* Infineum; Milton Hill, United Kingdom; Global Trade Compliance Project Advisor

IPG Photonics; Oxford, MA; 
Global Director Trade Compliance 
* Irving Shipbuilding; Halifax, NS, Canada; Manager, Export Compliance; Requisition ID: 19000058

* 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

Koch Chem Tech; Tulsa, OK; Import/Export Compliance Specialist; Requisition ID: 052017

* 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; Arlington, VA; Trade Compliance Import Manager; Requisition ID: 93515

* 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; Crystal City, VA; International Licensing Analyst Staff; Requisition ID: 465724BR

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

* Lockheed Martin; Stratford, CT; International Trade Compliance Authorization Owner; Requisition ID: 479245BR

* Lockheed Martin Aeronautics; Palmdale, CA; Export Compliance Site Lead; Requisition ID: 477630BR

* 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

* Mercury Systems; multiple locations; Trade Compliance Specialist; Requisition ID: 19-203

* Navigos Search; Ho Chi Minh City, Vietnam; Legal & Compliance Manager; Requisition ID: JO-1904-415857
* Netflix; Los Angeles, CA; Specialist, Trade Compliance

 Newell Brands; Norwalk, CT; 
Manager of Trade Operations 

* 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

* Pacific Northwest National Laboratory; Richland, WA; Export Control Professional; 509-375-4496; Requisition ID: 309048

* Parexel; Kiev, Ukraine; Trade Compliance Specialist; Requisition ID: 51579BR

* 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

* Project Alpha – Centre for Science and Security Studies KCL; London, United Kingdom; Internship Opportunity

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

* Raytheon; El Segundo, CA; Global Trade Authorization Owner; Requisition ID: 137660BR
* Raytheon; El Segundo & Goleta, CA; Global Trade Licensing Analyst I; Requisition ID: 136372BR
* Raytheon; El Segundo, CA; Global Trade Licensing Analyst II; Requisition ID: 136372BR

* Raytheon; El Segundo, CA; Import Ctl&Compliance Advisor; Requisition ID:136269BR

* Raytheon; El Segundo, CA/McKinney, TX/Rosslyn, VA; Senior Analyst Global Trade Management; Requisition ID: 136411BR
* Raytheon; El Segundo, CA/McKinney, TX; Senior Manager, Global Trade Strategy; Requisition ID: 135692BR
* Raytheon; McKinney, TX: Senior Analyst Global Trade Licensing; Requisition ID: 136939BR

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

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

* Repligen; Waltham, MA; Senior Manager, Global Trade Compliance

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

* Saab Defense and Security USA LLC; East Syracuse, NY;
Senior Import and Classifications Analyst 

 SABIC; Houston TX; 
Senior Analyst, Trade Compliance
; Requisition ID: 8411BR

* 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 I; Requisition ID: R0007830

* Sierra Nevada Corporation; Arlington, VA; International Trade Compliance Analyst I; Requisition ID: R0008020
* Sierra Nevada Corporation; Arlington, VA; International Trade Compliance Analyst I; Requisition ID: R0008021

* Sierra Nevada Corporation; Arlington, VA;
International Trade Compliance Analyst II
; Requisition ID: R0007508

* Sierra Nevada Corporation; Arlington, VA; International Trade Compliance Analyst II; Requisition ID: R0007996
Sierra Nevada Corporation; Arlington, VA / Sparks, NV / Centennial, CO; International Trade Compliance Manager II; Requisition ID: R0007901

* Signify; Eindhoven or Amsterdam, the Netherlands;  
Legal Export Control Officer
; Requisition ID: 289784

* Solenis; Wilmington, DE; Global Trade Compliance Specialist II; Requisition ID: R0002807

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

* Teledyne Technologies; Mountain View, CA;
Trade Compliance Import Administrator
Janice Whitaker; Requisition ID: 2019-9078   

* 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. 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 State/Directorate of Defense Trade Controls; Washington D.C.;  Attorney [Multiple positions]; legaljobs@state.gov

* U.S. Department of the Army – U.S. Army Security Assistance Command; Redstone Arsenal, AL; Security Assistance Policy Specialist; Requisition ID: 60590  

* 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

* UPS; Münchenstein, Switzerland; Customs & Trade Compliance Coordinator; Requisition ID: 052228

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

* Vigilant GTS; Remote Position, U.S.; Global Trade Compliance Account Manager

* VT iDirect; Herndon, VA;
Manager, Global Logistics
; Requisition ID: 2018R-3120-1;
* Walt Disney; Kissimmee, FL; Export Compliance Analyst; Requisition ID: 634260BR

* Walt Disney; Kissimmee, FL; Trade Compliance Analyst (Project Hire); Requisition ID: 654599BR

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

* 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  

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TE_a115. FCC Presents “Designing an Internal Compliance Program for Export Controls & Sanctions”, 1 Oct in Bruchem, the Netherlands

This training course is designed for compliance officers, managers, and other professionals who aim to enhance their organization’s compliance efforts. The course will cover multiple topics and tackle various key questions, including but not limited to:
– Setting the Scene: ensuring compliance in the export control and sanctions arena
– What is expected from your organization? A closer look at the official frameworks and guidelines from U.S. and European government agencies
– Key elements of an ICP
– Best practice tips for enhancing your current compliance efforts  
– Internal controls samples (policies, procedures, instructions)
– Strategic benefits of having an ICP.
* What: Designing an Internal Compliance Program for Export Controls & Sanctions”
* Date: Tuesday, 1 Oct 2019
* Location: Full Circle Compliance, Landgoed Groenhoven, Dorpsstraat 6, Bruchem, The Netherlands
* Times:
  – Registration and welcome: 9.00 am – 9.30 am
  – Training course hours: 9.30 am – 4.30 pm
* Level: Intermediate
* Target Audience:  the course provides valuable insights for both compliance professionals, employees and (senior / middle) management working in any industry subject to U.S. and/or EU (member state) export control laws and sanctions regulations.
* Instructors: Drs. Ghislaine C.Y. Gillessen RA (Managing Director) and Marco M. Crombach MSc (Senior Manager).
* Information & Registration: click
here or contact us at 
events@fullcirclecompliance.eu or 31 (0)23 – 844 – 9046.  

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ICPA Presents “2019 EU Conference”, 15-17 May in London

* What: 2019 EU Conference
  – Import and Export Track (click
here for the agenda)
Professional Speakers
   – Hot Industry Topics
* When: 15-17 May 2019
* Where:
The Tower Hotel, London, United Kingdom.
* Sponsor: International Compliance Professionals Association (ICPA)
* Information & Registration: Click

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Charlotte Bronte (21 Apr 1816 – 31 Mar 1855; was an English novelist and poet, the eldest of the three Brontë sisters who survived into adulthood and whose novels became classics of English literature.)

– “Life is so constructed, that the event does not, cannot, will not, match the expectation.”

Henry Fielding (22 Apr 1707 – 8 Oct 1754; was an English novelist and dramatist known for his rich, earthy humor and satirical prowess, and as the author of the picaresque novel 
Tom Jones. Additionally, he holds a significant place in the history of law enforcement, having used his authority as a magistrate to found (with his half-brother John) what some have called London’s first police force, the Bow Street Runners.)

  – “There is perhaps no surer mark of folly than to attempt to correct natural infirmities of those we love.”
Monday is pun day:
* I’m reading an interesting book on anti-gravity. I just can’t put it down!
* I couldn’t remember how to throw a boomerang, but it came back to me.
* Q. What did the buffalo say to his son?  A. “Bison!”

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. 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: 5 Apr 2019:
84 FR 13499-13513: Civil Monetary Penalty Adjustments for Inflation

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: 11 Apr 2019: 84 FR 14608-14614: Revisions to the Unverified List (UVL) 
* 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.   


  – 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 Apr 2019: 84 FR 16398-16402: International Traffic in Arms Regulations: Transfers Made by or for a Department or Agency of the U.S. Government   
  – The only available fully updated copy (latest edition: 19 Apr 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: 18 Apr 2019: Harmonized System Update (HSU) 1906

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

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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  

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


* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; Assistant Editors, Vincent J.A. Goossen and Alexander Witt; and Events & Jobs Editor, Sven Goor. 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.

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

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

* SUBSCRIPTIONS: Subscriptions are free.  Subscribe by completing the request form on the Full Circle Compliance website

* BACK ISSUES: An archive of Daily Bugle publications from 2005 to present is available HERE.

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