19-0429 Monday “Daily Bugle'”

19-0429 Monday “Daily Bugle”

Monday, 29 April 2019

  1. Treasury/OFAC Amends 31 CFR Part 579 to Implement EO 13848 (“Imposing Certain Sanctions in the Event of Foreign Interference in a United States Election”)
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. CDHS/CBP Publishes Update to AESTIR Appendix O (ITAR Exemption Codes)
  4. State/DDTC: (No new postings.)
  5. EU Extends Arms Embargo Against Myanmar/Burma
  1. Reuters: “Trump Pulling U.S. Out of U.N. Arms Treaty”
  1. A. Viski: “Conversations in International Commerce and Policy: Demand for Expertise in Strategic Trade”
  2. B.S. Haney: “Calculating Corporate Compliance & The Foreign Corrupt Practices Act”
  3. The FAQ of the Day: Self-Classification Determination
  1. Monday List of Ex/Im Job Openings: 154 Openings Posted This Week, Including 21 New Openings 
  1. FCC Presents: “U.S. Export Controls: The International Traffic in Arms Regulations (ITAR) from a non-U.S. Perspective”, 26 November 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 (29 Apr 2018), HTSUS (18 Apr 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


Federal Register, 29 Apr 2019.) [Excerpts.]
84 FR 17950-17958: Foreign Interference in U.S. Elections Sanctions Regulations
* AGENCY: Office of Foreign Assets Control, Treasury.
* ACTION: Final rule.
* SUMMARY: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is adding regulations to implement Executive Order of September 12, 2018 (“Imposing Certain Sanctions in the Event of Foreign Interference in a United States Election”). OFAC intends to supplement these regulations with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance, general licenses, and statements of licensing policy.
Effective Date: April 29, 2019.
* FOR FURTHER INFORMATION CONTACT: OFAC: Assistant Director for Licensing, tel.: 202-622-2480; Assistant Director for Regulatory Affairs, tel.: 202-622-4855; Assistant Director for Sanctions Compliance & Evaluation, tel.: 202-622-2490; or the Department of the Treasury’s Office of the Chief Counsel (Foreign Assets Control), Office of the General Counsel, tel.: 202-622-2410.
* SUPPLEMENTARY INFORMATION: … On September 12, 2018, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701-1706) (IEEPA), issued Executive Order 13848 (83 FR 46843, September 14, 2018) (E.O. 13848).
  In E.O. 13848, the President determined that the ability of persons located, in whole or in substantial part, outside the United States to interfere in or undermine public confidence in United States elections, including through the unauthorized accessing of election and campaign infrastructure or the covert distribution of propaganda and disinformation, constitutes an unusual and extraordinary threat to the national security and foreign policy of the United States. Accordingly, the President then declared a national emergency to deal with that threat.
  OFAC is issuing the Foreign Interference in U.S. Elections Sanctions Regulations, 31 CFR part 579 (the “Regulations”), to implement E.O. 13848, pursuant to authorities delegated to the Secretary of the Treasury in E.O. 13848. A copy of E.O. 13848 appears in appendix A to this part.
The Regulations are being published in abbreviated form at this time for the purpose of providing immediate guidance to the public. OFAC intends to supplement this part 579 with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance, general licenses, and statements of licensing policy. The appendix to the Regulations will be removed when OFAC supplements this part with a more comprehensive set of regulations. …
Andrea Gacki, Director, Office of Foreign Assets Control.
Approved: Sigal P. Mandelker, Under Secretary, Office of Terrorism and Financial Intelligence, Department of the Treasury.

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

* Treasury/OFAC; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Remittance Forwarding Services and Travel and Carrier Services to Cuba [Pub. Date: 30 April 2019.]
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(Source:  CSMS# 19-000221
, 26 Apr 2019.)
… The following updates have been made to the Automated Export Trade System Interface AESTIR Appendix O – DDTC ITAR Exemption Codes

– 22 CFR 126.4 (a) Export, Re-export, Re-Transfer or

Temporary Import of defense article, technical data, or defense service by agency of U.S. Government 
– 22 CFR 126.4 (b) Export, Re-export, Re-Transfer or Temporary Import of defense article, technical data, or defense service on behalf of U.S. Government agency.
– 22 CFR 126.4 (c) Return of temporary, or permanent export of defense article, technical data, or defense service for end-use by U.S. Government agency in foreign country.

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The European Council prolonged the restrictive measures in place on Myanmar/Burma for one year, until 30 April 2020.
The sanctions regime includes an embargo on arms and equipment that can be used for internal repression, an export ban of dual-use goods for use by the military and border guard police, and export restrictions of equipment for monitoring communications that might be used for internal repression. It also prohibits the provision of military training to and military cooperation with the Myanmar Armed Forces (Tatmadaw).
The prolongation also covers targeted restrictive measures on 14 individuals for serious human rights violations, or association with such violations, committed against the Rohingya population, ethnic minority villagers or civilians in Rakhine, Kachin and Shan States. These individuals are high-ranking officials from the Myanmar Armed Forces (Tatmadaw) and the border guard police.
The Council last adopted conclusions on Myanmar on 10 December 2018, expressing deep concern over the findings of the independent international fact-finding mission (FFM) of the UN Human Rights Council which concluded that gross human rights violations were committed in Kachin, Rakhine and Shan States, in particular by the Myanmar Armed Forces (Tatmadaw). The Council called upon the Government of Myanmar/Burma to take, without further delay, meaningful action and to make progress in all areas of concern set out in its previous conclusions of 26 February 2018.
The legal acts were adopted by the Council by written procedure. They will be published in the Official Journal of 30 April 2019.

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(Source: Reuters, 26 Apr 2019.) [Excerpts.]
President Donald Trump told the National Rifle Association on Friday he was pulling the United States out of an international arms treaty signed in 2013 by then-President Barack Obama but opposed by the NRA and other conservative groups.
Trump told members of the gun lobby at an annual meeting he intends to revoke the status of the United States as a signatory to the Arms Trade Treaty, which was never ratified by the U.S. Senate. …
Dropping out of the treaty is part of a broader Trump administration overhaul of arms export policies to bolster a domestic industry that already dominates global weapons trade. …

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8. A. Viski: “Conversations in International Commerce and Policy: Demand for Expertise in Strategic Trade”

(Source: George Mason University, 25 Apr 2019.)
* Author: Andrea Viski, adjunct professor in the Schar School’s Master’s in International Commerce and Policy program, director of the Strategic Trade Research Institute (STRI).
What do news headlines about the North Korean nuclear weapons program, the Huawei CFO arrest, the use of chemical weapons in Syria, and sanctions against Venezuela have in common? These headlines all involve the use of trade to influence the course of international events.
Because of globalization and rapid technological development, trade is a more powerful foreign policy tool than ever before. And never has the scope and meaning of trade itself been so debated.
Controlling the trade of sensitive materials, equipment, and technology that can be used for Weapons of Mass Destruction (WMD) has traditionally been rooted in list-based controls with nonproliferation as an objective – commonly referred to as export controls. The use of such trade controls has expanded vastly in the last two decades, and now these list-based WMD controls are joined by numerous United Nations Security Council sanctions resolutions as well as unilateral or regional sanctions programs that go beyond nonproliferation as a primary foreign policy objective.
And recently, trade controls have also come to encompass controls over transactions involving foreign investments-precluding trans-border flows of sensitive know-how and technology. Together, these various tools comprise the complex and evolving world of strategic trade controls.
The modern landscape of strategic trade encompasses not just what is traditionally perceived as trade – the export of a physical good from Country A to Country B – but also ideas, knowledge, technical assistance, and technology. And due to the sophisticated networks used by bad actors to acquire sensitive goods, a variety of factors-trans-shipment routes and trade finance, for example-play an important role in understanding the ways trade can affect international security.
Given the rising importance of strategic trade controls as a foreign policy tool, the demand for expertise in this field is larger than ever.
Nearly every U.S. company, research institute, or university exporting or dealing in trade-sensitive items and technology has a compliance department. In companies, compliance professionals screen-controlled products, services, and technology to make sure that they can be exported legally, and work with company employees in implementing internal compliance programs. In universities, compliance professionals work with university departments to ensure that, for example, certain research that has WMD relevance is conducted with security considerations in mind.
Demand for qualified personnel is also significant in the public sector. Licensing officers play a crucial national security role by reviewing export license requests and taking part in international and inter-agency efforts to preclude WMD proliferation or sanctions violations.
Demand is also high in enforcement and intelligence spheres, be it piecing together WMD proliferation networks or prosecuting companies that have violated U.S. trade controls. And given the important role of the U.S. in capacity-building, further career opportunities exist in contributing to international efforts to implement strategic trade controls in countries all over the world. Finally, expertise in strategic trade issues is a valuable and coveted asset in the research and journalistic communities. …

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. B.S. Haney: “Calculating Corporate Compliance & The Foreign Corrupt Practices Act” 

Abstract: Technology is rapidly disrupting every industry and institution around the globe. Yet, corporate compliance has remained relatively unaffected by technological change when compared to other industries. If firms continue to lag behind in their compliance efforts, their risk exposure to the potentially lethal sanctions associated with major compliance failures will continue to increase with time. This is particularly true in the context of the Foreign Corrupt Practices Act. Generally, the Foreign Corrupt Practices Act (“FCPA”) is a regulatory statute that forbids bribery and false accounting for domestic firms doing business abroad. And, in the past decade the DOJ and SEC have begun aggressively enforcing the FCPA. Firms should begin using technology to develop more robust and cost-efficient compliance programs to insulate themselves from the FCPA’s harsh penalties.
     This Article provides an algorithm that allows firms to evaluate and improve their compliance programs in accordance with several published sources of guidance. Compliance scholars have made clear that it is critical for firms to maintain strong corporate compliance programs and have suggested different models and frameworks for internal evaluation and auditing. However, those suggestions fail to consider how technology may be used to improve the cost-efficiency of corporate compliance and ethics programs. This Article takes an informatics-based approach to evaluating and improving firm compliance by focusing on the most important compliance functions according to the Department of Justice (“DOJ”), courts, and other Government actors. Indeed, firms may drastically improve the cost-efficiency of their compliance efforts by adopting the analytical framework proposed in this Article. …

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The FAQ of the Day: Self-Classification Determination

(Source: State/DDTC, 27 Apr 2019.)

Q: We have a Commodity Jurisdiction (CJ) determination issued before the effective date of the relevant category’s revision, pursuant to Export Control Reform. The original determination was that our product is subject to the International Traffic in Arms Regulations (ITAR). The product is clearly no longer controlled on the revised USML category and is clearly not controlled by any other USML category. May we, under the Order of Review, make a self-determination that the product is no longer subject to the ITAR without submitting a new CJ request to reverse the previous CJ determination?
A: Yes. A CJ determination that an item is subject to the USML is automatically superseded by amendments to the relevant USML categories that no longer include the item within their scope. 78 Fed. Reg. 22740, 22750 (Apr. 16, 2013). Thus, there is no need to submit a CJ request to confirm that an item no longer within the scope of a USML category is no longer subject to the ITAR — even if DDTC had previously issued a CJ determination that the item was subject to the ITAR prior to an amendment of the USML category at issue. To ensure compliance with U.S. export control rules with respect to a product, one must make a self-determination regarding its correct jurisdictional and classification status before exporting or reexporting it. If there is doubt about whether the product is within the scope of a USML category, one may seek a CJ determination from DDTC under the established procedures.

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MS_a111. Monday List of Ex/Im Job Openings: 154 Openings Posted This Week, Including 19 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


* 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
* 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

ASML; Veldhoven, the Netherlands; Customs & Export Control Classification Specialist; Requisition ID: req9253

* 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

Brooks; Chelmsford, MA; Senior Import / Export Compliance Analyst; Requisition ID: R0822
# C4ATS; Orlando, FL; Defense Import-Export Compliance Manager; Ivette De Jesus Ivette.DeJesus@c4ats.com CFO 243 Wetherbee Rd Orlando, FL 32824 Tel.407.206.3886 Ext 104 Cell: 407.488.7894. 

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

Cummins Inc; Global; Global Export Controls Manager; Barbara Flynn; Requisition ID: IRC380364
Cummins Inc; Export Controls Analyst Senior; Barbara Flynn; Requisition ID: IRC351977

* 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

* 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

* 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; 
Commodities Jurisdiction Analyst

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

Hitachi Vantara; Singapore; Trade Compliance Analyst; Requisition ID: 1003050 (026187)
Honeywell; any SPS location, U.S.; Export Compliance Manager (North America); Requisition ID: HRD45798
Honeywell; Paris, France; Export Compliance Lead; Requisition ID: HRD60078
Huntington Ingalls Industries; Fairfax, VA; Contracts/Business Administration Manager; Requisition ID: 18613
Huntington Ingalls Industries; Fairfax, VA; Import Export Administrator; Requisition ID: 18614

* 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

Itron; Austin, TX; Compliance & Regulatory Counsel; Requisition ID: 1900030

* 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; 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

Mastercard; O’Fallon, MO; Manager, Legal Compliance, Export Controls Compliance; Requisition ID: R-84414

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

Mercury Systems; multiple locations; Principle Trade Compliance Specialist; Requisition ID: 19-226

* 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

Nouryon; Radnor, PA; Global Trade Compliance Manager; Requisition ID: 190001UJ

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

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

PCCW Limited; Herndon, VA; Manager – International Trade Compliance (Americas)career-corporate@pccw.com; Requisition ID: MITC-0419-US
PCCW Limited; Hong Kong, China; Manager – International Trade Compliance (Asia)career-corporate@pccw.com; Requisition ID: MITC-041900-HK

* 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; 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

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

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

* Sarepta Therapeutics; Cambridge, MA;
Director, Logistics & Global Trade Compliance 
Science and Engineering Services, LLC; Huntsville, AL; Trade Compliance Administrator; Requisition ID: 946
Shell; Houston, TX; Advisor Trade Controls; Requisition ID: 105518BR

* 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 

# Tesla, Inc.; Fremont, CA; Program Manager, Tariff Strategy; Requisition ID: 46503 

* 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 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

University of Manchester; Manchester, United Kingdom; Export Control Compliance Officer; Requisition ID: PSX-13808

* 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_a112. FCC Presents “U.S. Export Controls: The International Traffic in Arms Regulations (ITAR) from a non-U.S. Perspective”, 26 November in Bruchem, the Netherlands

This intermediate-level training course is specifically designed for compliance professionals and those in a similar role who aim to stay up-to-date with the latest International Traffic in Arms Regulations (ITAR) requirements that apply to non-U.S. transactions.
The course will cover multiple topics relevant for organizations outside the U.S. that are subject to the International Traffic in Arms Regulations, including but not limited to: the U.S. regulatory framework, key ITAR concepts and definitions, tips regarding classification and licensing, essential steps to ensure an ITAR compliant shipment, how to handle a (potential) non-compliance issue, recent enforcement trends, and the latest regulatory amendments, including the latest U.S. Export Control Reform developments. Participants will receive a certification upon completion of the training.
* What: U.S. Export Controls: The International Traffic in Arms Regulations (ITAR) from a non-U.S. Perspective
* When: Tuesday, 26 Nov 2019
 – Welcome and Registration: 9.00 am – 9.30 am
 – Training hours: 9.30 am – 4.30 pm
* Where: Full Circle Compliance, Landgoed Groenhoven, Dorpsstraat 6, Bruchem, the Netherlands
* Information & Registration: via the
event page or contact FCC at
events@fullcirclecompliance.eu or + 31 (0)23 – 844 – 9046
* This course can be followed in combination with “U.S. Export Controls: The Export Administration Regulations (EAR) from a non-U.S. Perspective” (27 Nov 2019), and/or “The ABC of Foreign Military Sales” (29 Nov 2019). Please, see the event page for our combo deals.

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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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* Jay Leno (James Douglas Muir Leno, born 28 Apr 1950, is an American comedian, actor, writer, producer, and television host.  He hosted his last episode of The Tonight Show on February 6, 2014. Since then, Leno has hosted Jay Leno’s Garage.)
 – “I think high self-esteem is overrated. A little low self-esteem is actually quite good. Maybe you’re not the best, so you should work a little harder.”
* John F. Kennedy (John Fitzgerald Kennedy; 29 May 29, 1917 – 22 Nov 1963; was an American politician and journalist who served as the 35th president of the United States from January 1961 until his assassination in November 1963.)
  – “Physical fitness is not only one of the most important keys to a healthy body, it is the basis of dynamic and creative intellectual activity.”

* Bob Hope (Leslie Townes Hope, 29 May 1903 – 27 July 2003; was a British-born American stand-up comedian, vaudevillian, actor, singer, dancer, athlete, and author. With a career that spanned nearly 80 years, Hope appeared in more than 70 short and feature films, and was the author of 14 books.)
 – “Middle age is when your age starts to show around your middle.”
Monday is pun day:
* Where should you go if you’re cold?  Stand in a corner.  It’s 90 degrees there.
* The soldiers who survived mustard gas and pepper spray were seasoned veterans.

* Sausage puns are the wurst.

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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: 19 Apr 2019: 84 FR 17950-17958: Foreign Interference in U.S. Elections Sanctions Regulations [amendment of 31 CFR Part 579 to implement EO 13848]  
* 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  

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* 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.

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