19-0513 Monday “Daily Bugle'”

19-0513 Monday “Daily Bugle”

Monday, 13 May 2019

The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, DOE/NRC, Customs, NISPOM, EAR, FACR/OFAC, FAR/DFARS, FTR/AES, HTSUS, and ITAR), plus news and events. Subscribe here. Contact us for advertising 

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  1. State Seeks Comments Regarding Commodity Jurisdiction Determination 
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce Identifies Entities of National Security Concern
  3. Commerce/BIS Welcomes Registrations for Annual Conference on 9-11 July
  4. State/DDTC: (No new postings.)
  5. EU Commission Publishes New Guidance to Help EU countries Run Joint Defense Procurements
  1. Reuters: “China Defies Trump with New Round of Tariffs on U.S. Goods”
  1. Atlantic Council Publishes Report on Integration of U.S. Industrial Capabilities with Close Allies, Recommends “Dramatic Reset of U.S. Export Control System”
  2. M. Volkov: “OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)”
  3. Y. Kuchma: “What to Expect When You’re Expecting a Compliance Monitor”
  1. Monday List of Ex/Im Job Openings: 154 Openings Posted This Week, Including 12 New Openings 
  1. FCC Presents: “U.S. Export Controls: The ITAR from a non-U.S. Perspective”, 26 Nov in Bruchem, the Netherlands
  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 


State Seeks Comments Regarding Commodity Jurisdiction Determination
Federal Register, 13 May 2019.) [Excerpts.]
84 FR 20945: 30-Day Notice of Proposed Information Collection: Request for Commodity Jurisdiction Determination
* ACTION: Notice of request for public comment and submission to OMB of proposed collection of information.
* SUMMARY: The Department of State has submitted the information collection described below to the Office of Management and Budget (OMB) for approval. 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 30 days for public comment.
*DATES: Submit comments directly to the Office of Management and Budget (OMB) up to June 12, 2019.
* ADDRESSES: Direct comments to the Department of State Desk Officer in the Office of Information and Regulatory Affairs at the Office of Management and Budget (OMB). You may submit comments by the following
  – Email:
oira_submission@omb.eop.gov. You must include the DS form number, information collection title, and the OMB control
number in the subject line of your message.
  – Fax: 202-395-5806. Attention: Desk Officer for Department
of State.
You must include the information collection title (Request for
Commodity Jurisdiction Determination), form number (DS-4076), and the OMB control number (1405-0163) in all correspondence.
  – Title of Information Collection: Request for Commodity
Jurisdiction Determination.
  – OMB Control Number: 1405-0163.
  – Type of Request: Revision of a Currently Approved
  – Originating Office: Directorate of Defense Trade Controls
  – Form Number: DS-4076.
  – Respondents: Any person requesting a commodity
jurisdiction determination. …
Abstract of Proposed Collection
Pursuant to ITAR Sec. 120.4, a person, as defined by ITAR Sec.
120.14, may request a written determination from the Department of State stating whether a particular article or service is covered by the United States Munitions List (USML). Form DS-4076 is the means by which respondents may submit this request. Information submitted via DS-4076 will be shared with the Department of Defense, Department of Commerce, and other USG agencies, as needed, during the commodity jurisdiction process. Determinations will be made on a case-by-case basis based on the commodity’s form, fit, function, and performance capability.
Karen M. Wrege, Chief Information Officer.

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


* Commerce/BIS;
   – RULES; Addition of Certain Entities to the Entity List, Revision of an Entry on the Entity List, and Removal of an Entity from the Entity List; and
   – NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals [Concerning Offsets in Military Exports; Pub. Dates: 14 May 2019.]
* DHS/CBP; NOTICES; Meetings: Commercial Customs Operations Advisory Committee [Pub. Date: 14 May 2019.]
* USTR; NOTICES; Product Exclusions: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation [Pub. Date: 14 May 2019.]

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Commerce Identifies Entities of National Security Concern

(Source: Commerce, 13 May 2019.) [Excerpts.]
Diversions to China, Iran, and within Pakistan Land 12 Parties on the Bureau of Industry and Security’s Entity List
Today, the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce announced that it will add 12 foreign entities and individuals to the Bureau’s Entity List. This list contains the names of foreign parties that are subject to specific license requirements for the export, reexport, and/or in-country transfer of controlled items, ensuring that sensitive technologies do not fall into the hands of those who would threaten U.S. national security or American citizens. Organizations or persons who violate these rules – as defined under the Export Administration Regulations – are subject to criminal penalties and administrative sanctions.

In total, the additions include four entities with locations in both China and Hong Kong, and a further two Chinese, one Pakistani, and five Emirati persons. …

The four new entities located in both China and Hong Kong attempted to procure U.S.-origin commodities that would have supported Iran’s weapons of mass destruction (WMD) and military programs, in violation of U.S. export controls. Separately, four Emirati persons are included for obtaining U.S.-origin items for an existing entity list member without a license and for a denied party, Mahan Air, which is currently subject to a temporary denial order.

Two other Chinese entities participated in the prohibited export of controlled technology, which was then supplied to organizations affiliated with the People’s Liberation Army. Additionally, one Pakistani company is included on the update for procuring controlled technology on behalf of that country’s unsafeguarded nuclear activities. Another person in the UAE refused to support a BIS end-use check, which is cause for admission to the Entity List. …

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Commerce/BIS Welcomes Registrations for Annual Conference on 9-11 July

Commerce/BIS, 13 May 2019.)
The Bureau of Industry and Security (BIS) will hold the 32nd Annual Conference on Export Controls in Washington, D.C. July 9-11, 2019. The conference attracts experts from industry, academia, and government from around the world to learn and exchange ideas about export control issues.  It is one of the Bureau’s most notable export control outreach events.  
The theme of this year’s conference is “Emerging Technologies, Strategic Trade, and Global Threats”.  The planned agenda includes sessions on:

– 5G 
– Artificial Intelligence (AI) 
– Emerging Technology 
– The Committee on Foreign Investment in the United States (CFIUS)/ Foreign Investment Risk Review Modernization of 2018 (FIRRMA) 
– Export Control Reform Act of 2018 (ECRA)

The 2019 BIS Annual Conference will be at the Marriott Marquis Hotel. A conference room rate is available for attendees.
To Register Now as an Attendee
Click Here.
Exhibit opportunities are available.  The exhibit hall will be open during the entire conference:  on Tuesday, July 9 from 7:30 a.m. – 5:00 p.m., on Wednesday, July 10 from 7:30 a.m. – 6:30 p.m., and on Thursday, July 11 from 7:30 a.m. – 1:30 p.m. To Register Now as an Exhibitor
Click Here.

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EU Commission Publishes New Guidance to Help EU Countries Run Joint Defense Procurements

European Commission, 10 May 2019.)
The European Commission has published guidance on cooperative defense procurement to help EU countries apply the Defense Procurement Directive (Directive 2009/81/EC) consistently and make use of all the cooperation possibilities it offers. This will facilitate EU countries’ participation in collaborative defense projects under the future European defense fund and its current precursor programs. …
The guidance, announced in the 2016 
European defense action plan and in the evaluation of the directive, provides practical information on cooperative procurement between 2 or more EU countries and promotes openness in defense markets, while respecting the security interests of individual EU countries. In particular, the guidance clarifies the conditions for cooperative projects to be compatible with EU procurement rules applicable in the area of defense and security. The guidance complements the European defense fund, through which the EU provides financial support all along the lifecycle, from research to prototype development up to certification. The 
European defense fund will be fully operational in 2021. Meanwhile, 
EU funded defense cooperation is already materializing with precursor programs
For the first time in European history, under the current EU budget period, the EU is incentivizing European defense cooperation with a budget envelope of €590 million. Several research projects are already underway and the Commission recently issued the first calls for projects to jointly develop defense equipment and technology covering all domains (air, land, sea, cyber and space).
More information

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Reuters: “China Defies Trump with New Round of Tariffs on U.S. Goods”

Reuters, 12 May 2019.) [Excerpts.]
China said on Monday it would impose higher tariffs on a range of U.S. goods including frozen vegetables and liquefied natural gas, striking back in its trade war with Washington after U.S. President Donald Trump warned it not to.
The move, widely expected after the United States last week raised tariffs on $200 billion in Chinese imports, heightened fears the world’s two largest economies were spiraling into a no-holds-barred dispute that could derail the global economy.
China’s finance ministry said it plans to set import tariffs ranging from 5% to 25% on 5,140 U.S. products on a revised $60 billion target list. It said the tariffs will take effect on June 1.
“China’s adjustment on additional tariffs is a response to U.S. unilateralism and protectionism,” the ministry said. “China hopes the U.S. will get back to the right track of bilateral trade and economic consultations and meet with China halfway.”
The White House and U.S. Trade Representative’s office did not immediately respond to requests for comment. …

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COM_a18. Atlantic Council Publishes Report on Integration of U.S. Industrial Capabilities with Close Allies, Recommends “Dramatic Reset of U.S. Export Control System”

Atlantic Council, 23 Apr 2019.) [Excerpts.]
In U.S. law, the National Technology and Industrial Base (NTIB) comprises the industrial bases of the United States and three of its closest historical allies, Australia, Canada, and the United Kingdom. Canada was included when the original NTIB was established in 1994, and its scope was expanded in 2016 to include Australia and the United Kingdom. That recent expansion has corresponded with a changing threat and technology environment, in which the leading sources of industrial innovation reside outside the defense sector and, increasingly, beyond the U.S. and its Western allies. This new threat and technology environment will require a different a type of NTIB to support future defense-industrial planning and execution. The purpose of this new Atlantic Council report is to promote urgent deliberations over what a modern NTIB should look like, and to encour age Congress and the administration to adopt measures that will enable access to defense-industrial resources that are more responsive to the needs of the National Defense Strategy.   
“Leveraging the National Technology Industrial Base to Address Great-Power Competition,” is a comprehensive report by William Greenwalt, authored by former deputy under secretary of defense for industrial policy, available
here. The study is an attempt to begin a discussion on what a new NTIB should look like, and how Congress and the administration can pursue policies that can pre-pare the United States and its allies to compete in this new environment.
Among other things, Greenwalt stresses ”
export contamination-or the so-called “ITAR taint”-and the extraterritorial application of US export-control laws limit the industrial base available to US defense programs, and has incentivized both allies and the commercial market to develop their own solutions that deliberately avoid U.S. technology and persons. “
Greenwalt thinks that “the export-control regime within the NTIB will need to be dramatically reset,” while a “new technology-control system, based on a trusted community of industrial partners, should be established and tested within the NTIB to incentivize advanced research and development, as well as greater defense cooperation to meet the new security environment.” He believes that “a first step would require the US administration to apply the Canadian International Trafficking in Arms Regulation (ITAR) exemption to the UK and Australia, but also significantly broaden this exemption to address issues of ITAR contamination or taint (the use of controlled US knowledge at the research-and-development stage that applies to a product or service forever) and extraterritorial application of US export-control regulations and laws that have outlived their usefulness as guiding principles-at least among close allies. Additional legislative options address supply-chain transfers, program licensing, the foreign military-sales program, and past defense trade treaties with the UK and Australia.”
Greenwalt thinks that “Cold War management institutions, such as the ITAR and the US acquisition system, are now limiting the [U.S.] DoD’s access to some of the best technologies in the world.” He states that, overall, the US export-control system “has become increasingly backward looking,” because “it is designed to control things that have already been developed; this seems logical enough as the initial basis of control, but then takes the view that any US content must be the dominant technology that triggers controls.” According to Greenwalt, “this becomes an issue when any US person becomes involved in technology development, however superficially. This could be-come even more apparent and problematic in the current attempt to control “emerging technologies,” which may incorrectly assume that US industry, research, and investment still independently dominate these technologies. The system goes out of its way to be non-discriminatory, controlling goods and services on an equal basis for both U.S. allies and potential enemies. An arms embargo may keep China from ever being granted a license to buy U.S. weapons, but the real impact is felt by U.S. allies who may be granted a license to gain access to U.S. content after six to nine months of excruciating, bureaucratic process. Potential enemies or competitors would never apply for a license, so they either need to steal, indigenously develop their own technology, or buy from Russia or China. Thus, U.S. export controls are really about allocating technology to U.S. allies, and keeping it out of the hands of third- and fourth-tier countries that do not yet have the capability to develop it themselves. As a result, the US system has largely defaulted into a process of arms-sales trans-actions to the developing world, and a bureaucratic nightmare for close allies and industry.”
Export Control Reform is also mentioned in the report. Greenwalt states: “Despite the intention of export-control reform (ECR) in the last administration to focus the ITAR on U.S. ‘crown jewels,’ and transfer other items to the Commerce Department, under a system that is more flexible as regards US allies, this review found no appreciable differences from this reform effort that practically reduced the burden of cooperation with allies.”
To read the full report, click here.

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M. Volkov: “OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)”
Volkov Law Group Blog, 8 May 2019. Reprinted by permission.)
* Author: Michael Volkov, Esq., Volkov Law Group,
mvolkov@volkovlaw.com, 240-505-1992.
On the heels of the Justice Department’s announcement of its new compliance guidance, on May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance programs (“SCP”) (
Together with its aggressive enforcement of economic sanctions, OFAC has set a new standard for SCPs, and has “strongly encourage[d]” companies and individuals subject to OFAC jurisdiction to implement a “risk- based approach to sanctions compliance by developing, implementing and routinely updating a SCP.” 
OFAC has demonstrated an aggressive policy of enforcement this year in particular – especially with respect to the Iran sanctions program.   In this new era of aggressive OFAC sanctions enforcement, companies subject to OFAC jurisdiction should be mindful of the requirements for an effective SCP.  Companies that are in the process of implementing or updating their OFAC sanctions compliance program should review these documents and should incorporate these compliance expectations and elements into their own analysis. 
In its Framework, OFAC explained that, as part of its determination of an appropriate penalty for violations of a sanctions program, it will evaluate a subject entity’s SCP under its Sanctions Enforcement Guidelines to determine an appropriate civil monetary penalty and other requirements under a settlement agreement.  If a subject has an “effective SCP” at the time of the violation, or if the subject implements remedial compliance measures at the time of the resolution, OFAC may reduce a penalty and/or deem the penalty non-egregious.
Framework Structure
OFAC’s Framework is based on five essential components and includes an important Appendix outlining several of the root causes underlying violations of OFAC’s sanctions programs. 
OFAC noted the each risk-based SCP will vary depending on a variety of factors, including the company’s size and sophistication, products and services, customers and counterparties, and geographic locations, each SCP should be based on and incorporate at least five essential components of compliance:
(1) Management Commitment
(2) Risk Assessment
(3) Internal Controls
(4) Testing & Audit
(5) Training
Management Commitment, subject companies have to ensure that senior management (e.g. directors, executives, senior leaders) demonstrate its commitment to, and support of, the organization’s SCP.  This commitment is critical to ensure that the SCP receives “adequate resources and is fully integrated into the day-to-day operations,” and helps “legitimize the program, empower its personnel, and foster a culture of compliance throughout the organization.”  OFAC’s Framework notes that effective management support includes the provision of adequate resources to the compliance unit(s) and support for compliance personnel’s authority within an organization.
To meet this requirement, OFAC’s framework notes five specific elements:
(1) Senior management has reviewed and approved the organization’s SCP.
(2) Senior management ensures that its compliance unit(s) have been delegated sufficient authority and autonomy to deploy the policies and procedures in a manner that effectively controls its OFAC risks.  Senior management has to ensure the existence of direct reporting lines between SCP functions and senior management, including routine and periodic meetings between these two elements of the organization.
(3) Senior management has taken and will continue to take, steps to ensure that the compliance unit(s) receive adequate resources – including in the form of human capital, expertise, information technology and other resources, as appropriate – that are relative to the organization’s breadth of operations, target and secondary markets, and other factors affective its overall risk profile.  Under this element, OFAC outlined the following criteria: (a) The organization has appointed a dedicated OFAC sanctions compliance officer (who can also be responsible for other compliance programs); (b) The quality and experience of the SCP personnel, including their technical knowledge and expertise, the ability of the personnel to understand complex financial and commercial activities, apply their OFAC knowledge, and identify OFAC-related issues, risks and prohibited activities; (c) The efforts to ensure that personnel dedicated to the SCP have sufficient experience and appropriate “position” within the organization; and (d) Sufficient control functions exist to support the SCP, including but not limited to information technology software and systems.
(4) Senior management promotes a “culture of compliance” through the organization.  Under this element, OFAC outlined the following criterial: (a) The ability of personnel to report sanctions related misconduct by the organization or its personnel to senior management without fear of reprisal; (b) Senior management messages and takes actions that discourage misconduct and prohibited activities, and highlight the potential repercussions of non-compliance with OFAC sanctions; and (c) The ability of the SCP to have oversight over the actions of the entire organization, including but not limited to senior management, for the purposes of compliance with OFAC sanctions.
(5) Senior management demonstrates recognition of the seriousness of apparent violations of the laws and regulations administered by OFAC, or malfunctions, deficiencies, or failures by the organization and its personnel to comply with the SCP’s policies and procedures, and implements necessary measures to reduce the occurrence of apparent violations in the future. Such measures should address the root causes of past violations and represent systemic solutions whenever possible. 

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. Y. Kuchma: “What to Expect When You’re Expecting a Compliance Monitor”

Global Compliance News
, 2 May 2019.) [Excerpts.]

* Author: Yuliya Kuchma, Esq.,
. Of Baker McKenzie.
The goal of the recent change in the US DOJ’s approach to the use of corporate monitors is to ensure that the hiring of a compliance monitor as one of the conditions of a corporate settlement will be required only if it appears to be truly beneficial to improve the company’s compliance environment, and will not impose unnecessary burden to its business’ operations.
The settlement agreement has been signed, hands have been shaken, and what seemed to be an endless string of meetings and update calls with the counsel and the government, has come to the end. But not all companies that reached Foreign Corrupt Practices Act settlements with the U.S. Department of Justice can actually breathe out. For some of them, the end of the investigation is just the beginning of another chapter that may be just as lengthy and expensive as the investigation they just went through.
According to Brian A. Benczkowski, the assistant attorney general in charge of the Justice Department’s Criminal Division, the goal of the recent change in the DOJ’s approach to the use of corporate monitors is to ensure that the hiring of a compliance monitor as one of the conditions of a corporate settlement will be required only if it appears to be truly beneficial to improve the company’s compliance environment, and will not impose unnecessary burden to its business’ operations. “[T]he imposition of a corporate monitor is never meant to be punitive,” he said during the speech he gave at New York University School of Law last October. …

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MS_a111. Monday List of Ex/Im Job Openings: 154 Openings Posted This Week, Including 12 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; Irving, TX; Customs and Trade Compliance Analyst 
* Abbott; Sylmar, CA; Compliance Director

* 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;

* Ajilon; Grapevine, TX; Import Export Compliance Manager; Requisition ID: US_EN_7_849168_2557836

Allnex; Drogenbos, Belgium; Head of Trade Compliance EMEA

AM General; Auburn Hills, MI; 
International Compliance Analyst

* Ansys; Pittsburgh, PA; Export Compliance Specialist; Requisition ID: 7539

* 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; San Diego, CA; 
Customs & Export Control Classification Specialist;
Requisition ID: req9558

* 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; Williamstown, Australia; Assistant Export Control Officer; Requisition ID: BAE/1391315EXT

Beiersdorf; Hamburg, Germany; International Trade Expert

* Belk; Charlotte, NC; Sr Manager – Global Trade & Customs Compliance; Skyler Evans; Requisition ID: JR-20062

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

* BMW Manufacturing; Spartanburg, SC; SECT MGR Customs Compliance; Requisition ID: 190001DP
* Boehringer Ingelheim; Milan, Italy; Internship Compliance; Requisition ID: 192007

* Brooks; Chelmsford, MA; Senior Import / Export Compliance Analyst; Requisition ID: R0822

* Continental; Fairlawn, OH; Import Specialist, International Trade Compliance; Requisition ID: 117416BR
* Continental; Nürnberg, Germany; Specialist Customs & Foreign Trade (m/f/d); Requisition ID: 114014BR

* 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

* Deloitte; Zaventem, Belgium; Experienced Junior/Senior Customs and Global Trade Consultant; Requisition ID: 1800009Q

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

* Elbit Systems of America; Merrimack, NH; 
Licenses & Agreements Officer
; Requisition ID 2019-6948

* Embraer; Melbourne, FL; Sr. Trade Compliance Specialist; Requisition ID: 176896

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

* Esri; Redlands, CA; Export Compliance Specialist

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

* 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; Government Compliance Specialist; Requisition ID: 23607BR
* General Atomics; San Diego, CA; Government Regulatory Compliance Specialist; Requisition ID: 23576BR

* 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

* 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; Paris, France; Export Compliance Lead; Requisition ID: HRD60078
* Huntington Ingalls Industries; Fairfax, VA; Contracts/Business Administration Manager; Requisition ID: 18613

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

# * IKEA Purchasing Services; King of Prussia, PA; Regional Customs Manager, Americas 
* 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 
* Integra LifeSciences; Plainsboro, NJ; Import/Export Compliance Specialist; Requisition ID: 2019-29346

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
# *
Leonardo DRS; St Louis, MO; Export/Trade Compliance Specialist;
; Requisition ID: 94325

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

* Lockheed Martin; Arlington, VA; 
International Licensing Analyst Staff; Requisition ID: 480803BR

* 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

* 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; Manager, Trade Compliance; Requisition ID: 19-349

* 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

* Northrop Grumman; Redondo Beach, CA, San Diego, CA or Melbourne, FL; Sr. International Trade Compliance Analyst; Requisition ID: 19013440

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

* 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

* Qorvo; Richardson, TX; Import/Export Analyst; Requisition ID: 0008593

* Qualcomm; Bangalore, India; Export Compliance Specialist; Requisition ID: N1969832

* Raytheon; El Segundo, CA; Global Trade Authorization Owner; Requisition ID: 137660BR

* 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; 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

* Rockwell Automation; Mayfield Heights, OH and Milwaukee, WI; Senior Analyst, Import/Export Compliance; Requisition ID: 85004BR

* 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: 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

* SIG SAUER, Inc.; Newington, NH; Director of Trade Compliance; Requisition ID: 1114

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

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

* Sun Chemical; Cincinnati, OH, Northlake, IL, Parsippany, NJ;  
Requisition ID: 2019-2733

* Synopsys Inc.; Remote, U.S.; Director, Global Trade Compliance; Requisition ID: 20358BR

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 – Collins Aerospace; Cedar Rapids, IA; Export Licensing Specialist (ITC); Requisition ID: 01311691
* United Technologies – Collins Aerospace; Cedar Rapids, IA; Sr. Product Classification Specialist; Requisition ID: 01311991
* United Technologies – Collins Aerospace; Rockford, IL; International Trade Compliance Intern; Requisition ID: 01308699
* United Technologies – Collins Aerospace; Windsor Locks, CT; Associate Director Trade Compliance; Requisition ID: 01308017

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

* Viasat; Carlsbad, CA;
Global Trade Analyst
; Requisition ID: 2771

* Viasat; Carlsbad, CA; Global Trade Analyst; Requisition ID: 2824

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

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

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TE_a112. FCC Presents “U.S. Export Controls: The ITAR from a non-U.S. Perspective”, 26 Nov 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.

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


Florence Nightingale (12 May 1820 – 13 Aug 1910; was an English social reformer and statistician, and the founder of modern nursing. Nightingale laid the foundation of professional nursing with the establishment of her nursing school at St Thomas’ Hospital in London. It was the first secular nursing school in the world.)
– “A dark house is always an unhealthy house, always an ill-aired house, always a dirty house. Want of light stops growth and promotes scrofula, rickets, etc., among the children. People lose their health in a dark house, and if they get ill, they cannot get well again in it.” 
Daphne du Maurier (Dame Daphne du Maurier, Lady Browning, DBE, 13 May 1907 – 19 Apr 1989; was an English author and playwright. Her stories have been described as “moody and resonant” with overtones of the paranormal.  Many have been successfully adapted into films, including the novels 
My Cousin Rachel, and 
Jamaica Inn, and the short stories 
“The Birds” and 
“Don’t Look Now/Not After Midnight”.
  – ”
Women want love to be a novel, men a short story.”
Monday is pun day:
* What do you call a bear with no teeth?  A gummy bear.
* How did Darth Vader know what Luke was getting him for his birthday?  He could sense his presence.

* Why shouldn’t you trust atoms?  They make up everything.

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

. 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: 29 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  

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


* 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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