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19-0520 Monday “Daily Bugle'”

19-0520 Monday “Daily Bugle”

Monday, 20 May 2019

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

inquiries and rates
. 

[No items of interest noted today.] 

  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS Welcomes Registrations for Annual Conference on 9-11 July
  3. DoD/DSCA Posts New Policy Memo
  4. State/DDTC: (No new postings.)
  5. EU Council Extends Syria Sanctions by One Year
  6. EU Amends Restrictive Measures Concerning ISIL (Da’esh) and Al-Qaida, and Syria, Creates New Cyber-Attack Sanctions Regime
  1. The Buffalo News: “Man Accused of International Gun Sales Goes to Prison”
  2. The Drive: “Company Teases New F-16 Flight Sim After Developer Ends Up in Jail Over Buying USAF Manuals”
  3. The New York Times: “Infineon Denies Report It Has Suspended Huawei Shipments
  4. Nikkei Asian Review: “Japan Weighs Export Controls for Cutting-Edge Tech”
  5. ST&R Trade Report: “U.S., Canada, Mexico to Terminate Steel and Aluminum Tariffs”
  6. Tech Crunch: “Why Start-Ups Need to Be Careful About Export Licenses and the Huawei Ban”
  1. D.H. Laufman & J. Clark: “Executive Order Imposes New Compliance Obligations on Parties to Transactions Involving Information and Communications Technologies”
  2. J. Haggin: “Turkey Loses GSP Status & More!”
  3. T.M. Polino, D.R. Hamill & D. Salkeld: “Additional Duties Proposed on Another $300 Billion of China Products”a
  1. David Laufman Moves to Wiggin & Dana Law Firm 
  2. Monday List of Ex/Im Job Openings: 152 Openings Posted This Week, Including 17 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 (14 May 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 (13 May 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 

EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1

[No items of interest noted today.] 

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

OGSOTHER GOVERNMENT SOURCES

OGS_a11. Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register)

 
* Commerce/BIS; RULES; Addition of Entities to the Entity List [Pub. Date: 21 May 2019.]   
* * * * * * * * * * * * * * * * * * * * 

OGS_a22
. Commerce/BIS Welcomes Registrations for Annual Conference on 9-11 July
(Source: Commerce/BIS, 13 May 2019.) [Repost of 13 May Daily Bugle.]
 
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.
* * * * * * * * * * * * * * * * * * * *

OGS_a33.
DoD/DSCA Posts New Policy Memo

(Source: DoD/DSCA, 19 May 2019.)

 
   Effective immediately, Program Code “7E” is assigned to track and execute FY 2019/2020 funds provided for PKO-OCO under Division F of the Department of State, Foreign Operation and Related Program Appropriations Act, 2019 (P.L. 116-06). These funds are available for obligation until September 30, 2020 and for reprogramming until September 30, 2024.

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

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OGS_a55.
EU Council Extends Syria Sanctions by One Year

(Source: Council of the European Union, 17 May 2019.) [Excerpts.]
 
On 17 May 2019, the Council extended EU restrictive measures against the Syrian regime until 1 June 2020. In line with the EU strategy on Syria, the EU decided to maintain its restrictive measures against the Syrian regime and its supporters as the repression of civilian population continues.
 
The Council also removed 5 deceased persons from the list, as well as one entity which ceased to exist and one entity for which there were no longer grounds to keep it under restrictive measures. The list now includes 270 persons and 70 entities targeted by a travel ban and an asset freeze for being responsible for the violent repression against the civilian population in Syria, benefiting from or supporting the regime, and/or being associated with such persons or entities.
 
More broadly, sanctions currently in place against Syria include an oil embargo, restrictions on certain investments, a freeze of the assets of the Syrian central bank held in the EU, export restrictions on equipment and technology that might be used for internal repression as well as on equipment and technology for the monitoring or interception of internet or telephone communications. …

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OGS_a66.
EU Amends Restrictive Measures Concerning ISIL (Da’esh) and Al-Qaida, and Syria, Creates New Cyber-Attack Sanctions Regime

(Source: Official Journal of the European Union, 17 and 20 May 2019.)
 
Regulations
* Commission Implementing Regulation (EU) 2019/791 of 16 May 2019 amending for the 302nd time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organisations
* Council Regulation (EU) 2019/796 of 17 May 2019 concerning restrictive measures against cyber-attacks threatening the Union or its Member States
* Council Implementing Regulation (EU) 2019/798 of 17 May 2019 implementing Regulation (EU) No 36/2012 concerning restrictive measures in view of the situation in Syria
 
Decisions
* Council Decision (CFSP) 2019/797 of 17 May 2019 concerning restrictive measures against cyber-attacks threatening the Union or its Member States
* Council Decision (CFSP) 2019/806 of 17 May 2019 amending Decision 2013/255/CFSP concerning restrictive measures against Syria

 

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NWSNEWS

NWS_a17
.
The Buffalo News: “Man Accused of International Gun Sales Goes to Prison”

(Source: The Buffalo News, 17 May 2019.) [Excerpts.]
 
A Canadian accused of international arms sales stood before a judge in Buffalo Friday and admitted his guilt.
 
Aydan Sin, 47, pleaded guilty to violating the Arms Export Control Act and will face a recommended sentence of up to 63 months in prison.
 
Sin, who appeared Friday before U.S. District Judge Richard J. Arcara, was accused of conspiring with two other Canadians to sell 15 mini Uzi submachine guns and 40 9mm Glock pistols in 2017 to customers in Colombia and the United Arab Emirates.
 
Prosecutors don’t know who the intended customers were, but Assistant U.S. Attorney Aaron J. Mango said they requested the guns’ serial numbers be removed. …

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

NWS_a28
.
The Drive: “Company Teases New F-16 Flight Sim After Developer Ends Up in Jail Over Buying USAF Manuals”

(Source: The Drive, 17 May 2019.) [Excerpts.]
 
It’s no secret that The War Zone is a fan of Eagle Dynamics’ hyper-realistic flight simulator Digital Combat Simulator World, better known as DCS World. So it’s exciting to see the company offer the first glimpse of its upcoming F-16C Block 50 module. But it now comes with an unusual added twist as one of the company’s programmers, Oleg Tishchenko, is now sitting in the Weber County Jail in Utah charged with attempting to smuggle sensitive U.S. military aircraft flight manuals related to the F-16 Viper and the F-22 Raptor back home in violation of the U.S. government’s International Traffic in Arms Regulations (ITAR). …
 
The U.S. government has charged Tishchenko with one count each of conspiracy to commit an offense against the United States, violation of the Arms Export Control Act, smuggling goods from the United States, attempted violation of the Arms Export Control Act, and attempts to smuggle goods from the United States. You can find a copy of the full indictment here. All of this centers around the Russian’s purchase and attempts to purchase U.S. Air Force “Technical Order” manuals for various models of the F-16, as well as the F-22. …

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NWS_a39
.
The New York Times: “Infineon Denies Report It Has Suspended Huawei Shipments
(Source: The New York Times, 20 May 2019.) [Excerpts.]
 
German chipmaker Infineon is continuing most shipments to Huawei, it said on Monday, denying a report in Japan’s Nikkei daily that it had suspended deliveries to the Chinese telecoms firm.
 
Infineon, which makes power-management chips used in cars, smartphones and wind turbines, said most of its products were not covered by the U.S. export control restrictions announced by the Trump administration last Thursday.
 
“As of today, the great majority of products Infineon delivers to Huawei is not subject to U.S. export control law restrictions, therefore those shipments will continue,” Infineon said in a statement. …

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NWS_a410
.
Nikkei Asian Review: “Japan Weighs Export Controls for Cutting-Edge Tech”

(Source: Nikkei Asian Review, 20 May 2019.) [Excerpts.]
 
Japan is considering restricting exports of advanced technology used in such applications as artificial intelligence and robots, following the lead set by recent American measures aimed at China.
 
While Japanese law has a framework for keeping sensitive technology out of foreign hands, it focuses mainly on dual-use goods that can be utilized in nuclear weapons, missiles, and chemical and biological weapons, for example. The list of restricted items includes certain machine tools, electronic components and materials.
 
But there are advanced technologies expected to see broader use that are not covered by these curbs even if they present a security risk. While exports of certain 3D printers can be restricted via the machine tools category, “there are many other technologies that cannot be banned under our current framework,” including AI and robotics, a government source said.
 
The U.S. is employing export controls in its trade war with China, most recently with the addition of Huawei Technologies to a blacklist that essentially bans exports to the telecommunications giant. Washington earlier this year closed a public comment period on planned restrictions that target emerging technologies in 14 categories, including AI, biotechnology, robotics, quantum computing, 3D printing and advanced materials. …

 

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NWS_a511
.
ST&R Trade Report: “
U.S., Canada, Mexico to Terminate Steel and Aluminum Tariffs”

 
The U.S. announced May 17 that it will eliminate all section 232 tariffs on steel and aluminum products from Canada and Mexico, which in turn will remove all retaliatory tariffs on U.S. goods. However, tariffs could be reimposed if imports of these products surge.
 
The U.S. imposed section 232 tariffs of 25 percent on steel and 10 percent on aluminum products imported from Canada and Mexico as of June 1, 2018. Those two countries responded with retaliatory tariffs on goods imported from the U.S. (
Click here
for ST&R’s web page providing full details.)
 
To address the problems underlying the decision to impose these tariffs, which largely have to do with the growth of production in and exports from China, a joint statement said the U.S. and Canada have agreed to implement effective measures to prevent (a) the importation of aluminum and steel that is unfairly subsidized and/or sold at dumped prices and (b) the transshipment of aluminum and steel made outside of the U.S. or Canada to the other.
 
In addition, the statement said, a process will be established for monitoring U.S.-Canada trade in steel and aluminum products. If imports surge meaningfully beyond historic volumes over a period of time (which was not defined), the importing country may request consultations with the exporting country. After such consultations, the importing party may impose duties of 25 percent for steel and 10 percent for aluminum with respect to the individual product(s) where the surge took place. If such measures are imposed, the exporting country agrees to retaliate only in the affected sector.
 
Although no official notice from Mexico was available at press time, press sources indicate that the terms above will apply to U.S.-Mexico trade in steel and aluminum products as well.

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NWS_a612
.
Tech Crunch: “Why Start-Ups Need to Be Careful About Export Licenses and the Huawei Ban”

(Source: Tech Crunch, 20 May 2019.) [Excerpts.]
 
America is the land of free trade … precisely until it is not. Through a thicket of laws and regulations, the U.S. government has broad control over what can get exported to whom, particularly in areas with sensitive technology or national security concerns. In general, those restrictions are loose, which is why startups mostly haven’t had to think about export laws.
 
That open world is rapidly closing though, and startups could well be the most harmed given that they have limited resources to handle these sorts of bureaucratic processes and the potential large penalty fines.
 
Last week, President Trump signed an executive order requiring that the Department of Commerce initiate a review of regulations and enforcement practices to ensure that U.S. entities (people and companies) don’t provide “information and communications technology or services” to a “foreign adversary.” That term was read as describing China, although nothing in the order prevents its expansion to cover other countries in the future. …

  

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COMMCOMMENTARY

COM_a113.
D.H. Laufman & J. Clark: “Executive Order Imposes New Compliance Obligations on Parties to Transactions Involving Information and Communications Technologies”
 
* Authors: David H. Laufman, Esq., 
dlaufman@wiggin.com; and Jared Clark, Esq., 
jclark@wiggin.com. Both of Wiggin & Dana LLP
 
On May 15, President Trump issued an Executive order declaring a national emergency with respect to the threat posed by “foreign adversaries” seeking to exploit vulnerabilities in U.S. information and communications technology infrastructure and services. The “Executive Order on Securing the Information and Communications Technology and Services Supply Chain,” which comes amidst heightened trade tensions with China, presents considerable new challenges and complications for U.S. companies dependent on Chinese information or communications technology. In particular, the order will require U.S. businesses to implement new compliance strategies as they race to adopt fifth-generation, or 5G, networking technology.
 
The order broadly prohibits U.S. companies from acquiring, importing, transferring, dealing in, or using any information and communications technology or service “where the transaction involves any property in which any foreign country or a national thereof has any interest,” if the Secretary of Commerce has made the following determinations: (1) the transaction involves information and communications technology or services designed, developed, manufactured, or supplied, by persons owned by, controlled by, or subject to the jurisdiction or direction of a “foreign adversary”; and (2) the transaction (a) poses an undue risk of sabotage to or subversion of the design, integrity, manufacturing, production, distribution, installation, operation, or maintenance of information and communications technology or services in the United States; (b) poses an undue risk of catastrophic effects on the security or resiliency of United States critical infrastructure or the digital economy of the United States; or (c) otherwise poses an unacceptable risk to the national security of the United States or the security and safety of United States persons. 
 
China is clearly the primary target of the order, though not expressly identified as such.  On the same day the order was issued, the Department of Commerce added Chinese telecommunications giant Huawei Technologies Co. Ltd. to its “Entity List” on the grounds that that Huawei “is engaged in activities that are contrary to U.S. national security or foreign policy interests.” As a result, U.S. companies are now prohibited from exporting equipment to Huawei without a license, with license applications subject to a presumptive policy of denial. In addition, the order follows and supplements a 2018 law, included in the Defense Authorization Act, that banned the U.S. government and government contractors from using equipment manufactured by Huawaei and fellow Chinese telecommunications company ZTE Corporation. Finally, the order defines “foreign adversary” as “any foreign government or foreign non-government person engaged in a long-term pattern or serious instances of conduct significantly adverse to the national security of the United States or security and safety of United States persons” – a definition that closely corresponds to U.S. Government intelligence and law enforcement assessments regarding Chinese government threats to the U.S. supply chain.
 
In addition to authorizing the Secretary of Commerce to block transactions of the nature described above, the order empowers the Secretary to designate specific countries and companies as “foreign adversaries” and to identify certain technologies that warrant particular scrutiny under the order.  The Secretary may also direct when and how U.S. businesses must cease using such technologies, and may establish procedures for licensing otherwise-prohibited transactions. The Secretary must publish regulations implementing these new authorities within 150 days of the order.
 
The ultimate impact of the order on business operations will be determined by the final form of implementing regulations and practical experience, but there is little question that the order will result in significant new compliance obligations for U.S. businesses. Even with a framework of published rules in place, regulatory uncertainty is likely to persist; like the U.S. sanctions on Russia, the order draws its legal authority in part from the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.), and, if the Russia sanctions are any guide, U.S. businesses may find that compliance with the order is complicated by the fact that even the most well-intentioned rules are easier to follow in theory than in practice. At a minimum, forward-thinking U.S. businesses considering transacting with foreign companies in the information or communications technology space should begin to develop compliance processes that front-load due diligence on the ownership structures of prospective counterparties and the relationships between prospective counterparties and their home (or other foreign) governments.

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COM_a2
14
.
J. Haggin: “Turkey Loses GSP Status & More!”

(Source: Editor, 18 May 2019.)
 
* Author: Judy Haggin, Senior Director of Compliance, Total Logistics Resource, 
judyh@shiptlr.com
, +1 971-634-1477
 
On April 30th, we issued a Compliance Alert regarding the Trump administration’s intention to terminate Turkey’s designations as a beneficiary developing country under the GSP program.  Last night (May 16), President Trump issued his Presidential Proclamation ending GSP status for Turkey, effective today, May 17, 2019.   The proclamation also ended safeguard exemptions that Turkey had enjoyed for residential washers and CSPV cells.  In a second proclamation issued yesterday, President Trump restored the duty rate on steel products from Turkey from 50% to 25%, effective May 21, 2019.
 
We also learned today that an agreement has been reached to remove Section 232 duties from Canada and Mexico 
within the next 48 hours.  This will remove one major barrier to the newly negotiated USMCA agreement being ratified by all three countries.  For more information on all of these issues and their developments, please see the Compliance Alert at 
www.shiptlr.com
.

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COM_a3
15
.
T.M. Polino, D.R. Hamill & D. Salkeld: “Additional Duties Proposed on Another $300 Billion of China Products”
(Source:
Arent Fox, 15 May 2019.)
 
* Authors: Teresa M. Polino, Esq.,
teresa.polino@arentfox.com; David R. Hamill, Esq., 
david.hamill@arentfox.com; and David Salkeld, Esq.
david.salkeld@arentfox.com. All of Arent Fox LLP.
 
Update on Product Exclusions and Enforcement of List 3 Duty Increase
 
As President Donald Trump threatened last weekend – just days after the Section 301 tariff on List 3 products was increased from 10 percent to 25 percent following a breakdown in trade negotiations between the United States and China – the Administration on Monday released a fourth list of Chinese-origin products to be subject to additional duties. For these tariffs to become effective, the US Trade Representative will need to publish a final notice after public comment and hearing.
The United States and China have been engaged in protracted negotiations over the Chinese government’s acts, policies, and practices related to technology transfer, intellectual property, and innovation that the Trump Administration has found to be unreasonable and burdensome to US commerce.
 
To date, the President has used his authority under Section 301 of the Trade Act of 1974 three times to levy a 25 percent retaliatory tariff on 6830 subheading categories of imported Chinese high-tech and consumer goods valued at $250 billion per year. Although List 3, alone valued at $200 billion, had originally set an additional duty rate at 10 percent, that rate was
increased to 25 percent effective 12:01 A.M. May 10, further straining the bilateral talks.
 
New Products for China Tariffs
 
Moreover, after China allegedly “retreated from specific commitments made in previous rounds” and increased its own tariffs against US goods, the USTR officially
proposed a fourth list of goods valued at nearly $300 billion. This 135-page List 4 would comprise 3805 categories of goods including cellphones and other electronic devices, agricultural products like cheese, toys, apparel, home goods, shoes, sporting goods, chemicals, and child safety seats.
 
If this proposal is accepted, all Chinese imports excluding certain pharmaceuticals, medical products, rare earth metals, and minerals will be subject to a 25 percent extra levy.
 
Before List 4 can take effect, the proposal will undergo a public comment period and hearing similar to those for Lists 1 through 3. The dates are:
 
  – June 10: Deadline to request to appear at hearing
  – June 17: Deadline to submit pre-hearing comments
  – June 17: Public hearing at USTR
  – June 24: Deadline to submit post-hearing rebuttal comments (due 7 days after the final day of hearings).
 
USTR has requested that comments focus on:
 
– The specific tariff subheadings to be subject to increased duties, including whether the subheadings listed in the proposal should be retained or removed, or whether subheadings not currently on the list should be added;
– The level of the increase, if any, in the rate of duty;
The appropriate aggregate level of trade to be covered by additional duties;
– Whether imposing increased duties on a particular product would be practicable or effective to obtain the elimination of the concerned Chinese acts, policies, and practices; and
– Whether imposing additional duties on a particular product would cause disproportionate economic harm to US interests, including small- or medium-size businesses and consumers.
 
President Trump has indicated his desire to meet with Chinese President Xi Jinping at a G20 summit in Osaka, Japan in late June, which may affect the implementation of List 4. However, absent progress on negotiations, USTR could publish the final version of List 4 as soon as July with an effective date shortly thereafter if it moves as fast as it did to implement earlier tariffs.
 
A combined list of the products covered by Section 301 Lists 1, 2, 3, and 4 is available
here.
 
Product Exclusions
 
Meanwhile, USTR published its
fourth notice of product exclusions for List 1. The excluded goods, mostly machinery, include outboard motor engines for boats, certain fork lifts, ATM circuit boards, and pressure valves. It remains unknown whether a process for importers to request an exclusion of specific products would accompany List 4 as it did for Lists 1 and 2, and as is expected to be announced before the end of the month for List 3. The USTR confirmed that List 3 will have an exclusion process only after the duty rate was increased from 10 percent to 25 percent.
 
List 3 Increased Tariff Rate Effective Date
 
Furthermore, following an updated
CSMS message, USTR
published in the Federal Register a notice stipulating that List 3 goods already in transit from China before May 10 and entered prior to June 1 will be subject to the 10 percent duty rate rather than the higher 25 percent rate. Goods exported and entered on or after May 10 will be assessed the 25 percent rate, as will all goods entered on or after June 1, regardless of export date.

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MSEX/IM MOVERS & SHAKERS

MS_a016. David Laufman Moves to Wiggin & Dana Law Firm

(Source: Editor)
 
David H. Laufman has moved from a solo practice to the Wiggin & Dana law firm in Washington, D.C. Laufman was previously chief of the U.S. Department of Justice National Security Division’s Counterintelligence and Export Control Section, where he supervised the Justice Department’s enforcement of U.S. export control and sanctions laws, as well as the Foreign Agents Registration Act, and oversaw investigations in 2016 involving both Hillary Clinton’s use of a private email server and Russian election interference.  At Wiggin & Dana, David will co-chair the national security practice group. He will also be a member of the firm’s white-collar defense, investigations, and corporate compliance practice group and the international trade compliance group. Contact David at
d.laufman@wiggin.com or call + 1 202-800-2477.  

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MS_a117. Monday List of Ex/Im Job Openings: 152 Openings Posted This Week, Including 17 New Openings 

(Source: Events & Jobs Editor) 
 

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

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

#
” New or amended listing this week

 

* Abbott; Irving, TX; Customs and Trade Compliance Analyst 
* Abbott; Sylmar, CA; Compliance Director 
#
* Accenture
; Buenos Aires, Argentina; Contract Analyst – Trade Compliance

* 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

*
 
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


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

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

#
* Boeing; Bangalore, India; Trade Control Specialist; Requisition ID: 1900122844
#
* Boeing; Berlin, Germany; Global Trade Controls Manager; Requisition ID: 1900113134

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

#
* Cisco; Charlotte, NC; Trade Compliance Manager; Requisition ID: 1261937

* Continental; Fairlawn, OH; Import Specialist, International Trade Compliance; Requisition ID: 117416BR

* 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

#
* DHL; Hong Kong, China; Regional Compliance Officer, APEC; Requisition ID: req78306
#
* DHL; Central Europe; Compliance Manager; Requisition ID: req77632


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 

*
 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
 

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

* 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

* Integra LifeSciences; Plainsboro, NJ; Import/Export Compliance Specialist; Requisition ID: 2019-29346

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

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


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

#
* Kelley Drye & Warren LLP; Washington DC; Junior Export Controls/Sanctions Associate

* 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

#
* LanceSoft; Tewksbury, MA; Export Controls / Classification Contractor

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

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

#
* Lockheed Martin; multiple locations, U.S.; Cyber Governance Compliance Analyst; Requisition ID: 467162BR

* Leonardo DRS; Melbourne, FL; 
Senior Supply Chain Analyst – Small Business Compliance
; Requisition ID: 91669
*
Leonardo DRS; St Louis, MO; Export/Trade Compliance Specialist;
brandy.mormino@drs.com
; 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 Aeronautics; Palmdale, CA; Export Compliance Site Lead; Requisition ID: 477630BR

#
* Lockheed Martin Rotary and Mission Systems; Liverpool, NY, Moorestown, NJ, Owego, NY, Stratford, CT; Intl Licensing Analyst Stf; Requisition ID: 483502BR

* 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

#
* Microsoft; Redmond, WA; Export Control Manager; Requisition ID: 609856

*
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

#
* Ormat Technologies; Reno, NV; Manager, Global Trade Compliance

* 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

* 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

# * Rolls Royce; Indianapolis, IN; Export Control Manager – Defense; Requisition ID: JR6046902 
* Saab Defense and Security USA LLC; East Syracuse, NY;
Senior Import and Classifications Analyst 

*
 SABIC; Houston TX; 
Senior Analyst, Trade Compliance
;
Danielle.Cannata@sabic.com
; 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; Taipei, Taiwan; Summer Internship Legal & Compliance; Requisition ID: 107028

* 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

#
* Spin Master; Bratislava, Slovakia; Logistics Coordinator – Trade Compliance Analyst

* 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   

* 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

* 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

#
* XPO Logistics; Greenwich, CT; Compliance Paralegal
#
* XPO Logistics; Greenwich, CT; Director, Trade Compliance Counsel

 
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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_a118. 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.
 
Details
* 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.

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

ENEDITOR’S NOTES

*
Nancy Astor (Nancy Witcher Langhorne Astor; 19 May 1879 – 2 May 1964; was an American-born British politician and the first female Member of Parliament (MP) to take her seat. Astor was an American citizen who moved to England at age 26 and married Waldorf Astor. He succeeded to the peerage and entered the House of Lords; she then entered politics and won his former seat in Plymouth in 1919, becoming the first woman to sit as an MP in the House of Commons.)
  – 
“The penalty of success is to be bored by people who used to snub you.”
 
*
Honore de Balzac (20 May 1799 – 18 Aug 1850; was a French novelist and playwright. The novel sequence 
La Comédie Humaine, which presents a panorama of post-Napoleonic French life, is generally viewed as his magnum opus.)
  
– “Laws are spider webs through which the big flies pass and the little ones get caught.”
 
Monday is pun day:
* Two birds are sitting on a perch and one says “Do you smell fish?”
* What’s it called when you have too many aliens? Extraterrestrials.
* Want to hear a pizza joke? Never mind, it’s too cheesy.

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

EN_a320
. Are Your Copies of Regulations Up to Date?
(Source: Editor)

 

*
DHS CUSTOMS REGULATIONS: 19 CFR, Ch. 1, Pts. 0-199.  Implemented by Dep’t of Homeland Security, U.S. Customs & Border Protection.

  – Last Amendment: 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: 14 May 2019: 84 FR 21233-21238: 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 
 
* DOC FOREIGN TRADE REGULATIONS (FTR): 15 CFR Part 30.  Implemented by Dep’t of Commerce, U.S. Census Bureau.
  – Last Amendment: 24 Apr 2018: 83 FR 17749-17751: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates
  – HTS codes that are not valid for AES are available here.
  – The latest edition (1 Jan 2019) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR contains all FTR amendments, FTR Letters and Notices, a large Index, and approximately 250 footnotes containing case annotations, practice tips, Census/AES guidance, and explanations of the numerous errors contained in the official text. Subscribers receive revised copies in Microsoft Word every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance website.  BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR. Government employees (including military) and employees of universities are eligible for a 50% discount on both publications at www.FullCircleCompiance.eu.   

 

DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM): DoD 5220.22-M. Implemented by Dep’t of Defense.
  – Last Amendment: 18 May 2016: Change 2: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and cancelled Supp. 1 to the NISPOM (Summary here.)
 
 
DOE ASSISTANCE TO FOREIGN ATOMIC ENERGY ACTIVITIES: 10 CFR Part 810; Implemented by Dep’t of Energy, National Nuclear Security Administration, under Atomic Energy Act of 1954.
  – Last Amendment: 23 Feb 2015: 80 FR 9359, comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. This rule also identifies destinations with respect to which most assistance would be generally authorized and destinations that would require a specific authorization by the Secretary of Energy.
 
DOE EXPORT AND IMPORT OF NUCLEAR EQUIPMENT AND MATERIAL; 10 CFR Part 110; Implemented by Dep’t of Energy, U.S. Nuclear Regulatory Commission, under Atomic Energy Act of 1954.
  – Last Amendment: 20 Nov 2018, 10 CFR 110.6, Re-transfers.
 

* DOJ ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War.  Implemented by Dep’t of Justice, Bureau of Alcohol, Tobacco, Firearms & Explosives.
  – Last Amendment: 14 Mar 2019: 84 FR 9239-9240: Bump-Stock-Type Devices 

 

DOS INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130. Implemented by Dep’t of State, Directorate of Defense Trade Controls.
  – Last Amendment: 19 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: 13 May 2019:
Harmonized System Update (HSU) 1907 

  – HTS codes for AES are available here.

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

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

EN_a0321
Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

Review last week’s top Ex/Im stories in “Weekly Highlights of the Daily Bugle Top Stories” published  
here

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

EPEDITORIAL POLICY

* 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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