19-0722 Monday “Daily Bugle'”

19-0722 Monday “Daily Bugle”

Monday, 22 July 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 

inquiries and rates

[No items of interest today.]
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. DHS/CBP Posts Harmonized System Update (HSU) 1913
  4. Justice: “Vicksburg Felon Sentenced to Almost 6 Years in Federal Prison for International Gun Trafficking Conspiracy and Illegally Possessing Firearms”
  1. Defense News: “Limits on Western Arms Exports Helped Spur Indigenous Saudi and UAE Defense Industry”
  2. WorldECR: “EU Court Annuls Yanukovych Sanctions”
  1. A.B. Kerr & S.J. Ettinger: “Do’s and Don’ts When Diversifying Manufacturing Operations”
  2. American Shipper: “Exporters’ Input ‘Valuable’ to BIS”
  3. K.C. Georgi, M.M. Hassoun & R.K. Alberda: “Reforming US Secondary Sanctions – What’s Wrong That Can Be Righted?”
  1. Monday List of Ex/Im Job Openings: 137 Openings Posted This Week; 20 New Openings
  1. ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar Series in Austin, TX
  2. FCC Presents “U.S. Export Controls: 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 (27 Jun 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 (5 Jun 2018), HTSUS (22 Jul 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


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OGS_a11. Items Scheduled for Publication in Future Federal Register Editions

(Source: Federal Register, 22 Jul 2019.)

* President; ADMINISTRATIVE ORDERS; Transnational Criminal Organizations; Continuation of National Emergency [Pub. Date: 23 Jul 2019.]
* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Pub. Date: 23 Jul 2019.]
* Treasury/OFAC; RULES; Global Terrorism Sanctions Regulations; Transnational Criminal Organizations Sanctions Regulations; and Hizballah Financial Sanctions Regulations [Pub. Date: 23 Jul 2019.]

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. Commerce/BIS: (No new postings.)
(Source: Commerce/BIS) 
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DHS/CBP Posts Harmonized System Update (HSU) 1913

(Source: CSMS #39000771, 22 Jul 2019.)
Harmonized System Update (HSU) 1913 was created on July 21, 2019 and contains 113 ABI records and 23 harmonized tariff records.
Modifications include those made as a result of the United States Trade Representative’s (USTR) Notice of Product Exclusions: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property and Innovation. The Notice can be found in the Federal Register, dated July 9, 2019: Vol. 84, No. 131, Page 32831 or via the link.
Per the Agricultural Marketing Service (AMS), changes were also made to frozen mangos.   They are now included, as a covered commodity, under the Mango Promotion, Research and Information Order, effective July 22, 2019. The final rule can be found in the Federal Register, dated February 21, 2019: Vol. 84 No. 35, Page 5335. You may also access it by using the link.
Adjustments required by the verification of the 2019 Harmonized Tariff Schedule (HTS) are also included.
The modified records are currently available to all ABI participants and can be retrieved electronically via the procedures indicated in the CATAIR. For further information about the retrieval process, please contact your client representative.
All other questions regarding this message, please contact Jennifer Keeling via email.

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Justice: “Vicksburg Felon Sentenced to Almost 6 Years in Federal Prison for International Gun Trafficking Conspiracy and Illegally Possessing Firearms”
(Source: Justice, 18 Jul 2019.) [Excerpts.]
Jackson, Miss. – Maurice Taylor, 33, of Vicksburg, was sentenced today to 70 months in federal prison, followed by three years of supervised release, for conspiring to violate the Arms Export Control Act and being a convicted felon in possession of a firearm, …  
Taylor was also ordered to pay a $2,500 fine.
Maurice Taylor carried out a scheme in which he shipped stolen firearms from Mississippi to a co-conspirator in London, England. He prepared two separate packages containing stolen firearms concealed within children’s toys, and mailed the packages to London, in violation of the Arms Export Control Act. DNA evidence confirmed that Taylor, who is a convicted felon, was one of the people who handled the firearms. The firearms had been stolen days earlier during a burglary of a pawn shop in Natchez, Mississippi. Taylor texted with his co-conspirator messages and photographs of the guns he would mail, and received back from London confirmation numbers for wired payments for the guns, through a mobile phone application. After the London Metropolitan Police arrested Taylor’s partner, the LMP seized his phone and several firearms from his car. Evidence of the communications and the electronic payments were retrieved from the co-conspirator’s phone.
Taylor pled guilty on March 28, 2019 to conspiracy to violate the Arms Export Control Act and possession of a firearm by a convicted felon. He has prior felony convictions for burglary and grand larceny in Sharkey County, Mississippi.  …

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Defense News: “Limits on Western Arms Exports Helped Spur Indigenous Saudi and UAE Defense Industry”

(Source: Defense News, 22 Jul 2019.) [Excerpts.]
Western concerns about making military technology transfers to the United Arab Emirates and Saudi Arabia may have led to greater reliance on indigenous military technologies in the conflict in Yemen, and experts expect those investments to continue to grow.
It’s a slow but potentially important shift in how the regional powers – historically major buyers of Western military goods – approach arming themselves.
The UAE and Saudi Arabia will have an increased concentration on local military production as part of a broader diversification of sources, said Wehbe Katicha, a former Lebanese general who is now a member of Parliament.
“As the threat posed by Iran increases, especially in [the] Hurmuz Strait, Gulf countries are more likely to increase their armament through many sources,” Katicha noted. “They will not move out [from] the USA ‘umbrella,’ but producing ammunitions and armored vehicles locally is one of the options to overcome sanctions.”

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WorldECR: “EU Court Annuls Yanukovych Sanctions”

(Source: WorldECR, Jul 2019.) [Excerpts.]
The General Court of the European Union, has, in a series of joint cases, annulled asset-freezes against what it described as ‘seven members of the former Ukrainian ruling class, including Viktor Yanukovych [pictured], former President of Ukraine.’
In an explanatory document, the court said that the Council of the European Union had frozen the funds in March 2014, in response to the crisis in Ukraine at the time, with the Council describing the seven at that time as having been “responsible for the misappropriation of Ukrainian state funds,” on the grounds that they were “subject to criminal proceedings in Ukraine to investigate crimes in connection with the embezzlement of Ukrainian State funds and their illegal transfer outside Ukraine.”  …

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A.B. Kerr & S.J. Ettinger: “Do’s and Don’ts When Diversifying Manufacturing Operations”

(Source: K&L Gates LLP, 19 Jul 2019.) [Excerpts.]

* Authors: Anthony B. Kerr, Esq., Tony.Kerr@klgates.com, + 65 6713 0203; Stacy J. Ettinger, Esq., Stacy.Ettinger@klgates.com, +1 202 778 9072, both of K&L Gates LLP.
To date, the United States has imposed tariffs on US$250 billion worth of Chinese-made products while China has imposed retaliatory tariffs on US$110 billion worth of U.S.-produced goods.
Manufacturers in China and the United States are facing hard choices, whether to absorb the additional tariff costs or to pass those costs onto their customers (and, eventually, the consumers). A large number of companies have chosen to diversify and relocate all or part of their manufacturing operations to countries outside of China and the United States. Of course, not all moves away from China are the result of the additional U.S. tariffs; the rapidly increasing cost of doing business in China has been a major push factor. The additional U.S. tariffs have just accelerated boardroom decisions to diversify manufacturing operations.
Many tech companies are already moving all or part of their operations out of China to countries such as Taiwan, Malaysia, Japan, and Vietnam. Vietnam appears to be the most popular destination for many companies. 

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American Shipper: “Exporters’ Input ‘Valuable’ to BIS”

(Source: American Shipper, 19 Jul 2019.) [Excerpts.]
A former Commerce Department official in charge of export controls during the Obama administration told the Senate Banking Committee on Thursday that to ensure these regulations remain impactful and do not harm the economy requires continuous interaction with exporters for their insights and feedback on proposed regulations.
“In the seven years that I did on export control reform, I found the input from industry extraordinarily valuable,” Eric Hirschhorn, who served as undersecretary of commerce and industry at the Commerce Department from April 2010 to January 2017, told members of the Senate Banking Committee.
“The Commerce Department and its sister agencies put forth proposed regulations and said to industry, “How does this work? Does this work for you? Is it too broad? Are we catching things that are sold every day all over the world? Are we leaving things out that we ought to control?'”
President Barrack Obama mandated in August 2009 that the mostly Cold War-era U.S. export controls, which are administered by the Commerce, State and Defense departments, be updated to reflect current national security threats and economic realities.  …

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K.C. Georgi, M.M. Hassoun & R.K. Alberda: “Reforming US Secondary Sanctions – What’s Wrong that Can Be Righted?”

(Source: WorldECR, July 22, 2019) [Excerpts.]
* Authors: Kay C. Georgi, Esq., kay.georgi@arentfox.com, +1 202 857 6293; Marwa M. Hassoun, Esq., marwa.hassoun@arentfox.com, +1 213 443 7645;  and Regan K. Alberda, Esq., regan.alberda@arentfox.com, +1 202 775 5771; all of Arent Fox LLP.
In a nutshell, US secondary sanctions are the sanctions that the United States can apply to wholly non-US actors in wholly non-US transactions of which the US administration disapproves. Numerous statutory and executive orders provide authority for imposing secondary sanctions for transactions involving multiple countries, primarily Iran, Russia, North Korea and Venezuela, and involving a wide range of activities, including violating human rights. Many of these authorities include the ‘nuclear option’ of placing the sanctioned individual or entity on the SDN list. None of these authorities include a well-defined numerical threshold for imposing sanctions, with many requiring sanctions for ‘significant transactions’ or providing ‘material support’. The US administration has identified many persons and entities for sanctions or placed them on the SDN list under these authorities. So what’s wrong with this? We do not want to debate the goals of economic sanctions or whether they are preferable to the use of military force, but only to identify some problems with the application of secondary sanctions:
   1) The triggers for secondary sanctions are unclear: What is a ‘significant transaction’? OFAC’s FAQ 542 tells us: ‘OFAC will consider the following list of seven broad factors that can assist in the determination of whether a transaction is “significant”: (1) the size, number, and frequency of the transaction(s); (2) the nature of the transaction(s); (3) the level of awareness of management and whether the transaction(s) are part of a pattern of conduct; (4) the nexus between the transaction(s) and a blocked person; (5) the impact of the transaction(s) on statutory objectives; (6) whether the transaction(s) involve deceptive practices; and (7) such other factors that the Secretary of the Treasury deems relevant on a case-by-case basis.
   2) There’s no one to ask. Non-US persons who are not subject to US jurisdiction cannot apply to OFAC for a license. And while OFAC tries to answer questions posed to its compliance hotline, it is a small department and there are understandably a lot of people asking questions. Additionally, the guidance from one OFAC representative is not generally binding upon OFAC itself.
   3) Secondary sanctions are actually imposed in a discriminatory fashion. This is not intended as a criticism: it takes time and money to build up a file supporting the imposition of secondary sanctions. Even a fully-funded sanctioning authority cannot possibly keep up and decisions on whom to target must be made. 
   4) Placing a person or an entity on the SDN list is a nuclear option. It is not merely a question of doing business with Iran or doing business with the United States. Indeed, an entity on the SDN List will have problems doing business in its own country, due to risk-averse positions taken by banks and other companies, which have only been exacerbated by the risk of secondary sanctions. We know of one company that was almost bankrupt by the time it was removed from the SDN list, and that company had minimal US business. 
   5) There often is no warning. In many cases, the US government has reportedly reached out to the non-US company or government and said, ‘Hey, what you are doing is lining you up for secondary sanctions, cut it out.’ It has certainly been warning the Turkish and Indian governments not to purchase the Russian S400 missile system. But SDN blocking sanctions are effective only if imposed with no warning at all. So the individuals and companies that are placed on the SDN list often wake up in the morning to find their assets have been blocked. 
   6) Getting off the SDN list is very difficult and takes time and resources. In some cases, parties cannot be removed from the list for a particular period of time. Often parties end up hiring US counsel in order to facilitate their removal from the SDN list. 
   7) Secondary sanctions do not usually trigger standard force majeure clauses. Non-US companies cannot tell customers that they cannot perform binding contracts because the United States has imposed secondary sanctions: they are not legally compelled to comply with US secondary sanctions laws. 
   8) Secondary sanctions commercially favor the non-compliant. When companies that do not wish to trigger secondary sanctions find some means to step aside, the companies who step in are those that do not care about US foreign policy or the US market. So does this have to be the case? We think not – some possible solutions might be:
(1) Adopt clear and high thresholds for investments and transactions, and clear descriptions of conduct.
(2) Provide clearer guidance to non-US. parties. If the Department of Commerce can develop a decision tree for ‘specially designed’ why can’t something similar be done in the sanctions area?
(3) Require secondary sanctions be applied to investments and transactions above a certain amount, no matter the actor.
(4) Do not require the secondary sanctions to be SDN sanctions. There are many sanctions options that bite but do not put a company or individual out of business.
(5) Provide fair warning to the target and allow it to change its course. If the purpose of the sanctions is to change conduct, this is key.
(6) Provide a clear path for the removal of secondary sanctions. If you agree to X, you are removed from the SDN List.
(7) Provide a written warning of impending sanctions that the target can use to try to get out of the problematic contract, if applicable. Having a written statement from a government authority can help companies to exit contracts. Doing so will ensure that less compliant companies do not benefit from the discriminatory application of secondary sanctions by engaging in the very conduct the United States wishes to discourage. …

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MS_a110. Monday List of Ex/Im Job Openings: 153 Openings Posted This Week, Including 6 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; Orlando, FL;
Senior Compliance Analyst 
* Accenture; Buenos Aires, Argentina;
Contract Analyst – Trade Compliance 
Agility; Houston, TX;
Ocean Export Team Leader  

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

* AMAG Pharmaceuticals; Waltham, MA;
Associate, Logistics & Trade Compliance
; Requisition ID: 1386
* American Showa, Inc.; Columbus, OH;
Trade Compliance Specialist
; LoAnn Burt, 
* Arris; Suwanee, GA; Mgr. Trade Compliance; Requisition ID: 19000992

* Arrowhead Products; Los Alamitos, CA; Trade Compliance Specialist

* Ascend Materials; Houston, TX; Principal International Trade Compliance Specialist; Requisition ID: R0000954 

* Bose; Framingham, MA; Senior Customs & Trade Compliance Lead; Requisition ID: R12731

* Brunel; Halifax, Canada; Manager, Export Compliance; Requisition ID: PUB218296

Bunn-O-Matic Corporation; Springfield, IL;
Global Logistics Specialist
; Brenda Porschart; Requisition ID: 2019-1588

* Cargill; Jakarta, Indonesia; Global Trade Operations & Compliance

* Cisco Systems, Inc.; Charlotte, NC;
Trade Compliance Manager
; Requisition ID: 1261937
* Cisco Systems, Inc.; San Jose, CA or Research Triangle Park, NC; Customs Project Manager / Business Analyst; Requisition ID: 1263171
* Cloudflare; Austin, TX, San Francisco, CA, Washington D.C.; International Trade Compliance Manager 

* Cobham Advanced Electronic Solutions; Hauppauge, NY or Plainview, NY; Export Compliance Administrator; Requisition ID: req2484

* CommScope; Suzhou, China; Specialist, Import & Export

* Danaher – Leica Microsystems; Wetzlar, Germany; Chief Compliance Officer; Requisition ID: LEI004530

* DHL; Singapore; Trade Compliance Manager APAC; Requisition ID: req74719  

* Domino Printing; Cambridge, United Kingdom;
Trade Compliance Manager; Requisition ID: 001

* Elbit Systems of America; Merrimack, NH; Audit and Compliance Specialist; Requisition ID: 2019-7095

* Engenium; Orlando, FL;
Import/Export Compliance Specialist  
* Epiroc; Garland, TX;
Americas Trade Compliance Manager

* ePlus; Herndon, VA; Senior Manager Trade Compliance; Requisition ID: SENIOo2880

* Expeditors; Bedfont, United Kingdom;
Customs Brokerage Clerk 
* Expeditors; Romulus, MI; US Export Compliance Consultant

* Expeditors; Rozenburg, the Netherlands; Import en Export control medewerker 
* Flexport; Amsterdam, the Netherlands;
Regional Compliance Manager 

* FLIR; Arlington, VA; Director, Global Export Compliance Americas; Requisition ID: REQ12624 
* FLIR; Arlington, VA; Global Trade Compliance (GTC) Program Manager; Requisition ID: REQ12249

* FLIR; Billerica, MA; Global Trace Compliance – Site Trade Compliance Operations Leader; Requisition ID: REQ11588
* FLIR; Elkridge, MD and Nashua, NH; Import/Export Analyst, Global Trade Compliance; Requisition ID: REQ12529
* FLIR; Hong Kong, Shanghai, China, Singapore; Director, Global Export Compliance Asia Pacific; Requisition ID: REQ12630
* FLIR; Täby, Sweden; Director, Global Export Compliance EMEA; Requisition ID: REQ12627  

* Fluke Electronics; Everett, WA;
Trade Compliance Analyst 

* 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;
Import/Export Administrator
; Requisition ID: 24614BR

* Grass Valley; Newbury, United Kingdom; Logistics and Trade Compliance Manager; Requisition ID: 1094

* Harris Corporation; Van Nuys, CA; Trade Compliance Senior Specialist; Ramone Mellis; Requisition ID: ES20192103-30606

* Harvey John; Frankfurt am Main, Germany; Export Controls and Customs Manager; Requisition ID: JR6806
* Harvey John; Frankfurt am Main, Germany; Global Customs & Trade – Legal Counsel; Requisition ID: JR6805  
* 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

* Illumina; Great Abington, United Kingdom; Compliance Specialist; Requisition ID: 18249-JOB
* Illumina; San Diego, CA; Compliance Manager; Requisition ID: 18197-JOB

* Illumina; Woodlands, Singapore;
Staff Trade Compliance Analyst
; Requisition ID: 16691-JOB

Infineon Technologies, El Segundo, CA;
Senior Export Compliance Specialist
; Requisition ID: 31215;
* Integra LifeSciences; Plainsboro, NJ;
Import/Export Compliance Specialist
; Requisition ID: 2019-29346

* Itron; Raleigh, NC; Sr Manager Information Security – Audit and Compliance; Requisition ID: 1901000

* ITW; Norwood, MA;
Export Compliance Officer 

* Izpal Corporation; Bangkok, Thailand; Assistant Import/Export Manager

* Jaguar Land Rover; Shannon, Ireland;
Trade Compliance Specialist
; Requisition ID: 35602

* Johnson Controls; Milwaukee, WI;
Director, Global Trade Compliance
; Requisition ID: WD30055791295;
* Kelley Drye & Warren LLP; Washington DC;
Junior Export Controls/Sanctions Associate 
* Koch Chem Tech; Tulsa, OK;
Import/Export Compliance Specialist
; Requisition ID: 052017
* Kubota; Grapevine, TX;
Manager, Import & Export Compliance
; Requisition ID: 228
* Leidos; Columbia, MD;
International Trade Manager / Export Compliance
; Requisition ID: R-00005745;
* Lenovo; Guandong, China; AP Trade Compliance Specialist; Requisition ID: 73183

* Leonardo DRS; Melbourne, FL; 
Senior Manager, Trade Compliance
; Requisition ID:  94784

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

* Lexacount; Washington DC; Export Controls Associate; Requisition ID: 6522

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

* Lockheed Martin Aeronautics; Palmdale, CA;
Export Compliance Site Lead
; Requisition ID: 488546BR

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

* Lufthansa; Bremen, Germany;
Praktikant im Bereich Compliance Monitoring Management 
* Lufthansa; Frankfurt am Main, Germany;
Manager Compliance 
* Lufthansa; Neu-Isenburg, Germany;
Praktikum im Bereich Operational Compliance International 

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

* Medline Industries Inc.; Northfield, IL;
Customs Compliance Manager 

* Meggitt; Erlanger, KY;
Trade Compliance Specialist
; Requisition ID: 39460
* Meggitt; Fareham, United Kingdom;
Trade Compliance Officer
; Requisition ID: 39513
* Meggitt; Miami, FL;
Trade Compliance Coordinator
; Requisition ID: 40009
* Meggitt; Simi Valley;
Trade Compliance Coordinator
; Requisition ID: 39407
* Merck; Shanghai, China;
Trade Compliance Specialist
; Requisition ID: 193935

* Mercury Systems; Andover, MA; Corporate and Compliance Counsel; Requisition ID: 19-419

* Micron Technology; Xi’an, China; Logistics Import/Export Specialist I; Requisition ID: 135498

* Miller Canfield; Troy, MI; Corporate Attorney – International Trade; brennans@millercanfield.com

* Morson Group; Glasgow, UK; Export Control Officer Investigations

* NCR Corporation; Atlanta, GA; Export Compliance Analyst; Requisition ID: R0083245

* Netflix; Los Angeles, CA;
Specialist, Trade Compliance

* Northrop Grumman, Falls Church, VA, Int’l Trade Compliance Analyst 4, Requisition ID: 19010228

* Northrop Grumman; Falls Church, VA; USG International Policy Manager; Requisition ID: 19015251 
* Northrop Grumman; Redondo Beach, CA, San Diego, CA or Melbourne, FL; 
Sr. International Trade Compliance Analyst
; Requisition ID: 19013440
* Northrop Grumman Innovation Systems; Dulles, VA;
Sr. Principal International Trade Compliance Analyst
; Requisition ID: 19015953

* Philips; Amsterdam or Eindhoven, the Netherlands; Business Process Owner Trade Compliance Dangerous Goods; Requisition ID: 319231

* Pier1; Fort Worth, TX; Senior Manager Supply Chain & Trade Compliance; Requisition ID: 2019-20859

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

* PolyOne, Avon Lake, OH; Trade Compliance Analyst 

* Plexus Corp.; Neenah, WI; Global Trade Compliance Manager; Jillian Schooley; Requisition ID: R001823
* Plexus Corp.; Neenah, WI; Trade Compliance Analyst Sr.; Jillian Schooley; Requisition ID: R001823 

* Raytheon; Arlington, VA; Sr Attorney Trade Compliance; Requisition ID: 143388BR

* Raytheon, Cambridge, MA; Manager – Global Trade Licensing; Requisition ID: 142549BR
* Raytheon, Cambridge, MA; Sr Global Trade Licensing Analyst; Requisition ID: 139427BR

* Raytheon; Tuscon, AZ;
Empowered Official
; Requisition ID: 142045BR

* Raytheon; Tuscon, AZ;
Export Licensing and Compliance Specialist
; Requisition ID: 143962BR

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

* Royal Bank of Scotland; London, United Kingdom;
Sanctions Analyst Manager
; Requisition ID: 91139

* Rockwell Automation; Mayfield Heights, OH and Milwaukee, WI;
Senior Analyst, Import/Export Compliance
; Requisition ID: 85004BR
* SABIC; Houston TX; 
Senior Analyst, Trade Compliance
; Requisition ID: 8411BR

* Sandvik; Amsterdam, The Netherlands; Process Support Specialist Trade Compliance And Freight 
* Sandvik; Svedala, Sweden; Trade Compliance Officer; Requisition ID: R0011161

* Sarepta Therapeutics; Cambridge, MA;
Director, Logistics & Global Trade Compliance   
* Saudi Aramco; Dhahran, Saudi Arabia;
; Requisition ID: 17184BR
* Siemens; Hamburg, Germany;
Senior Export Control Expert 

* Siemens; Munich, Germany; Intern Regulatory Compliance; Requisition ID: 116687

* Siemens; Sacramento, CA;  
Custom Trade & Compliance Professional
; Requisition ID: 244347

* Sierra Nevada Corporation; Arlington, VA;
International Trade Compliance Analyst II
; Requisition ID: R0007996
* Sierra Nevada Corporation; Louisville, CO; International Trade Compliance Analyst Senior; Requisition ID: R0008390 
* SIG SAUER, Inc.; Newington, NH;
Director of Trade Compliance
; Requisition ID: 1114

* SIG SAUER, Inc.; Newington, NH; Jr. Analyst Trade Compliance; Requisition ID: req67

* Signify; Somerset, KY;
Trade Compliance Manager (Import/Export/Security)
; Requisition ID: 287174

* Solvay; Lyon, France;
SBS Export Compliance Expert
; Requisition ID: 9374

* Sun Chemical; Cincinnati, OH, Northlake, IL, Parsippany, NJ;
Global Trade Compliance Specialist
; Requisition ID: 2019-2733
* Synopsys Inc.; Remote, U.S.;
Director, Global Trade Compliance
; Requisition ID: 20358BR

* Teledyne Technologies; Englewood, CO, Lincoln, NE, Omaha, NE; Customs Compliance Manager; Requisition ID: 2018-8144

* Texas Tech University; Lubbock, TX;  
Program Manager Export Compliance
; Bill Wells, 
; Requisition ID: 17536BR

* Thales; Stuttgart, Germany;
Trade Compliance Spezialist (M/W/D)
; Requisition ID: R0054290
* Thermo Fisher Scientific; Franklin, MA; Sr. Trade Compliance Analyst; Requisition ID: 90074BR

* Thermo Fisher Scientific; Fremont, CA; Manager, Global Trade Compliance

* Thermo Fisher Scientific; Pittsburgh, PA;
Global Trade Compliance Specialist II
; Requisition ID: 99248BR

* Torres Law, PLLC; Dallas, TX; 
Import/Export Consultant-Legal

* United Technologies – Collins Aerospace; Cedar Rapids, IA;
Export Licensing Specialist (ITC)
; Requisition ID: 01311691
University of California; San Francisco, CA;
Export Control Officer
; Requisition ID: 51010;

* University of Colorado Boulder; Boulder, CO; Director for the Office of Export Controls; Requisition ID: 19419

* Velocity Electronics; Singapore; Trade Compliance Specialist

* Viasat; Carlsbad, CA;
Global Trade Analyst
; Requisition ID: 2824
* Vigilant GTS; Remote Position, U.S.;
Global Trade Compliance Account Manager  
* Virgin Orbit; Long Beach, CA; Sr Counsel, Compliance Attorney; Requisition ID: 2019-5516
* Walmart; Bentonville, AR; Analyst II, Specialty Compliance and Ethics, Export; Requisition ID: R-38186

* Walt Disney; Kissimmee, FL;
Trade Compliance Analyst (Project Hire)
; Requisition ID: 654599BR
* Wealth Ocean; Newport Beach, CA;
Marketing & International Trade Specialist  
* World Wide Technology; Edwardsville, IL; International Trace Compliance Specialist; Requisition ID: 19-0772

* World Wide Technology; Edwardsville, IL;
International Trade Compliance Supervisor
; Requisition ID: 19-0795
* XPO Logistics; Greenwich, CT;
Compliance Paralegal 
* XPO Logistics; Greenwich, CT;
Director, Trade Compliance Counsel 
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TE_a111. ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar Series in Austin, TX

(Source: Jill Kincaid; jill@learnexportcompliance.com)
* What: United States Export Control (ITAR/EAR/OFAC) Seminar Series in Austin, TX
* When: ITAR Seminar: September 16-17, 2019; EAR/OFAC Seminar: Sept 18-19, 2019
* Where: Austin, TX: Hilton Garden Inn Austin Downtown
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel: Scott Gearity and Melissa Proctor
* Register here, or email Jessica Lemon, 540-433-3977.

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TE_a212. 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 pricing deals.

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* Ernest Hemingway
(Ernest Miller Hemingway; 21 Jul 1899 – 2 Jul 1961; was an American journalist, novelist, short-story writer, and sportsman. His economical and understated style-which he termed the iceberg theory-had a strong influence on 20th-century fiction. Hemingway won the Nobel Prize in Literature in 1954. He published seven novels, six short-story collections, and two non-fiction works. Three of his novels, four short-story collections, including The Sun Also Rises, For Whom the Bell Tolls, A Farewell to Arms, To Have and Have Not, and The Old Man and the Sea.)
– “There is nothing noble in being superior to your fellow men. True nobility lies in being superior to your former self.”
* Emma Lazarus
(22 Jul 1849 – 19 Nov 1887; was an American author of poetry, prose, and translations, as well as a political activist. She wrote the sonnet “The New Colossus” in 1883, which includes lines of world-wide welcome. Its lines appear inscribed on a bronze plaque on the pedestal of the Statue of Liberty, installed in 1903, a decade and a half after Lazarus’s death.)
– “Give me your tired, your poor, your huddled masses yearning to breathe free.”
Monday is pun day:
* As I suspected, someone has been adding soil to my garden. The plot thickens.
* How do crazy people go through the forest? They take the physco path.
* What did the traffic light say to the car? Don’t look! I’m changing.

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


The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments to applicable regulations are listed below.

: 19 CFR, Ch. 1, Pts. 0-199.  Implemented by Dep’t of Homeland Security, U.S. Customs & Border Protection.
  – Last Amendment: 5 Apr 2019: 
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: 27 June 2019:
84 FR 30593-30595: Revisions to the Unverified List 


: 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 

  – The latest edition (4 Jul 2019) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR is a 152-page Word document containing 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 
.  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 


: 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 

: 10 CFR Part 810; Implemented by Dep’t of Energy, National Nuclear Security Administration, under the 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.

; 10 CFR Part 110; Implemented by Dep’t of Energy, U.S. Nuclear Regulatory Commission, under the 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

: 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: 4 Jul 2019) of the ITAR with all amendments is contained in 
Bartlett’s Annotated ITAR 
(“BITAR”), by James E. Bartlett III. The BITAR is a 371-page Word document containing 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 download, usually revised within 24 hours after every ITAR amendment. The BITAR is available by annual subscription from the Full Circle Compliance 
. BAFTR subscribers receive a $25 discount on subscriptions to the BITAR. Please 
contact us
 to receive your discount code.
: 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders.
Implemented by Dep’t of Treasury, Office of Foreign Assets Control.
  – Last Amendment: 5 June 2019:
84 FR 25992
– June 2019 Amendments to the Cuban Assets Control Regulations [amendment of 31 CFR Part 515]

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: 22 July 2019: 
Harmonized System Update (HSU) 1913  
  – HTS codes for AES are available 
  – HTS codes that are not valid for AES are available 

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Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

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

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* The Ex/Im Daily Update is a publication of FCC Advisory B.V., compiled by: Editor, James E. Bartlett III; and Assistant Editors, Alexander Witt and 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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