19-0729 Monday “Daily Bugle'”

19-0729 Monday “Daily Bugle”

Monday, 29 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. State (No new postings.)
  4. Treasury/OFAC Amends Venezuela-related General License
  1. Courier-Post: “Williamstown Woman Admits Guilt to Night-Vision Smuggling Scheme”
  2. ST&R Trade Report: “Increase in Tariff Enforcement Actions Highlights Importance of Compliance”
  1. A. Sreekumar: “Transforming India into a Defence Export Powerhouse [Part II of II]”
  2. Bloomberg Law: “Economic Sanctions and Export Controls Update Q2 2019”
  3. C. Hamilton: “Australian Universities Must Wake Up to the Risks of Researchers Linked to China’s Military”
  1. Monday List of Ex/Im Job Openings: 146 Openings Posted This Week; 26 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 2019), DOT/FACR/OFAC (24 July 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, 29 Jul 2019.)

* President; EXECUTIVE ORDERS; Mali; Blocking Property and Suspending Entry of Certain Persons (EO 13882) [Pub. Date: 30 July 2019.]
* Treasury/OFAC; NOTICES; Blocking or Unblocking of Persons and Properties [Pub. Date: 30 July 2019.]

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. Commerce/BIS: (No new postings.)
(Source: Commerce/BIS) 
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State/DDTC: (No new postings.)
(Source: State/DDTC)

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Treasury/OFAC Amends Venezuela-related General License

(Source: Treasury/OFAC, 26 July 2019.)
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is publishing amended Venezuela-related General License 8B, “Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for Maintenance of Operations for Certain Entities in Venezuela.”

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Courier-Post: “Williamstown Woman Admits Guilt to Night-Vision Smuggling Scheme”

(Source: Courier-Post, 29 July 2019.) [Excerpts.]
A Williamstown woman has admitted her role in a scheme to smuggle night-vision military gear to China.
Yuankai Yang conspired with at least two other people to buy night-vision goggles and other equipment from American companies and then ship the items to China, according to the U.S. Attorney’s Office for New Jersey.
Yang and the unnamed co-conspirators, who were all Chinese citizens, did not have an export license required for the defense items, the federal prosecutor’s office said.
Yang, who identified herself as a “Wall mart” employee in a court filing, allegedly received almost $210,000 in wire transfers from China for the purchase of night vision equipment between October 2015 and April 2018.
Authorities allege Yang also recruited American citizens to provide driver’s licenses in an effort to dupe sellers into believing the technology would not be exported. …

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ST&R Trade Report: “Increase in Tariff Enforcement Actions Highlights Importance of Compliance”

(Source: Sandler, Travis & Rosenberg Trade Report, 29 July 2019.)
U.S. Customs and Border Protection reports that there was a significant increase in its efforts to enforce trade remedies and other laws in 2018, highlighting some of the risk factors importers need to be aware of and the importance of taking compliance measures to mitigate them.
CBP’s trade and travel report states that in fiscal year 2018 the agency collected about $52 billion in tariffs, taxes, and other fees, including more than $40.6 billion in tariffs, an increase of nearly 23 percent over FY 2017. CBP states that much of this increase is attributable to the Section 201 safeguards on washing machines, washing machine parts, and solar cells and panels; the Section 232 tariffs on steel and aluminum goods; and the Section 301 tariffs on imports from China. As of Dec. 19, 2018, CBP had assessed nearly $527 million in Section 201 tariffs, more than $1.1 billion in Section 232 aluminum tariffs, more than $3.4 billion in Section 232 steel tariffs, and more than $8 billion in Section 301 tariffs on goods from China.
(Click here to access ST&R’s on-demand webinar on avoiding the pitfalls of Section 232 and 301 tariff liability.)
Also in FY 2018 CBP began enforcing 53 new antidumping and/or countervailing duty orders, bringing the total number of orders in effect to 469 and the value of imports subject to those orders to $24.2 billion. To enforce these orders, which has long been a priority for the agency, CBP (a) levied more than $92.1 million in monetary penalties on importers for fraud, gross negligence, and negligence with respect to AD/CV violations, (b) conducted entry summary reviews that resulted in the recovery of more than $65.5 million in AD/CV duties owed, (c) identified through audits approximately $25 million in AD/CV duties owed (with $2.5 million collected to date), and (d) seized shipments with a domestic value of more than $1.3 million for AD/CV violations.
Finally, CBP saw an increase in activity under the Enforce and Protect Act to combat the evasion of AD/CV duty orders on products such as aluminum extrusions, plywood, hangers, pencils, bedroom furniture, steel flanges, and diamond sawblades. CBP received 33 allegations under EAPA from interested parties in FY 2018, nearly doubling the amount from the previous year. CBP also took interim measures in six EAPA investigations and issued final determinations in 12, up from one in FY 2017. CBP states that during the past two years it has initiated 20 EAPA investigations; conducted 18 onsite verifications in Thailand, Vietnam, China, Malaysia, Cambodia, and the Philippines; and prevented the evasion of $50 million in AD/CV duties annually.

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A. Sreekumar: “Transforming India into a Defence Export Powerhouse [Part II of II]”

(Source: Frost & Sullivan, 25 July 2019.)
* Author: Arjun Sreekumar, Senior Consultant at Frost & Sullivan.
Selling the Solution Mix, Not the Product-Lessons from Turkey
Winning a defence contract abroad and making a presence in the global market is a tricky issue, especially for new market entrants such as India. While the product mix is mostly related to technical and operational capabilities where tried, tested and established defence primes hold sway in both brand and performance, it is in the solution mix that a new entrant seeking to establish a brand can make that difference. The solution mix is an extension of the defence product made up of ancillary and support mechanisms to make the buying nation’s acquisition and operation of the product easier. Many potential Second-World and Third-World markets are on the lookout for a solution mix that Indian companies can dovetail into their export offerings.
Defence OEMs such as ASELSAN in Turkey and various state-owned corporations in China are linked to financiers that provide loans with flexible payment schedules. The financial support (often state-sponsored or brokered) built into the solution mix is a key factor that enabled those OEMs to expand their presence in African, Central Asian and Latin American markets. Further, ancillary actions such as including extended maintenance and support contract provisions; having a fully operational, dedicated backend support system for the equipment sold; and bundling periodic trainings (especially because many potential markets have field conscripts or have high churn rates) are all factors that could influence a procurement decision.
Pragmatic, Long-term Strategy and Decision-making Support-Lessons from the US and China
Though the overall trend in defence spending usually exhibits an upward trajectory, a factor that some governments and newer defence companies tend to overlook is that this spending is cyclic. There are crests fueled by new procurement, replenishment or modernization drives and troughs as procurement ceases to give way to sustainability and maintenance contracts. Therefore, rather than have a “one-size-fits-all” strategy to promote exports, it has to be one that is based on the life cycles of platforms and subsystems. Adopting such a scientific approach and meshing it with the target markets’ defence budget, geopolitics, macroeconomics, indigenous industrial strengths and shortcomings provides a better picture of market potential and accessibility.
Using this approach, it is possible to understand that not every prospective high-revenue market is accessible and not every country with a relatively smaller defence budget should be written off in a firm’s business plan. It is also imperative to assess accessible market potential over a longer timeframe because of the high gestation periods of defence programs and to take into account future procurement that has not reached the initiation “project imitation” stage. This is because to win export contracts, defence companies need to be invested in the market way before the opportunity actually manifests itself. The adopted strategy should be forward-looking. As the Indian government is gearing up to promote defence exports in 85 nations by giving defence attachés a business development budget, it may bode well for the government to consider the aforementioned factors and devise a more pragmatic long-term strategy to ensure that business development budgets and expertise are funneled to the markets with the highest potential, and so should the nation’s private sector.
It may also be worthwhile for the Indian government to provide a country-specific analysis on the market potential of target countries, prospective partners, market-specific defence equipment demand and the process of exports. The US government has a dedicated website (export.gov) that details processes and revenue potential and helps guide US companies. Replicating this approach may be well received by the Indian defence industry, especially for tier 2 and tier 3 manufacturers and MSMEs, which cannot spend a lot in due diligence and business growth consultancy. Toward this end, the Indian government should consider investing in expert market intelligence.
In terms of business expansion strategy, Indian defence firms may benefit from a method China adopted to grow its defence business. China started by making inroads into markets that Western OEMs neglected or were blocked due to International Trade in Arms Regulations (ITAR)-related sanctions. This nation has slowly expanded its customer base by spreading its net wide, focusing on a large number of smaller-value contracts as opposed to major ones that Western OEMs often pursue. Broader market adoption of defence equipment can help build the brand, provided the quality of equipment meets customer requirements. Such a “market-skimming” approach could be suitable for Indian defence companies. This approach should not exclude smaller nations, which may not prima facie seem to be worthwhile defence markets. For example, the small nation of Trinidad & Tobago has procured naval radar upgrades and low tonnage naval vessels over the past three years with companies like Kelvin Hughes, Damen and Austal catering to the island nation’s demand. There are Indian companies that already have the capability and capacity to cater to such requirements; they just need to adopt and implement a long-term, incisive market expansion strategy.
Leveraging Geopolitical Exigencies-Lessons from China
Unexpected opportunities arise due to the strong interconnection between geopolitics and the defence industry. The Indian defence industry needs to be positioned to react quickly to such opportunities, and regulatory agencies must facilitate capitalization of such opportunities in mission mode as they are often short term but could be of high value. Chinese OEMs leveraged several crises in the Middle East to push their CH-4 and Wing Loong Unmanned Aerial Systems to nations such as Saudi Arabia and the United Arab Emirates at a time when Western options were not available to these countries. China seized the opportunity at the right time with a good-fit solution. An adaptable defence export policy should have built-in, fast-track approval policies so that domestic OEMs can capitalize on unexpected emerging opportunities.
Active & Passive Governmental Support – Lessons from the US and France
Successful defence OEMs have strong governmental backing as defence sales tend to be a subset of foreign policy. Governments can promote exports actively and passively. The Turkish government has actively contributed to the development of joint ventures and collaborative agreements between Turkish defence industry players and other non-Turkish defence companies to secure contracts. A case in point is RBSS (a three-way, Turkey-based joint venture between BMC, Germany’s Rheinmetall and Malaysia’s Etika ), which is gunning for contracts in the Middle East and Asia-Pacific. Other similar “active” examples are France and the US, where the government sketches out a country-specific agenda for defence exports during high-profile foreign policy visits. This active mode of promoting defence exports becomes increasingly important today as many governments pursue collaborative development of defence programs; in such cases, governmental linkages with participating nations may be necessary as a precursor to industry linkages.
Major defence exporters also use “passive” methods to popularize defence technology where defence trade does not overtly figure in bilateral or multilateral agendas. This is carried out through joint trainings, military exercises and operations with militaries in target markets where they are exposed to new equipment. The US military participated in over 130 exercises from 2013-2017. Over 75% of these exercises where with operatives from six major US defence export markets. Similar corollaries may be drawn in the case of France as well (this was demonstrated during the Varuna Naval exercise with India, where the naval version of the Dassault Rafale took part). The best promoter of defence equipment is not always a dedicated business development executive, but a military operator demonstrating the equipment in action.
As the incumbent Indian government embarks on a second term, it has reiterated its commitment to the vision of transforming India into a defence net exporter. This is achievable but will require crafted visioning, policy construction and governmental support in the right areas. Carving a niche for India in this highly competitive industry is difficult. Success in this sector is about getting many interlinked factors right, which isn’t easy, but the history of defence exports is replete with case studies, best practices and examples from which we can learn what is best adopted and what needs to be discarded. The nation will have to streamline processes, build dedicated institutions, train and retrain its diplomatic assets and adopt a concerted and pragmatic go-to-market strategy after taking into account the Indian industry’s strengths, weaknesses and global upcoming opportunities. The key takeaway here is the nation’s gambit has to be well-planned, long-sighted and smart to build its mark in defence exports. The government and industry should make their moves based on actionable intelligence and need to be ready for concerted market action and dialogue. Results may take time to manifest, but the accruing benefit makes the investment worthwhile.

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Bloomberg Law: “Economic Sanctions and Export Controls Update Q2 2019”

(Source: Bloomberg Law, 29 July 2019.) [Excerpts.]
Several important legislative, regulatory, and enforcement updates took place related to economic sanctions and export controls for the second quarter of 2019. Kirkland & Ellis attorneys discuss these actions, and what they may indicate about trends and takeaways in the second half of 2019.
The View from Washington: Key Compliance Takeaways
The Department of the Treasury Office of Foreign Assets Control (OFAC) continued to build on its heightened Q1 enforcement efforts, bringing 13 settlement and penalty actions against non-U.S. financial institutions, as well as U.S. and non-U.S. companies across a wide array of industries including shipping, software, and e-commerce travel.
OFAC issued A Framework for Compliance Commitments (the Framework), which formally puts companies on notice of its expectations with respect to an effective economic sanctions compliance program (SCP). Notably, OFAC expressly indicated that it would take into account whether a company maintains an effective SCP in determining what penalties to impose in the event of violations.
OFAC’s action quickly followed the U.S. Department of Justice’s (DOJ) publication of its Evaluation of Corporate Compliance Programs guidance, indicating marked interagency attention and coordination in corporate enforcement actions and an increased government-wide focus on national security and foreign policy-related cases.
With respect to export controls, the U.S. Department of Commerce Bureau of Industry and Security’s (BIS) placement of Huawei Technologies Co. Ltd. (Huawei) on the Entity List coupled with the president’s issuance of the Executive Order on Securing the Information and Communications Technology and Services Supply Chain (the Executive Order), would seem to raise the stakes of the trade war and reflect increasing strategic competition between the U.S. and China. …

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C. Hamilton: “Australian Universities Must Wake Up to the Risks of Researchers Linked to China’s Military”
(Source: The Conversation, 18 July 2019.) [Excerpts.]
* Author: Clive Hamilton, Professor of Public Ethics, Charles Sturt University, chamilton@csu.edu.au.
Two Australian universities, University of Technology Sydney and Curtin University, are conducting internal reviews of their funding and research approval procedures after Four Corners’ revealed their links to researchers whose work has materially assisted China’s human rights abuses against the Uyghur minority in Xinjiang province.
UTS, in particular, is in the spotlight because of a major research collaboration with CETC, the Chinese state-owned military research conglomerate. In a response to Four Corners, UTS expressed dismay at the allegations of human rights violations in Xinjiang, which were raised in a Human Rights Watch report earlier this year.
Yet, UTS has been aware of concerns about its collaboration with CETC for two years. When I met with two of the university’s deputy vice chancellors in 2017 to ask them about their work with CETC, they dismissed the concerns.
According to a report for the Jamestown Foundation, CETC openly declares that its purpose is “leveraging civilian electronics for the gain of the PLA (People’s Liberation Army).” Similar concerns had been raised about CETC’s military links and its work with the CSIRO. …

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MS_a110. Monday List of Ex/Im Job Openings: 146 Openings Posted This Week, Including 26 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 
Agility; Houston, TX;
Ocean Export Team Leader   
* Airbus; Blagnac, France; Export Control and Compliance Legal Counsel; Requisition ID: 10465602 FV EXT 1
* Airbus; Bremen, Germany; Export Compliance Manager; Requisition ID: 10465262 SZ DE EXT 1
* Airbus; Manching, Germany; Export Compliance Officer; Requisition ID: 10456130 NK EN EXT 3

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

* 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  

* BAE Systems; Arlington, VA; Director International Trade and Compliance/Senior Counsel; Requisition ID: 52758BR
* BASF; Mannheim, Germany; Manager Global Export Control; Requisition ID: EN57992009_ONLE_1
* BNZ; Wellington, New Zealand; Senior Sanctions Analyst; Requisition ID: 122322

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

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

* CACI; Chantilly, VA; Trade Compliance Analyst; Requisition ID: 223627_20151

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

* Cisco Systems, Inc.; Charlotte, NC;
Trade Compliance Manager
; Requisition ID: 1261937

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

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

* Danaher – SCIEX; Framingham, MA; Senior Manager Global Trade Compliance; Requisition ID: SCI003363

* 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

* Elbit Systems of America; Merrimack, NH; Senior Manager, Trade Compliance; Requisition ID: 2019-7120

* 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  
* Fortive; Irvine, CA; Global Trade Compliance Analyst; Requisition ID: ADV000243

* 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

* 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
* Hitachi Vantara; Singapore;
Trade Compliance Analyst
; Requisition ID: 1003050 (026187)
* Honeywell; Paris, France;
Export Compliance Lead
; Requisition ID: HRD60078

* HRL Laboratories, LLC; Malibu, CA, Trade Compliance Specialist; Requisition ID: #95

* Illumina; Great Abington, United Kingdom; Compliance Specialist; Requisition ID: 18249-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  

* Irving; Halifax, Canada; Export Compliance Specialist; Requisition ID: 19003115

* 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;
* Koch Chem Tech; Tulsa, OK;
Import/Export Compliance Specialist
; Requisition ID: 052017
* 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;
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; Frankfurt am Main, Germany; Director Operations Compliance & Administration

* Lufthansa; Frankfurt am Main, Germany;
Manager Compliance 
* Lululemon; British Columbia, Canada; Analyst, Global Trade Compliance; Requisition ID: 030738

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

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

* Medtronic; Sao Paulo, Brazil; Import/Export Coord III; Requisition ID: 19000C9M

* 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

* Microsoft; Dublin, Ireland; Export Control Manager; Requisition ID: 660530

* 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 Innovation Systems; Dulles, VA;
Sr. Principal International Trade Compliance Analyst
; Requisition ID: 19015953

* Paraxel; Quakertown, PA; Global Trade Compliance Coordinator; Requisition ID: 53257BR

* 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; Trade Compliance Analyst Sr.; Jillian Schooley; Requisition ID: R001823 

* Raytheon; Andover, MA; Manager III SC Compliance;
Requisition ID: 142917BR

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

* 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; Louisville, CO; International Trade Compliance Analyst Senior; Requisition ID: R0008390 

* 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; Lisbon, Portugal; Customs & Trade Control Operations officer – Customs classification; Requisition ID: 9203
* Solvay; Princeton, NJ and Alpharetta, GA; Customs Expert; Requisition ID: 9474
* STS Technical Services; Greensboro, NC; Trade Compliance Specialists; Requisition ID: 48411

* 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; Bordeaux, France; Trade Compliance Manager (H/F); Requisition ID: R0062904
* Thales; Brest, France; Export Control Manager (H/F); Requisition ID: R0069297

* 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 Pittsburgh; Pittsburgh, PA; Biological Import Specialist; Requisition ID: 19004979
* Valio; Helsinki, Finland; Quality Manager, Export

* 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  
* 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   
* Wilton Brands; Naperville, IL; Customs Compliance Manager 
* 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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* Alexis de Tocqueville
(Alexis Charles Henri Clérel, Viscount de Tocqueville; 29 July 1805 – 16 April 1859) was a French diplomat, political scientist and historian. He was best known for his works Democracy in America and The Old Regime and the Revolution. Democracy in America was published after Tocqueville’s travels in the United States and is today considered an early work of sociology and political science.)
  – “Democracy and socialism have nothing in common but one word, equality. But notice the difference: while democracy seeks equality in liberty, socialism seeks equality in restraint and servitude.”
  – “The American Republic will endure until the day Congress discovers that it can bribe the public with the public’s money.”
Monday is pun day:

* Why wouldn’t the shrimp share his treasure? Because he was a little shellfish.
* What did one hat say to the other? You stay here. I’ll go on ahead.
* I just wrote a book on reverse psychology. Do NOT read it!

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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: 23 July 2019: 84 FR 35307 – July 2019 Amendments to Global Terrorism Sanctions Regulations; Transnational Criminal Organizations Sanctions Regulations; and Hizballah Financial Sanctions Regulations [amendment of 31 CFR Parts 566, 590, and 594.]

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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