19-0826 Monday “Daily Bugle”

19-0826 Monday “Daily Bugle”

Monday, 26 August 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

  1. Justice/ATF Seeks Comments on Application to Transport Interstate of Temporarily Export Certain Firearms
  2. State Imposes Additional Sanctions on Russia
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. CRS: “The International Emergency Economic Powers Act: Origins, Evolution, and Use”
  4. DHS/CBP Releases Harmonized System Update 1914
  5. State/DDTC: (No new postings.)
  6. Singapore Customs Releases New Circular
  1. HPN: “CBP, LA Law Enforcement Seize more than 52,000 Gun Parts from China”
  2. Reuters: “China’s July Venezuela Oil Imports Fall over U.S. Sanctions”
  3. SCMP: “China Merchants Bank Shares Tumble as Investors Fear Escalating Trade War could Lead to U.S. Sanctions”
  1. C.N. Stinebower, C.B. Monahan & A.M. Solorzano: “Unique Challenges for U.S. Companies After New Designation of the Government of Venezuela”
  2. M. Miller, B. Murphy & S. Murray: “President Trump to Increase China Section 301 Duty Rates”
  1. Monday List of Ex/Im Jobs: 142 Openings Posted This Week; 15 New Openings
  1. ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar in Amsterdam
  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 (21 Aug 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 (6 Aug 2019), HTSUS (13 Aug 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


EXIM_a11Justice/ATF Seeks Comments on Application to Transport Interstate of Temporarily Export Certain Firearms

(Source: Federal Register, 26 Aug 2019.) [Excerpts.]
84 FR 44636-44637: Agency Information Collection Activities; Proposals, Submissions, and Approvals:
Application to Transport Interstate or Temporarily Export Certain National Firearms Act Firearms
* AGENCY: Bureau of Alcohol, Tobacco, Firearms and Explosives, Department of Justice.
* ACTION: 30-Day notice.
* SUMMARY: The Department of Justice (DOJ), Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), will submit the following information collection request to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act of 1995.
* DATES: The proposed information collection was previously published in the Federal Register, on June 21, 2019, allowing for a 60-day comment period. Comments are encouraged and will be accepted for an additional 30 days until September 25, 2019.
* FOR FURTHER INFORMATION CONTACT: If you have additional comments, particularly with respect to the estimated public burden or associated response time, have suggestions, need a copy of the proposed information collection instrument with instructions, or desire any other additional information, please contact: James Chancey, National Firearms Act Division either by mail at 244 Needy Road, Martinsburg, WV 25405, by email at nfaombcomments@atf.gov, or by telephone at 304-616-4500. Written comments and/or suggestions can also be directed to the Office of Management and Budget, Office of Information and Regulatory Affairs, Attention Department of Justice Desk Officer, Washington, DC 20503 or sent to OIRA_submissions@omb.eop.gov.
* SUPPLEMENTARY INFORMATION: Written comments and suggestions from the public and affected agencies concerning
the proposed collection of information are encouraged. Your comments should address one or more of the following four points:
– Evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility;
– Evaluate the accuracy of the agency’s estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used;
– Evaluate whether and if so how the quality, utility, and clarity of the information to be collected can be enhanced; and
– Minimize the burden of the collection of information on those who are to respond, including through the use of appropriate automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses. …
* * * * * * * * * * * * * * * * * * * * 

EXIM_a22. State Imposes Additional Sanctions on Russia

(Source: Federal Register, 26 Aug 2019.) [Excerpts.]
84 FR 44671-44672: Imposition of Additional Sanctions on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act
* AGENCY: State Department, Bureau of International Security and Nonproliferation
* SUMMARY:On August 6, 2018, a determination was made that the Russian government used chemical weapons in violation of international law or lethal chemical weapons against its own nationals. Notice of this determination was published on August 27, 2018 in the Federal Register, under Public Notice 10519, which resulted in sanctions against Russia. Section 307(B) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act), requires a decision within three months of August 6, 2018 regarding whether Russia has met certain conditions described in the law. Additional sanctions on Russia are required if these conditions are not met. The Secretary of State decided on November 2, 2018 that Russia had not met the CBW Act’s conditions and decided to impose additional sanctions on Russia on March 29, 2019.
* DATES:This determination is effective on August 26, 2019.
* FOR FURTHER INFORMATION CONTACT:Pamela K. Durham, Office of Missile, Biological, and Chemical Nonproliferation, Bureau of International Security and Nonproliferation, Department of State, Telephone (202) 647-4930.
* SUPPLEMENTARY INFORMATION:Pursuant to Section 307(b) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991, as amended (22 U.S.C. Section 5604(a) and Section 5605(a)), on March 29, 2019 the Secretary of State decided to impose additional sanctions on Russia. …

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


OGS_a13. Items Scheduled for Publication in Future Federal Register Editions

(Source: Federal Register, 26 Aug 2019.)

* State/DDTC: NOTICES; List of Entities and Subentities Associated with Cuba (Cuba Restricted List) [Pub. Date: 27 Aug 2019.] 

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

Commerce/BIS: (no new postings.) 


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

CRS: “The International Emergency Economic Powers Act: Origins, Evolution, and Use”

Congressional Research Service, 1 Aug 2019.) [Excerpts.] 
Summary of 66-page report:  
The International Emergency Economic Powers Act (IEEPA) provides the President broad authority to regulate a variety of economic transactions following a declaration of national emergency. IEEPA, like the Trading with the Enemy Act (TWEA) from which it branched, sits at the center of the modern U.S. sanctions regime. Changes in the use of IEEPA powers since the act’s enactment in 1977 have caused some to question whether the statute’s oversight provisions are robust enough given the sweeping economic powers it confers upon the President upon declaration of a state of emergency.
Over the course of the twentieth century, Congress delegated increasing amounts of emergency power to the President by statute. The Trading with the Enemy Act was one such statute. Congress passed TWEA in 1917 to regulate international transactions with enemy powers following the U.S. entry into the First World War. Congress expanded the act during the 1930s to allow the President to declare a national emergency in times of peace and assume sweeping powers over both domestic and international transactions. Between 1945 and the early 1970s, TWEA became the central means to impose sanctions as part of U.S. Cold War strategy. Presidents used TWEA to block international financial transactions, seize U.S.-based assets held by foreign nationals, restrict exports, modify regulations to deter the hoarding of gold, limit foreign direct investment in U.S. companies, and impose tariffs on all imports into the United States.
Following committee investigations that discovered that the United States had been in a state of emergency for more than 40 years, Congress passed the National Emergencies Act (NEA) in 1976 and IEEPA in 1977. The pair of statutes placed new limits on presidential emergency powers. Both included reporting requirements to increase transparency and track costs, and the NEA required the President to annually assess and extend, if appropriate, an emergency. However, some experts argue that the renewal process has become pro forma. The NEA also afforded Congress the means to terminate a national emergency by adopting a concurrent resolution in each chamber. A decision by the Supreme Court, in a landmark case, however, found the use of concurrent resolutions to terminate an executive action unconstitutional. Congress amended the statute to require a joint resolution, significantly increasing the difficulty of terminating an emergency. Like TWEA, IEEPA has become an important means to impose economic-based sanctions since its enactment; like TWEA, Presidents have frequently used IEEPA to restrict a variety of international transactions; and like TWEA, the subjects of the restrictions, the frequency of use, and the duration of emergencies have expanded over time. Initially, Presidents targeted foreign states or their governments. Over the years, however, presidential administrations have increasingly used IEEPA to target non-state individuals and groups, such as terrorists and persons who engage in malicious cyber-enabled activities. 
As of August 1, 2019, Presidents had declared 56 national emergencies invoking IEEPA, 31 of which are still ongoing.
Typically, national emergencies invoking IEEPA last nearly a decade, although some have lasted significantly longer—the
first state of emergency declared under the NEA and IEEPA, which was declared in response to the taking of U.S. embassy
staff as hostages by Iran in 1979, may soon enter its fifth decade.
IEEPA grants sweeping powers to the President to control economic transactions. Despite these broad powers, Congress has never attempted to terminate a national emergency invoking IEEPA. Instead, Congress has directed the President on 
numerous occasions to use IEEPA authorities to impose sanctions. Congress may want to consider whether IEEPA
appropriately balances the need for swift action in a time of crisis with Congress’ duty to oversee executive action. Congress may also want to consider IEEPA’s role in implementing its influence in U.S. foreign policy and national security decision-making. …
Read remainder of report

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

DHS/CBP Releases Harmonized System Update No. 1914

DHS/CBP, 26 Aug 2019.)
Harmonized System Update (HSU) Number 1914 was created on August 13, 2019 and contains 531 ABI records and 94 harmonized tariff records.
System modifications were made to support the Office 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 was published on July 31, 2019 in the Federal Register, Vol. 84, No. 147, page 37381, and can be retrieved via the link below…
Changes were also made to support the Office 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 issued on August 7, 2019. The Notice can be found in the Federal Register, Vol. 84, No. 152, page 38717 or by using the link below…

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

State/DDTC: (No new postings.)


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

Singapore Customs Releases New Circular

Singapore Customs, 26 Aug 2019.)
Singapore Customs has released the following document(s) on its website:

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


HPN: “CBP, LA Law Enforcement Seize more than 52,000 Gun Parts from China”

Homeland Preparedness News, 26 Aug 2019.) [Excerpts.]
Customs and Border Protection (CBP) authorities said a Los Angeles / Long Beach Seaport law enforcement collaboration recently resulted in the seizure of 52,601 illegal firearms parts.
The shipment, which violated the Chinese Arms Embargo, was intercepted with the aid of the Machinery Center of Excellence and Expertise (CEE) and the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). …
CBP personnel referred the items to ATF investigators, who confirmed the firearm parts were in violation of the Arms Export Control Act and International Traffic in Arms Regulations (ITAR), 27 CFR 447.52.

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

Reuters: “China’s July Venezuela Oil Imports Fall over U.S. Sanctions”

Reuters, 25 Aug 2019.) [Excerpts.]
China’s crude oil imports from Venezuela plunged 62% in July from the previous month, Chinese customs data showed on Sunday, as growing tension between Washington and the Maduro government made buyers wary of taking oil from the South American exporter. …
Venezuela’s oil exports fell 17.5% in July to their second-lowest since Washington imposed the sanctions in January, according to internal data from the company and Refinitiv Eikon. 
China National Petroleum Corp, a leading buyer of Venezuelan oil, has halted loadings in August amid concerns over potential hits by the secondary sanctions. …

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

SCMP: “China Merchants Bank Shares Tumble as Investors Fear Escalating Trade War could Lead to U.S. Sanctions”

South China Morning Post, 26 Aug 2019.) [Excerpts.]
Shares of China Merchants Bank (CMB), a blue-chip stock in Hong Kong, tumbled on Monday, with investors shying away from risky assets that could face further headwinds as the trade war between China and the United States escalates once again. …
A more important reason behind Monday’s decline is that most foreign investors are bearish about the Hang Seng Index for the whole year, and CMB has a higher beta among banking chips – essentially moving with a bigger band when the benchmark index moves, Chen added. …

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


COM_a112C.N. Stinebower, C.B. Monahan & A.M. Solorzano: “Unique Challenges for U.S. Companies After New Designation of the Government of Venezuela”

(Source: Winston & Strawn LLP, 22 Aug 2019.)
* Authors: Cari N. Stinebower, Esq., cstinebower@winston.com, +1 202 282 5788, Christopher B. Monahan, Esq., cmonahan@winston.com, +1 202 282 5778, Alexandra M. Solorzano, Esq., asolorzano@winston.com, +1 202 282 5748, all of Winston & Strawn LLP.
After the publication on August 5, 2019, of the new Executive Order (E.O.) 13884 – “Blocking Property of the Government of Venezuela,” which blocks all property and interests in property from the Government of Venezuela, U.S., and foreign companies have struggled to interpret its scope. That struggle has led many to submit specific license applications or requests for interpretative guidance from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).
In particular, the new sanctions prohibiting U.S. companies from dealing with the Government of Venezuela also contain a large number of general licenses -similar to those provided in other, more comprehensive embargo programs. The scope of the general licenses has been the subject of practitioners and industry debate as they try to determine the limits of such authorizations. For example, General License 28 (GL 28) “Authorizing Certain Activities Necessary to the Wind Down of Operations or Existing Contracts Involving the Government of Venezuela” is narrowly written in comparison with other wind down licenses issued under the Ukraine-Russia related sanctions program, including, General License 5 authorizing the divestiture or transfer to a foreign person of the U.S. person’s share of ownership, and General Licenses 14-E15-F, and 16E, authorizing transactions ordinarily incident and necessary to the maintenance of operations, contracts or other agreements. GL 28 is, rather, limited to the transactions that relate to the wind-down of operations and does not specifically mention authorization to engage in transactions for the maintenance of such contracts.
In addition, U.S. companies have experienced challenges with accomplishing a total wind-down of Venezuela-related operations involving the Government within the time limit imposed by GL 28 (i.e.through 12:01 a.m. eastern daylight time, September 4, 2019.)
Another major challenge for U.S. companies is the lack of a broad general license authorizing all activities (otherwise prohibited) that are ordinarily incident and necessary to conduct the activities authorized by general licenses. The lack of this general license, normally available in other sanctions regimes, limits the usefulness of some of the newly issued and revised general licenses because many U.S. persons cannot conduct authorized transactions without dealing with the Government of Venezuela for transactions incident to the authorized activity (e.g., dealing with the Government of Venezuela for the payment of taxes, request of permits, etc.). This is also the case for U.S. companies dealing exclusively with the private sector in Venezuela because the government presence is such that most of the transactions – even if purely private- involve certain dealings or interactions with the government.
Finally, U.S. persons – even if dealing exclusively with the private sector in Venezuela – are prohibited from making payments into government-owned banks, which account for the majority of the financial sector in Venezuela. These banks have not been specifically designated by OFAC, but operate as what is sometimes referred to as a ‘Shadow-Specially Designated Nationals (SDNs)’ per the application of the 50% ownership rule and based on the new E.O.’s definition of the Government of Venezuela. Consistent with prior OFAC guidance, newly issued OFAC Frequently Asked Questions (FAQs) regarding Venezuela sanctions reiterate that financial institutions should conduct its own customer due diligence – including identifying ownership structure – to ensure that none of the parties involved in a transaction are SDNs. U.S. companies and financial institutions will therefore have to block and report such payments.
U.S. companies facing these, and several other challenges as a result of the new sanctions, need to have answers and may need additional authorization or specific guidance from OFAC. Many must do so before the license expires to wind-down operations involving the Government of Venezuela on September 4th.

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

M. Miller, B. Murphy & S. Murray: “President Trump to Increase China Section 301 Duty Rates”

Miller & Company P.C., 23 Aug 2019.) [Excerpts.]
* Authors: Marshall Miller, Esq.,
mmiller@millerco.com, Brian Murphy, Esq.,
bmurphy@millerco.com, Sean Murray, Esq.,
smurray@millerco.com, all of Miller & Company P.C.
On August 23, 2019, President Trump issued 
tweets stating that (1) duty rates for China Section 301 Lists 1, 2, and 3 will increase from 25% to 30% beginning on October 1, 2019, and (2) China Section 301 List 4A duty rates scheduled to be imposed on September 1, 2019 will be 15% rather than 10%.  There is no mention at this time of an increase of the 10% duty rate on China Section 301 List 4B goods scheduled to go into effect December 15, 2019.
President Trump’s tweets follow China’s 
announcement that it will impose tariffs on $75 billion in U.S. goods in two batches on September 1 and December 15, 2019 in retaliation for the imposition of U.S. duties on $300 billion of China goods covered by Lists 4A and 4B. …
The USTR has indicated it will announce a China Section 301 List 4 exclusion 
process. …

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


MS_a114. Monday List of Ex/Im Job Openings: 142 Openings Posted This Week, Including 15 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; Alameda, CA; Customs, Trade and Compliance Analyst

* Accenture; Dublin, Ireland; Trade Compliance – Legal Associate Manager; Requisition ID: 00748516
* AeroPrecision; Tacoma, WA; Export Compliance Assistant
* Agility; Boston, MA; Import/Entry Writer Coordinator

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

* Arris; Suwanee, GA; Mgr. Trade Compliance; Requisition ID: 19000992

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

* BAE Systems; Arlington, VA; Director International Trade and Compliance/Senior Counsel; Requisition ID: 52758BR

* BAE Systems; Arlington, VA; International Trade Manager I (Compliance); Requisition ID: 52578BR

* Baker Hughes; Houston, TX;
Trade Compliance Classification Analyst
; Requisition ID: 1919330

* BASF; Mannheim, Germany; Manager Global Export Control; Requisition ID: EN57992009_ONLE_1

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

* Brunel; Halifax, Canada;
Export Compliance Specialist
; Requisition ID: PUB227372

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

* Cargill; Jakarta, Indonesia; Global Trade Operations & Compliance 
* Cobham Advanced Electronic Solutions; Exeter, NH; 
Export Compliance Administrator
; Requisition ID: req2614

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

* Comtech EF Data; Tempe, AZ or Germantown, MD; Vice President Compliance; Requisition ID: 2503

* Curtiss-Wright; Cheswick, PA; Sr. Manager, Global Trade ComplianceKirsty.harris@curtisswright.com; Requisition ID: 5272 
* 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
* Eaton; Aguascalientes, Mexico; Logistics and Trade Compliance Senior Analyst; Requisition ID: 076166

* Eaton; Peachtree City, GA; Director of Trade Compliance

* 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

* EOS Defense Systems USA; Huntsville; AL; 
Intermediate Level Compliance Analyst 
* EOS Defense Systems USA; Huntsville, AL; 
Senior Compliance Officer 

* Epiroc; Garland, TX;
Americas Trade Compliance Manager

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

* Expeditors; Rozenburg, the Netherlands; Import en Export control medewerker 
* Fircroft; Telford, United Kingdom; Export Controller

* 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; 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

* Google LLC; Mountain View, CA;
Associate Export Compliance Counsel 

*Harris Corporation; Amityville, NY; Trade Compliance Senior Specialist; Requisition ID: ES20191207-32075
*Harris Corporation; Cincinnati, OH; Export Compliance Officer; Requisition ID: 108642
* Harris Corporation; Rochester, NY; Senior Trade Compliance Specialist (ITAR & EAR); Requisition ID: CS20192404-31068 

* 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  

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

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

* 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
* Johnson Controls; Milwaukee, WI;
Director, Global Trade Compliance
; Requisition ID: WD30055791295;
* Koch Chem Tech; Tulsa, OK;
Import/Export Compliance Specialist
; Requisition ID: 052017
* 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

* Levi Strauss & Co.; San Francisco, CA; Trade Compliance Specialist, Process Documentation & Education
* Lexacount; Denver, CO; Trade Sanctions and Compliance Associate

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

* Lockheed Martin Aeronautics; Arlington, VA;
International Licensing Analyst; Requisition ID:
* Lockheed Martin Aeronautics; Fort Worth, TX; Global Trade Compliance Analyst; Requisition ID:
* Lockheed Martin Aeronautics; Fort Worth, TX; International Trade Compliance Empowered Official; Requisition ID:

* Lockheed Martin Aeronautics; Fort Worth, TX; International Trade Compliance Intern; Requisition ID:

* Lockheed Martin Aeronautics; Fort Worth; Senior Export Control Specialist; Requisition ID:

* 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;
Columbia Hights, MN; Associate Export Controls Analyst;
Requisition ID:

* 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; Simi Valley;
Trade Compliance Coordinator
; Requisition ID: 39407
* Merck; Shanghai, China;
Trade Compliance Specialist
; Requisition ID: 193935

* Miller Canfield; Troy, MI; Corporate Attorney – International Trade; brennans@millercanfield.com 
* Momentus; Santa Clara, CA; Regulatory Compliance Specialist

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

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

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

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

* NIKE Inc.; Beaverton, OR;
North America Customs Compliance Manager
; Requisition ID: 00455981

* Northop Grumman; Linthicum, MD; Principal International Due Diligence Analyst; Requisition ID: 19025076

* Ormco; Amersfoort, the Netherlands; EMEA Trade Compliance Specialist

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

* 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; Andover, MA; Global Trade (GT) Licensing Manager And Empowered Official; Requisition ID:
* Raytheon; Andover, MA; Andover, MA; Global Trade (GT) Licensing Manager And Empowered Official; Requisition ID:

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

* Raytheon; Tuscon, AZ;
Empowered Official
; Requisition ID: 137311BR
* Raytheon; Tuscon, AZ;
Empowered Official
; Requisition ID: 141847BR

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

* 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: JR6052906

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

* Sandvik; Amsterdam, The Netherlands; Process Support Specialist Trade Compliance And Freight  

* SAP; Newtown Square, PA; Export Control – Senior Specialist; Requisition ID: 226489

* Sarepta Therapeutics; Cambridge, MA;
Director, Logistics & Global Trade Compliance   
* Saudi Aramco; Dhahran, Saudi Arabia;
; Requisition ID: 17184BR

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

* Sierra Nevada Corporation; Arlington, VA; International Trade Compliance Analyst II; Requisition ID: R0007996

* Solvay; Brussels, Belgium; Global Trade Specialist; Requisition ID: 950  

* Solvay; Princeton, NJ and Alpharetta, GA; Customs Expert; Requisition ID: 9474

* 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

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

* Thomas Jones Consulting; Washington, DC;
Jr. International Trade, Export Controls & Economic Sanctions Associate  
* Tiffany & Co; Parsippany, NJ; Director, Trade & Logistics – Americas

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

University of California; San Francisco, CA;
Export Control Officer
; Requisition ID: 51010;

* University of Pittsburgh; Pittsburgh, PA; Biological Import Specialist; Requisition ID: 19004979

* Velocity Electronics; Singapore; Trade Compliance Specialist

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

* Vodafone; Bucharest, Romania;
Legal Sanctions and Trade Analyst
; Requisition ID: 258811

* Walmart; Bentonville, AR; Analyst II, Specialty Compliance and Ethics, Export; Requisition ID: R-38186

* Walmart; Bentonville, AR; Temporary Analyst, Global Sanctions;
Requisition ID:

* 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  
* Yaskawa; Eschborn, Germany; Zoll & Export Control Specialist EMEA 

back to top 

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


TE_a115. ECTI Presents United States Export Control (ITAR/EAR/OFAC) Seminar in Amsterdam

(Source: Jill Kincaid;
* What: United States Export Control (ITAR/EAR/OFAC) Seminar Series in Amsterdam, The Netherlands (for EU and other non-US Companies)
* When: ITAR Seminar: Sep 30-Oct 1, 2019; EAR/OFAC Seminar: Oct 2-3, 2019
* Where: Amsterdam, Hilton Amsterdam Hotel; Apollolaan 138, 1077 BG, Amsterdam, The Netherlands
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speaker Panel: Scott Gearity, Greg Creeser, Stephan Müller
* Register
, or email
Jessica Lemon
, 540-433-3977.

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

TE_a216. 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.

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


Bret Harte (Francis Brett Hart; 25 Aug 1836 – 5 May 1902; was an American short-story writer and poet, best remembered for his short fiction featuring miners, gamblers, and other romantic figures of the California Gold Rush.)

“Never a tear bedims the eye that time and patience will not dry.”

Mother Teresa (Mary Teresa Bojaxhiu, born Anjezë Gonxhe Bojaxhiu; 26 Aug 1910 – 5 Sep 1997; honored in the Roman Catholic Church as Saint Teresa of Calcutta, was an Albanian-Indian nun and missionary.)

“We think sometimes that poverty is only being hungry, naked and homeless. The poverty of being unwanted, unloved and uncared for is the greatest poverty. We must start in our own homes to remedy this kind of poverty.”

Monday is pun day.

* I got a new pair of gloves today, but they’re both ‘lefts’ which, on the one hand, is great, but on the other, it’s just not right.

* I bought some shoes from a drug dealer. I don’t know what he laced them with, but I’ve been tripping all day!

* Goodbye boiled water. You will be mist!

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

. 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: 21 August 2019: 84 FR 43493-43501: Addition of Certain Entities to the Entity List and Revision of Entries on the Entity List and 84 FR 43487-43493: Temporary General License: Extension of Validity, Clarifications to Authorized Transactions, and Changes to Certification Statement Requirements 


: 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.
* 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: 6 August 2019: 84 FR 38545 – August 2019 Amendments to Iranian Financial Sanctions Regulations and Iranian Human Rights Abuses Sanctions Regulations [amendment of 31 CFR Parts 561 and 562.] 

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 Aug 2019: 
Harmonized System Update (HSU) 1914 
  – HTS codes for AES are available 
  – HTS codes that are not valid for AES are available 

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

Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

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

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


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

* TO UNSUBSCRIBE: Use the Safe Unsubscribe link below.

Scroll to Top