19-0916 Monday “Daily Bugle”

19-0916 Monday “Daily Bugle”

Monday, 16 September 2019

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

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  1. Treasury/OFAC Issues Directive Concerning Economic Sanctions on Russia
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)
  3. State/DDTC: (No new postings.)
  4. EU Adopts New Decision on the Control of Arms Exports
  1. Bloomberg: “U.S. Semiconductor Companies Urge Trump to Hurry Huawei Licenses”
  2. Forbes: “Feds Demand Apple and Google Hand Over Names of 10,000+ Users of a Gun Scope App”
  3. Haaretz: “Police Arrest Workers of Israeli Cyber Group Ability on Suspicion They Violated Defense Export Law”
  4. Washington Post: “UN Votes to Ease Arms Embargo on Central African Republic”
  1. Safety at Sea: “Sanctions Main Cause for Concern in Maritime Insurance Market”
  1. Monday List of Ex/Im Jobs: 144 Openings Posted This Week; 19 New Openings
  1. ECTI Presents Export Control and IT Modernization – Issues and Considerations Webinar: October 1, 2019
  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 (30 Aug 2019), DOT/FACR/OFAC (9 Sep 2019), HTSUS (3 Sep 2019) 
  3. Weekly Highlights of the Daily Bugle Top Stories 


EXIM_a11. Treasury/OFAC Issues Directive Concerning Economic Sanctions on Russia

(Source: Federal Register, 16 Sep 2019.) [Excerpts.]
84 FR 48704-48705: Issuance of Russia-Related Directive Pursuant to Executive Order 13883 of August 1, 2019
* AGENCY: Office of Foreign Assets Control, Treasury.
* ACTION: Issuance of directive.
* SUMMARY: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a Russia-Related Directive under Executive Order 13883 of August 1, 2019.
* DATES: OFAC’s action described in this notice was effective on August 26, 2019.
* FOR FURTHER INFORMATION CONTACT: OFAC: Associate Director for Global Targeting, 202-622-2420; Assistant Director for Licensing, 202-622-2480; Assistant Director for Regulatory Affairs,202-622-4855; or Assistant Director for Sanctions Compliance & Evaluation, 202-622-2490.
Russia-Related Directive Under Executive Order of August 1, 2019 (“CBW Act Directive”)
Pursuant to sections 1(a)(ii), 1(b), and 5 of Executive Order 13883 of August 1, 2019 “Administration of Proliferation Sanctions and Amendment of Executive Order 12851” (the “Order”) and 31 CFR 544.802, and following the Secretary of State’s selection of the sanction related to bank loans pursuant to delegated authority under section 307(b) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991, as amended (22 U.S.C. 5605(b)), the Director of the Office of Foreign Assets Control has determined, in consultation with the Department of State, that the following activities by a U.S. bank, as defined below, including foreign branches, are prohibited, except to the extent provided by law or unless licensed or otherwise authorized by the Office of Foreign Assets Control: (1) Participation in the primary market for non-ruble denominated bonds issued by the Russian sovereign, as defined below, after August 26, 2019; and (2) lending non-ruble denominated funds to the Russian sovereign, as defined below, after August 26, 2019.
   For purposes of this Directive, the term “U.S. bank” means, consistent with the Order and 31 CFR 544.311, any entity organized under the laws of the United States or any jurisdiction within the United States (including its foreign branches), or any entity in the United States, that is engaged in the business of accepting deposits, making, granting, transferring, holding, or brokering loans or credits, or purchasing or selling foreign exchange, securities, commodity futures, or options, or procuring purchasers and sellers thereof, as principal or agent. The term “U.S. bank” includes but is not limited to depository institutions, banks, savings banks, trust companies, securities brokers and dealers, commodity futures and options brokers and dealers, forward contract and foreign exchange merchants, securities and commodities exchanges, clearing corporations, investment companies, employee benefit plans, and U.S. holding companies, U.S. affiliates, or U.S. subsidiaries of any of the foregoing. This term includes those branches, offices and agencies of foreign financial institutions that are located in the United States and otherwise meet the definition of “U.S. bank” used in this Directive, but not such institutions’ foreign branches, offices, or agencies.
   Furthermore, for purposes of this Directive, the term “Russian sovereign” means any ministry, agency, or sovereign fund of the Russian Federation, including the Central Bank of Russia, the National Wealth Fund, and the Ministry of Finance of the Russian Federation. This term does not include state-owned enterprises of the Russian Federation.
   Except to the extent otherwise provided by law or unless licensed or otherwise authorized by the Office of Foreign Assets Control, the following are also prohibited: (1) Any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions contained in this Directive; and (2) any conspiracy formed to violate any of the prohibitions in this Directive. …

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OGS_a12. Items Scheduled for Publication in Future Federal Register Editions

(Source: Federal Register, 16 Sep 2019.)

* Treasury/OFAC; NOTIVES; Blocking or Unblocking of Persons and Properties [Pub. Date: 17 Sep 2019.]

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Commerce/BIS: (No new postings.) 


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State/DDTC: (No new postings.)


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EU Adopts New Decision on the Control of Arms Exports

(Source: Council of the EU, 16 Sep 2019.)
The Council today adopted a decision amending the Council Common Position of 8 December 2008 on the control of arms exports, as well as a revised user’s guide. It also adopted conclusions on the review of the Common Position.
The Council decision takes account of a number of developments at both European Union and international level that have resulted in new obligations and commitments for member states since the adoption of the Common Position of 2008. These developments include in particular the entry into force of the Arms Trade Treaty (ATT) on 24 December 2014, which regulates the international trade in conventional arms. All member states are States Parties to the ATT. The ATT aims to establish the highest possible common international standards for regulating or improving the regulation of the international trade in conventional arms and to prevent and eradicate the illicit trade in conventional arms and prevent their diversion.
In its conclusions, the Council recalls its commitment to strengthening the control of the export of military technology and equipment and to reinforce cooperation and promote convergence in the field of export of military technology and equipment within the framework of the Common Foreign and Security Policy. It does this through the setting, upholding and implementation of high common standards for the management of transfers of military technology and equipment by all member states.
The Council reaffirms that military equipment and technology should be traded in a responsible and accountable way. It renews its commitment to promote cooperation and convergence in member states’ policies to prevent the export of military technology and equipment which might be used for internal repression or international aggression, or contribute to regional instability.

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Bloomberg: “U.S. Semiconductor Companies Urge Trump to Hurry Huawei Licenses”
(Source: Bloomberg, 13 Sep 2019.) [Excerpts.]
The U.S. semiconductor industry urged President Donald Trump to make good on his promise to ease the ban on sales to China’s Huawei Technologies Co. …
After meeting with Chinese President Xi Jinping in late June, Trump said he would loosen restrictions on Huawei export licenses and that Beijing had agreed to buy more U.S. farming goods. But neither side has followed through on those pledges, and the U.S. has since increased tariffs on Chinese goods, sparking retaliation by China.
In July, Trump met with chief executives from major technology companies including Micron Technology Inc. and Alphabet Inc.’s Google who asked for a timely decision on the resumption of sales to Huawei.
American businesses require a special license to supply goods to Huawei after the U.S. added the Chinese company to a trade blacklist in May over national-security concerns. …

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Forbes: “Feds Demand Apple and Google Hand Over Names of 10,000+ Users of a Gun Scope App”
(Source: Forbes, 6 Sep 2019.)
Own a rifle? Got a scope to go with it? The U.S. government might soon know who you are, where you live and how to reach you.
That’s because the government wants Apple and Google to hand over names, phone numbers and other identifying data of at least 10,000 users of a single gun scope app, Forbes has discovered. It’s an unprecedented move: Never before has a case been disclosed in which American investigators demanded personal data of users of a single app from Apple and Google. And never has an order been made public where the feds have asked the Silicon Valley giants for info on so many thousands of people in one go. …
Why the data grab?
The Immigration and Customs Enforcement (ICE) department is seeking information as part of a broad investigation into possible breaches of weapons export regulations. It’s looking into illegal exports of ATN’s scope, though the company itself isn’t under investigation, according to the order. As part of that, investigators are looking for a quick way to find out where the app is in use, as that will likely indicate where the hardware has been shipped. ICE has repeatedly intercepted illegal shipments of the scope, which is controlled under the International Traffic in Arms Regulation (ITAR), according to the government court filing. They included shipments to Canada, the Netherlands and Hong Kong where the necessary licenses hadn’t been obtained. …

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Haaretz: “Police Arrest Workers of Israeli Cyber Group Ability on Suspicion They Violated Defense Export Law”
(Source: Haaretz, 15 Sep 2019.) [Excerpts.]
Israel Police arrested a number of suspects associated with two Ability group cyber companies and raided offices on Sunday morning on charges of fraud, smuggling and money-laundering.
The two subsidiaries of Ability Inc. under suspicion are Ability Computer & Software Industries and Ability Security Systems.
The investigation began with a Defense Ministry probe into suspicions that the Ability group had broken the law governing security-related exports from Israel. The police investigation is being handled by the unit for International Crime Investigations, in collaboration with the Director of Security of the Defense Establishment. …
Six months ago, the Ability subsidiaries were reported to have broken the law by marketing and exporting eavesdropping and geolocation systems without a license. Following a hearing, the Defense Ministry suspended the subsidiaries from the registry of defense export companies and, according to reports in March, revoked their export license. …

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Washington Post: “UN Votes to Ease Arms Embargo on Central African Republic”
(Source: Washington Post, 12 Sep 2019.) [Excerpts.]
The U.N. Security Council voted unanimously Thursday to ease the arms embargo on the Central African Republic’s government following its signing of a peace agreement with 14 armed groups in February and progress in reforming its security sector. …
The new resolution gives a green light for the country’s security forces to be supplied with weapons with a caliber of 14.5 mm or less, and ammunition for them, with at least 20 days advance notification and specific requirements including that they not be transferred or sold. …

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Safety at Sea: “Sanctions Main Cause for Concern in Maritime Insurance Market”

(Source: Safety at Sea, 13 Sep 2019.)
* Author: Gabriella Twining, Reporter. 
The impact of international trade sanctions on shipping is a major concern to the maritime insurance and underwriting market, according to panelists at the London International Shipping Week (LISW) event.
The discussion, titled “Navigating Difficult Waters: How sanctions and wars are impacting the shipping world”, focused on the current situation in the Middle East, more specifically the Iran, UK, and US relationship.
Sanctions are currently the foreign policy tool of choice, explained Nick Busvine, partner at Herminius and panelist, given that the reluctance of governments to deploy military force or campaigns led to two publicly unpopular wars, Afghanistan and Iraq. With the international sanctions against Iran and North Korea since 2010, financial supply has been cut off to these countries without putting people’s lives at risk.
The panel said compliance with international sanctions is a major issue that underwriters currently face. This is due to the contradictory nature of certain sanctions. For example, if a vessel does not have insurance while sailing past Iran, the vessel is in breach of European sanctions, if it does it is in breach of US law.
Deputy-director of claims for North of England P&I Club, Mike Salthouse, explained the unrealistic expectations shipowners have on what insurers can do when it comes to AIS. The growing number of vessels ‘going dark’, turning off their AIS system, has been a cause of concern for governments automatically thinking that the vessel is carrying out illicit activities.
There has been a growing pressure for insurers to put a clause in policies to not allow ships to turn off their AIS. Although the act may be seen as a ‘red flag’, Richard Young, head of hull and machinery at Beazley, said ships turn off their AIS if being pursued by pirates, and the system is also prone to malfunction. Furthermore, ships automatically turn off their AIS if approaching Israel should they visit another port call in the Middle East.
Busvine noted that the robust approach to sanctions that the US government is undertaking means it will have to be able to back up its sanctions with military force should the infringing country call its bluff. Paraphrasing Jeremy Hunt when he was foreign minister, Busvine said, “However much we don’t want war, we have a chance of slipping into it.”

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MS_a111. Monday List of Ex/Im Job Openings: 144 Openings Posted This Week, Including 19 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

* 3M; Maplewood, MN; Trade Compliance Counsel; Requisition ID; R00990035

* Abbott; Alameda, CA; Customs, Trade and Compliance Analyst

* Accenture; Dublin, Ireland; Trade Compliance – Legal Associate Manager; Requisition ID: 00748516
* Agility; Boston, MA; Import/Entry Writer Coordinator 
* Airbus Defense and Space, Inc.; Herndon VA; Export and Trade Compliance Manager;
# * Ajilon; Houston, TX; Export Admin; 

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

* 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

* Bunge; Chesterfield, MO; Customs Compliance Manager – North America;  

Butler Aerospace & Defense; New Brighton, MN;
HSE and Compliance Coordinator

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

* CACI; Reston, VA;
Trade Compliance Specialist
; Requisition
ID: 225842

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

CGI Federal Inc., Fairfax, VA
; Trade Compliance Analyst ;
Ann Runfola;

* Cobham Advanced Electronic Solutions; Exeter, NH; 
Export Compliance Administrator
; Requisition ID: req2614

* Cobham Advanced Electronic Solutions; New York; 
Contracts Manager
; Requisition ID: 00S2L
* Cobham Advanced Electronic Solutions; San Diego; 
Manager, USG Compliance
; Requisition ID: req2730

* Collins Aerospace; Windsor Locks, CT; International Trade Compliance Intern (Summer 2020);
Requisition ID: 01348159

* 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; Duisburg, Germay; Compliance Manager; Requisition ID: req73899
* DHL; Kuala Lumpur, Malaysia; Export Control Expert Asia Pacific; Requisition ID: req81427

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

* Dorel Home; Wright City, MO; Sr. Manager of Logistics and Customs Trade Compliance;

* Eaton;
Menomonee Falls, WI;
Senior Analyst- Purchasing Compliance
; Requisition ID: 076684

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

* Elastic; St. Louis, MO; Export Control Manager;

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

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

*Emerson; San Jose, Costa Rica; Trade Compliance Analyst I; Requsition ID: 19011754

* Epiroc; Garland, TX;
Americas Trade Compliance Manager

* Expeditors; Bedfont, United Kingdom;
Customs Brokerage Clerk 
* Expeditors; Rozenburg, the Netherlands; Import en Export control medewerker  

* Expolanka; El Segundo, CA; Export/Import Compliance Analyst;
* Fircroft; Telford, United Kingdom;
Export Controller 
* FIS Gobal; Brown Deer, WI; Compliance Analyst Senior (ECCN & Trade Sanctions);

* FLIR; Arlington, VA;
Sr. Manager, Global Export Licensing – US Government & Defense
; Requisition ID: REQ12113
* FLIR; Billerica, MA;
Sr. Manager, Global Export Licensing – US Government & Defense
Requisition ID: REQ12113

* 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: 25215BR

* General Atomics; San Diego, CA;
Import/Export Administrator
; Requisition ID: 24614BR

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

* Harris Corporation; Arlington, VA; Manager, Trade Compliance; Requisition ID:

* 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 

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

* Johnson Controls; Wash DC; Senior Manager, Global Customs Compliance; Requisition ID: WD30076209195

* Koch Chem Tech; Tulsa, OK;
Import/Export Compliance Specialist
; Requisition ID: 052017

* L3Harris; Clifton, NJ; Senior Trade Compliance Specialist;
Requisition ID:

* 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; Stratford, CT; International Trade Compliance Authorization Owner; Requisition ID: 500608BR

* 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

* Lululemon; Hong Kong; Lead, Customs & Trade Compliance – APAC; Requisition ID: 031616

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

* Marshall; Cambridge, UK; Export Compliance;

* 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

* 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 
/JPL; Pasadena, CA; Export Compliance Advisor; Requisition ID:

* 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

* Northrop Grumman, Multiple Locations; 
International Trade Compliance Manager 2; Requistion ID: 19027198

* Ormco; Amersfoort, the Netherlands; EMEA Trade Compliance Specialist 
* Pacific Northwest National Laboratory Location: Richland, WA; Export Control Professional; Elaine King; Requisition ID: 309752

* 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   

* PwC – McLean, VA; Regulations and Export Controls Director; Stephanie Andrews; Requisition ID: 
* PwC – McLean, VA; Regulations and Export Controls Manager; Stephanie Andrews; Requisition ID:  


* 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; Broughton, UK; Export Control Manager; Requisition ID: 146798BR

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

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

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

* Raytheon; Tucson, AZ; Sr. Trade Compliance Investigator; Requisition ID: 147211BR

* Raytheon; Waddington, UK; Export Control Manager; Requisition ID: 146798BR

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

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

* SAP; Walldorf, GER; Regional Export Control Coordinator (RECC) for EMEA; Requisition ID: 226695

* Sarepta Therapeutics; Cambridge, MA;
Director, Logistics & Global Trade Compliance    
* Satair; Asburn, VA;
Export and Trade Compliance Specialist
; Requisition ID: 1184847

* 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; Lyon, France;
SBS Export Compliance Expert (m/f)
; Requisition ID: 9501

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

* Thales; Crawley, UK;
Trade Compliance Officer
; Requisition ID: R0071081

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

* Thales; Gennevilliers, France;
Senior Trade Compliance Manager H/F
; Requisition ID: R0064439
* Thales; Valence, France;
Trade Compliance Manager (H/F)
; Requisition ID: R0069297

* Tiffany & Co; Parsippany, NJ; Director, Trade & Logistics – Americas 

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


* Varian Medical Systems; Austin, TX; Global Trade Analyst; Requisition ID: 16361BR

* 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;
Customs Compliance Specialist
; Requisition ID:

* 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  

* Zebra; Singapore; Head of Trade Compliance, APAC;

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ECTI Presents Export Control and IT Modernization – Issues and Considerations Webinar: October 1, 2019  
Danielle Hatch

* What: Export Control and IT Modernization – Issues and Considerations
* When: October 1, 2019; 1:00 p.m. (EDT)
* Where: Webinar
* Sponsor: Export Compliance Training Institute (ECTI)
* ECTI Speakers: Waqas Shahid and Kaitlyn Alessi 
* Register
Danielle Hatch
, 540-433-3977

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TE_a213. 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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William Howard Taft (15 Sep 1857 to 8 Mar 1930; the 27th President of the United States, who also served as the Chief Justice of the Supreme Court. He is the only person to have headed both the executive and judicial branches of the Federal Government.)
– “Don’t write so that you can be understood; write so that you can’t be misunderstood.
J.C. Penny (James Cash Penny; 16 Sep 1875 to 12 Feb 1971; was an American businessman and entrepreneur who founded the J. C. Penny stores in 1902.)
– “Luck is always the last refuge of laziness and incompetence.”
Monday is pun day.
* I saw an ad for burial plots, and thought to myself this is the last thing I need.
* Atheists won’t solve exponential equations because they don’t believe in higher powers.
* Claustrophobic people are more productive thinking out of the box.

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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

: 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: 30 Aug 2019: 84 FR 45652-45654, Adjustment of Controls for Lower Performing Radar and Continued Temporary Modification of Category XI of the United States Munitions List.  

  – The only available fully updated copy (latest edition: 30 August 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 email, usually revised within 24 hours after every ITAR amendment. The BITAR is available by annual subscription from the Full Circle Compliance website. BAFTR subscribers receive a $25 discount on subscriptions to the BITAR, please contact us to receive your discount code.

* DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders.
Implemented by Dep’t of Treasury, Office of Foreign Assets Control.
Last Amendment: 9 Sep 2019: 84 FR 47121-47123 – Cuban Assets Control Regulations

, 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: 4 Sep 2019: Harmonized System Update (HSU) 1915   
  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

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Weekly Highlights of the Daily Bugle Top Stories

(Source: Editor) 

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

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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 Editor, Alexander Witt. The Ex/Im Daily Update is emailed every business day to approximately 7,500 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.

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