19-1112 Tuesday “Daily Bugle”

19-1112 Tuesday “Daily Bugle”

Tuesday, 12 November 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
. [The Daily Bugle was not published yesterday, 11 November, a U.S. Federal holiday.]

[No items of interest today.]
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.) 
  3. State/DDTC: (No new postings.)
  4. EU Commission Publishes Report on Materials Dependencies for Dual-Use Technologies Relevant to Europe’s Defence Sector
  5. EU Council Adopts Framework for Sanctions Concerning Turkey
  6. EU Council Renews Venezuela Sanctions Until 14 November 2020
  7. UK HMRC Issued Fines of Between £5,000 and £90,000 to 9 UK Exporters for Unlicensed Exports
  1. American Shipper: “OFAC: Know Your Equipment Lease End-User”
  2. Geospacial World: “Skydweller Aero to Build First Solar-Powered ITAR-Free Drone”
  3. The Moscow Times: “Russia Might Ease Accounting Rules on Sanctioned Firms”
  4. Newsweek: “Saudi Nationals Charged with Firearms Smuggling, Pretended Weapons Parts Were ‘Shower Curtain Rods'”
  1. Baker McKenzie: “USTR Posts More Exclusions From $200 Bn Sec. 301 Action Against Chinese Products”
  2. R.L. Cassin: “These ‘Mistakes’ Are Behind Most OFAC Violations”
  3. T. Murphy: “Section 301 Update – Transshipment (and Enforcement) Issues”
  1. Monday List of Ex/Im Jobs: 112 Openings Posted This Week; 9 New Openings
  1. ECS Presents “Managing ITAR/EAR Complexities Seminar” on 25-26 Mar in Park City, UT
  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 Oct 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


[No items of interest today.]
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OGS_a11. Items Scheduled for Publication in Future Federal Register Editions

(Source: Federal Register)

* Commerce/BIS; RULES; Addition of Entities to the Entity List, Revision of an Entry on the Entity List, and Removal of Entities from the Entity List [Pub. Date: 13 Nov 2019.]
* USTR; NOTICES; Product Exclusions: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation [Pub. Date: 13 Nov 2019.]

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Commerce/BIS: (No new postings.) 


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/DDTC: (No new postings.)

(Source: State/DDTC)

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EU Commission Publishes Report on Materials Dependencies for Dual-Use Technologies Relevant to Europe’s Defence Sector
(Source: European Commission, 9 Nov 2019.)
To support the European Commission in the preparation of future initiatives fostering the sustainability of strategic supply chains, this study was commissioned to assess bottlenecks in the supply of materials needed for the development of technologies important to Europe’s defence and civil industries. The study focuses on five dual-use technology areas, namely advanced batteries, fuel cells, robotics, unmanned vehicles and additive manufacturing (3D printing). This report examines how these technologies could address specific military needs and their differences in relation to civil needs and identified opportunities for future defence research areas that could potentially serve as a basis for the design of research initiatives to be funded under the future European Defence Fund. 

Moreover, potential opportunities for common policy actions are identified, notably to strengthen Europe’s position along the selected technologies’ supply chains, to facilitate collaboration between stakeholders, to increase industry involvement with special emphasis on SMEs, to improve existent legislation, and to increase synergies between civil and defence sectors to speed up progress in promising research areas.

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EU Council Adopts Framework for Sanctions Concerning Turkey
(Source: Council of the European Union, 11 Nov 2019.)
Today, the Council adopted a framework for restrictive measures in response to Turkey’s unauthorised drilling activities in the Eastern Mediterranean. The framework will make it possible to sanction individuals or entities responsible for or involved in unauthorised drilling activities of hydrocarbons in the Eastern Mediterranean.

The sanctions will consist of a travel ban to the EU and an asset freeze for persons, and an asset freeze for entities. In addition, EU persons and entities will be forbidden from making funds available to those listed.
The framework for restrictive measures makes it possible to place under sanctions:
(1) persons or entities responsible for drilling activities related to hydrocarbon exploration and production not authorised by Cyprus within its territorial sea, exclusive economic zone (EEZ) or continental shelf. Such drilling activities include, where the EEZ or continental shelf has not been delimited in accordance with international law, activities which may jeopardize or hamper the reaching of such a delimitation agreement;
   (2) persons or entities providing financial, technical or material support for the above mentioned drilling activities;
   (3) persons or entities associated with them.
Today’s decision is a direct follow-up to the Council conclusions of 14 October 2019, which were endorsed by the European Council on 17-18 October 2019, when the EU reaffirmed its full solidarity with Cyprus, regarding the respect of its sovereignty and sovereign rights in accordance with international law and invited the Commission and the European External Action Service to submit proposals for a framework for restrictive measures. …
* Council Decision (CFSP) 2019/1894 of 11 November 2019 concerning restrictive measures in view of Turkey’s unauthorised drilling activities in the Eastern Mediterranean.

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EU Council Renews Venezuela Sanctions Until 14 November 2020
(Source: Council of the European Union, 11 Nov 2019.)
In light of the ongoing political, economic, social and humanitarian crisis in Venezuela with persistent actions undermining democracy, the rule of law and the respect for human rights, the Council today extended the restrictive measures against Venezuela for one year, until 14 November 2020. The measures include an embargo on arms and on equipment for internal repression as well as a travel ban and an asset freeze on 25 listed individuals in official positions who are responsible for human rights violations and/or for undermining democracy and the rule of law in Venezuela.
These measures are intended to help encourage democratic shared solutions in order to bring political stability to the country and allow it to address the pressing needs of the population. The targeted measures are flexible and reversible and designed not to harm the Venezuelan population.
Council Regulation (EU) 2019/1889 of 11 November 2019 amending Regulation (EU) 2017/2063 concerning restrictive measures in view of the situation in Venezuela
Council Implementing Regulation (EU) 2019/1891 of 11 November 2019 implementing Regulation (EU) 2017/2063 concerning restrictive measures in view of the situation in Venezuela
Council Decision (CFSP) 2019/1893 of 11 November 2019 amending Decision (CFSP) 2017/2074 concerning restrictive measures in view of the situation in Venezuela

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UK HMRC Issued Fines of Between £5,000 and £90,000 to 9 UK Exporters for Unlicensed Exports
(Source: UK ECJU,12 Nov 2019.)
Between May and October 2019, HM Revenue & Customs (HMRC) issued compound penalties between £5,000 and £90,000 to 9 UK exporters. These related to unlicensed exports of dual use goods, military goods and related activity controlled by The Export Control Order 2008.
HMRC have policy responsibility for enforcing export controls on strategic goods and sanctions, and investigating breaches of those controls. Where appropriate, HMRC can use their powers to offer a compound penalty in lieu of prosecution.

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American Shipper: “OFAC: Know Your Equipment Lease End-User”
(Source: American Shipper, 9 Nov 2019.) [Excerpts.]
The U.S. Treasury Department’s Office of Foreign Assets Control assessed $210,600 civil penalty against Apollo Aviation Group for violating the Sudanese Sanctions Regulations.
Apollo Aviation Group, which is now part of Carlyle Aviation Partners Ltd., has agreed to pay a $210,600 civil penalty to settle 12 alleged violations of the Sudanese Sanctions Regulations, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) said.
The violations began on July 30, 2013, when Apollo leased two aircraft engines to a company in the United Arab Emirates, which in turn subleased the engines to a Ukrainian airline that installed them on an aircraft leased to Sudan Airways.  
At the time of the violations, Sudan Air was listed on OFAC’s 
Specially Designated Nationals and Blocked Persons (SDN) List 
for its ownership by the Sudanese government. U.S. persons and companies are generally prohibited from exporting to entities on the SDN List.
OFAC did not name the United Arab Emirates company or the Ukrainian airline in the settlement agreement. …


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Geospacial World: “Skydweller Aero to Build First Solar-Powered ITAR-Free Drone”
Geospacial World, 12 Nov 2019) [Excerpts.]
Leonardo S.p.A. of Italy is accelerating the progress of technology and innovation in autonomous flight by investing in Skydweller Aero Inc., a US/Spanish start-up specializing in large-scale solar-powered unmanned air systems. The initiative will result in the development and deployment of the Skydweller drone, the world’s first fully-electric unmanned aircraft capable of carrying large payloads with unlimited range and ultra-persistent endurance.  . . .
Thanks to its unique features, Skydweller combines potentially unlimited persistence and range with the flexibility of an aircraft. It will operate from existing airbases around the world, deploy thousands of miles away to areas of high need, and remain overhead for orders of magnitude longer than current aircraft. This revolutionary platform will be used for purposes ranging from land and maritime surveillance to monitoring the environment and infrastructure, from industrial geo-information services to telecommunications and precision navigation. During emergencies and disaster-recovery situations, the system can be rapidly deployed from distant locations to provide backup communications and direct support to first responders. . . .
The system will comply with European export laws and will not be subject to International Traffic in Arms Regulations (ITAR) restrictions. This will enable the aircraft to satisfy government and commercial needs around the world. Leonardo will act as the prime contractor for commercial opportunities in Italy, the United Kingdom, Poland and NATO.  Development and construction of the aircraft will be carried out at the Skydweller facility in the Castilla-La Mancha region of Spain. Leonardo Aircraft division will participate in development and engineering activities via a dedicated team.

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The Moscow Times: “Russia Might Ease Accounting Rules on Sanctioned Firms”
(Source: The Moscow Times, 8 Nov 2019.) [Excerpts.]
Russia’s defense contractors would no longer have to produce annual financial reports in latest proposals to protect sanctioned companies.  
Russia could let a handful of companies stop publishing mandatory annual reports and financial statements in an attempt to protect them from further Western sanctions.
In new proposals submitted this week, the Finance Ministry proposed cancelling obligatory reporting for around 20 Russian firms on a government list of companies that should receive special treatment because of U.S. and EU sanctions against them. The move is designed to limit how much Western governments can find out about the companies, and protect their customers and contractors from being named on future sanctions lists by the U.S. or EU.
Companies that could receive the exemption include sanctioned businesses connected to the defense industry, such as Russian Helicopters, gun maker Kalashnikov Concern and state arms exporter Rosoboronexport, the Russian business daily Kommersant reported. …


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Newsweek: “Saudi Nationals Charged with Firearms Smuggling, Pretended Weapons Parts Were ‘Shower Curtain Rods'”
(Source: Newsweek, 9 Nov 2019.) [Excerpts.]
Two Saudi nationals have been charged by a federal grand jury with conspiring to smuggle firearms out of the United States, contrary to strict export controls governed by the Arms Export Control Act.
A five-count indictment outlining the charges was handed down on Wednesday naming Saudi residents Hatim Humeed Alsufyani, 36, and Mosab Alzahrani, 27, who previously lived in the United States on a student visa while purportedly attending California State University, San Bernardino.  
Both men are believed to currently be in the Kingdom.
The 1976 Arms Export Control Act and a related executive order allow presidential administrations to restrict the flow of weapons out of the country. The State Department determines which weapons to designate as “defense articles” under the statute, which forms the basis of the United States Munitions List in the tome of Federal Regulations.
Individuals exporting weapons or weapons components covered by the munitions list, as Alsufyani and Alzahrani are alleged to have done, would need to first obtain an export license from the State Department. …


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Baker McKenzie: “USTR Posts More Exclusions From $200 Bn Sec. 301 Action Against Chinese Products”
(Source: International Trade Compliance Update, 8 Nov 2019.)
On November 7, 2019, the US Trade Representative (USTR) posted an advance copy of a Federal Register notice that announces USTR’s determination to grant certain exclusion requests, as specified in the annex to this notice from the additional duties on goods of China with an annual trade value of approximately $200 billion (Tranche 3) as part of the action in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation.
Effective September 24, 2018, USTR imposed additional 10 percent duties on goods of China classified in 5,757 full and partial subheadings of the Harmonized Tariff Schedule of the United States (HTSUS), with an approximate annual trade value of $200 billion. See 83 Fed. Reg. 47974, as modified by 83 Fed. Reg.  49153. In May 2019, USTR increased the additional duty to 25 percent. See 84 Fed. Reg. 20459. On June 24, 2019, USTR established a process by which U.S. stakeholders may request exclusion of particular products classified within an 8-digit HTSUS subheading covered by the $200 billion action from the additional duties. See 84 Fed. Reg. 29576 (the June 24 notice).
The June 24 notice required submission of requests for exclusion from the $200 billion action no later than September 30, 2019, and noted that USTR would periodically announce decisions. In August 2019, USTR granted an initial set of exclusion requests. USTR granted additional exclusions in September and October 2019. USTR regularly updates the status of each pending request on the USTR Exclusions Portal.
Based on the evaluation of the factors set out in the June 24 notice, USTR has determined to grant the product exclusions set out in the Annex to the notice. USTR’s determination also takes into account advice from advisory committees and any public comments on the pertinent exclusion requests. 
As set out in the Annex, the exclusions are reflected in 2 ten-digit HTSUS subheadings and 34 specially prepared product descriptions, which cover 42 separate exclusion requests. 
In accordance with the June 24 notice, the exclusions are available for any product that meets the description in the Annex, regardless of whether the importer filed an exclusion request. Further, the scope of each exclusion is governed by the scope of the product descriptions in the Annex, and not by the product descriptions set out in any particular request for exclusion. 
– Paragraph A, subparagraphs 1 and 2 establish a new subheading, 9903.88.34 and a new US note 20(mm) to subchapter III of chapter 99 to cover the products granted exclusions;
– Paragraph A, subparagraphs 3-5 are conforming amendments to the HTSUS reflecting the modification made by the Annex. As stated in the September 20, 2019 notice, the exclusions will apply from September 24, 2018, to August 7, 2020. 
U.S. Customs and Border Protection will issue instructions on entry guidance and implementation. 
USTR will continue to issue determinations on pending requests on a periodic basis.

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R.L. Cassin: “These ‘Mistakes’ Are Behind Most OFAC Violations”
FCPA Blog, 8 Nov 2019.) [Excerpts.]
* Author: Richard L. Cassin, Editor at Large.
Earlier this year the Treasury Department’s Office of Foreign Assets Control published A Framework for OFAC Compliance Commitments. It describes essential components of a sanctions compliance program (management commitment, risk assessment, internal controls, testing and auditing, and training). There’s also a neat section about “root causes” of sanctions violations that OFAC found during actual investigations.
To paraphrase Bismarck, it’s great to learn from mistakes, especially when the mistakes aren’t yours. Here then are the mistakes of others, accidental or otherwise, behind most OFAC violations:
No sanctions compliance program. 
Incredible but true. After nearly 70 years of OFAC regulations, “numerous” enforcement actions still involve companies with no formal sanctions compliance program. OFAC regulations don’t require companies to adopt a program and a lot of them don’t. But it’s a no brainer that companies subject to OFAC jurisdiction and doing anything that crosses borders should have a formal sanctions compliance program.
Improper due diligence.
 Some companies with cross-border businesses are still failing to ask and answer basic sanctions-related questions. OFAC found violators that didn’t know who owned their customers or intermediaries, where they were physically located, and whether the counter-parties and agents were even aware of OFAC regulations
Bad information and the wrong tools.
 Outdated lists of sanctioned people and organizations caused violations. As did search software that didn’t account for alternative or regional spellings of prohibited countries or parties – Habana instead of Havana, Kuba instead of Cuba, Soudan instead of Sudan, and so on.
Being wrong about who and what are covered by OFAC regulations. 
Numerous violators concluded wrongly that they weren’t subject to OFAC regulations, or that the regulations didn’t apply to or prohibit their specific deal. Multiple organizations violated sanctions by shifting deals to their foreign units. “In many instances,” OFAC said, “the root cause of these violations stems from a misinterpretation or misunderstanding of OFAC’s regulations.”
Being willfully blind about where U.S.-origin goods, technology, or services will end up.
 OFAC said even large and sophisticated companies sold controlled items to buyers (often repeatedly and over several years) who had “the specific intent” of re-selling or transferring the items to blocked people, organizations, or countries.
De-centralized and inconsistent compliance functions and programs.
 At some violators, OFAC found compliance staff and decision-makers scattered across offices or business units. The organizations lacked a formal escalation process to review high-risk customers or transactions. OFAC also found “inefficient or incapable oversight and audit function” in some violators, and frequent miscommunication about the organization’s sanctions-related policies and procedures.
Bosses going rogue. 
Employees – particularly in supervisory, managerial, or executive-level positions – played “integral roles” in causing or abetting some violations. It happened even in companies that had “a fulsome sanctions compliance program in place.” Compounding the problem, the bad bosses usually did their best to “obfuscate and conceal” their activities from compliance personnel and from regulators and law enforcement. OFAC calls this root cause “individual liability” but said it can hold the employers liable for the violations (see respondeat superior), as well as the rogue employees.
A final caveat:
 OFAC’s Framework lists ten “root causes” behind sanctions violations and describes them in more complete and technically accurate language. I’ve shortened OFAC’s list by combining items and dropping others.
This summary is only an introduction to OFAC’s guidance and isn’t a substitute for the originalavailable 

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T. Murphy: “Section 301 Update – Transshipment (and Enforcement) Issues”

(Source: Author)

With negotiations over the Phase 1 deal in full swing in the press (e.g., China publicly saying that the United States had agreed to roll back tariffs as part of the deal last Thursday, and President Trump saying that he had not agreed to do so on Friday, etc.), we wanted to flag an issue that all companies seeking alternative sources of supply outside of China should keep in mind.
In the past week, there have been several stories about foreign suppliers seeking to take (illegal) shortcuts to avoid the Section 301 tariffs on Chinese-origin goods shipped to the United States.  These stories recount situations where Chinese-origin goods are exported to a third country (e.g., Vietnam) where minimal-to-no processing occurs, but the suppliers relabel the goods to conceal the true origin in order to avoid the additional U.S. duties.   

In one story, Vietnam Customs reportedly seized $4.3 billion worth of Chinese-origin aluminum that had been relabeled as Vietnam-origin and destined for shipment to the United States (this was in part to avoid antidumping/countervailing duties applicable to Chinese-origin aluminum).  The story also mentions recent seizures of bicycles, machinery, clothes, shoes and electronics that were falsely labeled as being of Vietnam origin after being transshipped from China, through Vietnam, to the United States.  A copy of this specific report is attached for your reference.
Countries like Vietnam, Malaysia, Thailand, etc. are all reaping the benefits of the U.S.-China trade war as suppliers look to move production out of China.  Unscrupulous suppliers, however, will seek to cut corners by transshipping or relabeling Chinese-origin products destined for the United States.  The governments of these countries have a meaningful incentive to root out that behavior and stop it, so as not to draw the ire of the United States.  An increasing trade in goods deficit is concerning enough to these governments; the last thing they want is to be branded as a haven for transshipment thereby drawing unwanted attention from the United States (e.g., a new Section 301 action, new antidumping/countervailing duty investigation, etc.).  Accordingly, these governments are increasingly comparing import data to export data and scrutinizing export shipments to identify possible transshipment situations.  Certain countries, like Vietnam, are also drafting new rules to address when an article can be labeled “Made in Vietnam” (to the extent these rules impose standards that are inconsistent with the U.S. Customs and Border Protection substantial transformation test, it will create additional headaches for U.S. importers – e.g., if a product that must be labeled as being “Made in Vietnam” under the U.S. rules cannot be labeled as “Made in Vietnam” under the new rules in Vietnam).
Accordingly, all companies working with suppliers to move production from China to third countries should take reasonable steps to ensure that transshipment is not occurring.  Companies should ensure that new/relocated production facilities actually have the capability to perform the expected processing operations, obtain additional certifications from the suppliers, add this issue to third-party inspections/audits performed as part of the new facility set up, and take other reasonable steps to demonstrate that reasonable precautions against transshipment have been taken.  We expect that CBP will increasingly be asking importers about this issue (i.e., to validate non-China country of origin).  Those who can pull the answer out of the file will fare much better than those who have to scramble to put the answer together at that point.  Make sure you are part of the former group, and not the latter.

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MS_a115. Monday List of Ex/Im Job Openings: 112 Openings Posted This Week, 9 New Openings

(Source: Events & Jobs Editor) 

Published every Monday or first business day of the week. (The list was not published yesterday, a U.S national holiday.) Please send job openings in the following format to 
.  Listings are free.

” New or amended listing this week

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

* ABB; Bangalore, India; Trade Compiance Manager;

* Adecco; Round Rock, TX; Export Compliance;

* Advanced Concepts & Technologies International, Lexington Park, MD; Foreign Disclosure Specialist 

* Ajilon; Princeton, NJ;
Import and Export Coordinator
* Ajilon; Melville, NY;
Import Export Administrator
* Ajilon; Elizabeth, NJ;
Ocean Air Import and Export Specialist

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

* Arrow Electronics; Denver, CO; Transportation Import/Export Specialist; amanda.elam@arrow.com; Requisition ID: 172946

* Arrow Electronics; Zapopan, Mexico; Transportation Coordinator II; 

; Requisition ID: R172262 

* Arrow Electronics: Zapopan, Mexico; Transportation Coordinator II; 
; Requisition ID: R172264

* Arrowhead Products; Los Alamitos, CA; Trade Compliance Specialist 
* ASML; Chandler, AZ; Sr Export Controls Manager;
Requisition ID:

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

* BASF; Mannheim, Germany; Manager Global Export Control; Requisition ID: EN57992009_ONLE_1
* Battelle; Columbus, OH, or alternate location; International Trade Compliance Manager 
* Belk; Charlotte, NC; Manager, Global Trade & Customs Compliance; ewelina_janiszewski@belk.com; Requisition ID: JR-27974

* Blue Origin; Kent, WA; Export Control Administrator;

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

* BP; Houston, TX; International Trade Regulations Analyst; Requisition ID: 110367BR

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

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

* CACI; Chantilly, VA;
Trade Compliance Specialist; Requisition ID: 225842_20151

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

* Carnegie Mellon University; Pittsburgh, PA, Export Compliance Manager; hbragg@andrew.cmu.edu;

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

* Cobham Advanced Electronic Solutions; San Diego; 
Manager, USG Compliance
; Requisition ID: req2730

* Cobham Satcom; Concord, CA; Import Export Compliance Officer; Carolyn Grimes or 1-925-681-9596;

* 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

* Cubic; Durham, NC; Senior Export Compliance Analyst; Requisition ID: REQ_19711

* Curtiss-Wright; Charlotte, NC; Senior Manager, Global Trade Compliance; Requisition ID:

* 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; Portsmouth, UK; Trade Compliance Analyst;
Requisition ID: SHA001042;

* DHL; Duisburg, Germay; Compliance Manager; Requisition ID: req73899

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

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

* Expolanka; El Segundo, CA; Export/Import Compliance Analyst;

* FLIR; Täby, Sweden; Director, Global Export Compliance EMEA; Requisition ID: REQ12627  

* Fluke Electronics; Everett, WA;
Trade Compliance Analyst  

* General Atomics; San Diego, CA;
Government Compliance Specialist
; Requisition ID: 23607BR
* General Atomics; San Diego, CA;
Government Regulatory Compliance Specialist
; Requisition ID: 25215BR

* IDEX Corporation; Albuquerque, NM;
Trade Compliance Coordinator

* IPG Photonics; Oxford, MA; Trade Compliance Manager; Requisition ID: 285450196

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

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

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

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

* L3Harris; Greenville, TX; Empowered Official; Contact Roger Ethridge, roger.ethridge@l3harris.com; Requisition ID: 110364

* Lawrence Berkeley National Laboratory; Berkeley, CA; Export Compliance Specialist; Requisition ID: 88638

* Lawrence Livermore National Laboratory; Livermore, CA; Export Control Officer; Requisition ID: 106174

* Lenovo; Guandong, China; AP Trade Compliance Specialist; Requisition ID: 73183
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; Washington DC; Export Controls Associate; Requisition ID: 6522

* Lockheed Martin Aeronautics; Arlington, VA;
International Licensing Analyst; Requisition ID:

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

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

* Mars; Chicago, IL; Trade Compliance Analyst; Requisition ID: 249666;

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

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

* Mercury Systems; Any City; Principal Trade Compliance Specialist; Requisition ID: 19-604

* Miller Canfield; Troy, Mi;
Associate Attorney – Mergers & Acquisitions; 

* Moog Inc., Space and Defense Group; East Aurora, NY; Operation Trade Specialist;
* Moog Inc., Space and Defense Group; East Aurora, NY; Senior Trade Compliance Specialist;
Moog Inc., Space and Defense Group; Torrence, CA; Trade Compliance Administrator (Export);

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

* Netflix; Los Gatos, CA; Manager, Trade Compliance;

* Nouryon Corp; Houston, TX; Director, Global Trade Compliance; 
* Northrop Grumman; Falls Church, VG;
International Trade Compliance Manager 1
; Requisition ID: 19032304

Northrop Grumman; Herndon, VA; International Trade Compliance Analyst; Requisition ID:

* Northrop Grumman; Melbourne, FL;
Principal International Trade Compliance Analyst
; Requisition ID: 19033647
* Northrop Grumman; Mesa, AZ; Principal International Trade Compliance Analyst: Jill VanValkenburg, 1-925-351-7665 or Jill.Valkenburg@ngc.com 

* OneWeb; McLean, VA; Export Compliance Specialist  
* PAE; Falls Church, VA; Director – International Trade Compliance Office; Requisition ID: R0037636 

* Paraxel; Kiev, Ukraine; Trade Compliance Specialist;

* Pattonair; Fort Worth, TX; Trade & Regulatory Compliance Manager;

* Plexus Corp; Remote; Sr. Manager – International Trade Controls; Requisition ID: R006729

* PolyOne, Avon Lake, OH; Trade Compliance Analyst  

* Raytheon; Andover, MA; Sr An Global Trade Licensing; Requisition ID:
* Raytheon; Ft. Wayne, IN; Sr. Analyst Global Trade Licensing; Requisition ID:
* Raytheon; Fulton, MD; Global Trade Licensing Manager; Requisition ID:
* Raytheon; Tucson, AZ; Global Trade Licensing Analyst; Requisition ID:

* Roche; Mannheim, Germany; Head of Export Control & Customs;

* 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

* Saudi Aramco; Dhahran, Saudi Arabia;
; Requisition ID: 17184BR

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

* SLAC National Accelerator Laboratory (Stanford University); Menlo Park, CA; Export Compliance Manager; Requisition ID: 3928

* Sophos; Multiple Locations; Senior Manager, Trade Compliance;

* SRC Inc.; Syracuse, NY; International Trade Compliance Analyst; Requisition ID: 3526

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

* Thales; Ottawa, Canada; Procurement Supplier Contracts Manager;
Requisition ID: R0077808;

* Thales; Gennevilliers, France;
Trade Compliance Manager H/F
; Requisition ID: R0071200
* Thales; Melbourne, Australia;
Trade Compliance Manager
Requisition ID: R0074607;

* 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

* United Technologies; Haute-Garonne, France; Export Control Officer;
Requisition ID:

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

* Walt Disney; Burbank, CA;
Principal Counsel – Compliance
; Requisition ID: 706363BR
* Walt Disney; Kissimmee, FL;
Trade Compliance Analyst
; 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

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ECS Presents “Managing ITAR/EAR Complexities Seminar” on 25-26 Mar in Park City, UT

(Source: ECS)
*What:  Managing ITAR/EAR Complexities Seminar
*When:  March 25-26, 2020
*Sponsor:  Export Compliance Solutions & Consulting (ECS)
*ECS Instructors:  Suzanne Palmer, Lisa Bencivenga

 or by calling 866-238-4018 or

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TE_a217. FCC Presents “U.S. Export Controls: 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: here or contact FCC at events@fullcirclecompliance.eu or + 31 (0)23 – 844 – 9046
* This course can be followed in combination with “U.S. Export Controls: The Export Administration Regulations (EAR) from a non-U.S. Perspective” (27 Nov 2019), and/or “The ABC of Foreign Military Sales” (29 Nov 2019). Please, see the event page for our combo deals.

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(Editor’s note:  The Daily Bugle was not published yesterday because it was Veterans Day, a U.S. Federal holiday. But we know you don’t want your full week of quotations and puns to be cut short, so here they are Monday’s entries, a day late.]

* Martin Luther
(10 Nov 1483 – 18 Feb 1546; was a German professor of theology, composer, priest, monk, and the seminal figure in the Protestant Reformation. An ordained priest, Luther disputed several of the Catholic church practices. His refusal to renounce all of his writings at the demand of Pope Leo X resulted in his excommunication and condemnation as an outlaw by the Holy Roman Emperor.)
 – “There is no more lovely, friendly, and charming relationship, communion, or company than a good marriage.”
* Fyodor
Dostoevsky (Fyodor Mikhailovich Dostoevsky; 11 Nov 1821 – 9 Feb 1881, was a Russian novelist, short story writer, essayist, journalist, and philosopher. His most acclaimed works include Crime and PunishmentThe IdiotDemons, and The Brothers Karamazov. Many literary critics rate him as one of the greatest psychologists in world literature.)
  – “There is no subject so old that something new cannot be said about it.”
  – “
If there is no God, everything is permitted.”


Monday is pun day.

* Q: What kind of chocolate do they sell at the airport?  
   A: Plane chocolate.
* Q: What kind of music are balloons afraid of?  
   A: Pop Music
* Q: Why shouldn’t you fall in love with a pastry chef?  
   A: He’ll dessert you.
Tuesday, 12 Nov
* Auguste Rodin
(François Auguste René Rodin; 12 Nov 1840 – 17 Nov 1917; was a French sculptor, generally considered the progenitor of modern sculpture.  Rodin spent over 40 years working on his elaborate Gates of Hell, an unfinished portal for a museum that was never built. Many of the portal’s figures became sculptures in themselves, including two of Rodin’s most famous figures, The Thinker and The Kiss.)
  – “Nothing is a waste of time if you use the experience wisely.”
  – “I choose a block of marble and chop off whatever I don’t need.”
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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.

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 October 2019: FR 56117-56121: Restricting Additional Exports and Reexports to Cuba 


: 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
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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.

* 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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