19-1118 Monday “Daily Bugle”

19-1118 Monday”Daily Bugle”

Monday, 18 November

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

inquiries and rates

[No items of interest today.]
  1. Items Scheduled for Publication in Future Federal Register Editions
  2. Commerce/BIS: (No new postings.)
  3. Commerce/Census: “Is Thanksgiving Really Almost Here?”
  4. Commerce/ITA: “Innovate Customs Procedures in Laredo, Texas Accelerate U.S. Exports to Mexico”
  5. State/DDTC: (No new postings.)
  6. DHS/CBP: “New Draft Chapter of Entry Summary Status Notification CATAIR (V17) Posted on CBP.gov”
  7. OMB/OIRA Reviews of Proposed Ex/Im Regulations: Activities Not Exports, Re-exports, or Transfers
  1. Bloomberg: “Senators Knock ‘Slow’ Pace of Technology Export-Control Reviews”
  1. Torres Trade Law: “Department of State Proposes Amending ITAR Definitions, Creating Encryption Carve-Out”
  2. 3rdwave: “Trade Compliance – A Defence for the ‘C’ Suite”
  3. Tuttle Law: “20 Nov 2019 (this Wednesday) is the Last Day to File Extension for List 1 Initial Exclusion
  1. Monday List of Ex/Im Jobs: 106 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

* Commerce/BIS: Temporary General License: Extension of Validity; temporary general license to Huawei Technologies Co., Ltd. and one hundred and fourteen of its nonU.S. affiliates on the Entity List.
  – Scheduled
 Pub. Date: 20 Nov 2019.

* State: Updating the State Department’s List of Entities and Subentities Associated with Cuba (Cuba Restricted List)
Scheduled Pub. Date: 19 Nov 2019

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Commerce/Census: “Is Thanksgiving Really Almost Here?”

Global Reach Blog

For many of us, Thanksgiving marks the beginning of the holiday season. While we each have our personal favorite holiday, Thanksgiving is perhaps the most popular. During this time, families and friends gather together, join parades (and watch from the sidelines) and cheer on their hometown football teams.
But perhaps the most impressive thing about Thanksgiving is the food! Whether it’s fried turkey in Texas, the three bean salad in the south, cranberry relish in the northeast or arroz con gandules y pernil (pigeon pea stewed rice and pork roast) in Puerto Rico, food takes center stage at Thanksgiving.  
In a nod to this food-centric holiday, we decided to check out the most popular imported food items for the month of November.
To find this info, we searched USA Trade Online, the official source for trade data, provided by the U.S. Census Bureau. Given our interest in foodstuff, we focused on Schedule B numbers found in chapters one to 24.
Based on the imported value, the top three imported food items for November 2018 were frozen shrimp and prawns, beer made from malt and food preparations (like fruit and vegetable juices, compound alcoholic preparations and coffee whiteners).

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Tradeology, 18 Nov 2019) [Excerpts.]
Last month, from October 16-17, industry leaders and officials from the U.S. Department of Commerce’s International Trade Administration (ITA) traveled to Laredo, Texas, one of the premier cities for U.S.-Mexico trade.
With over $100 billion in U.S. exports processed in 2018 alone, customs officials on both sides of the border face increasing demands to perform efficient and effective inspections. The Laredo International Airport has seized upon this growing commercial opportunity by innovating their customs process and establishing a unique bi-national inspection facility in 2013. ITA’s Advisory Committee on Supply Chain Competitiveness (ACSCC) had the privilege of touring and learning more about this facility and its achievements over the past several years. . . .
Elizabeth Merritt, Managing Director for Cargo Services at Airlines for America and ACSCC member, highlighted the importance of streamlined customs procedures to U.S. industries and value chains saying, “by leveraging a bilateral customs partnership, the Laredo airport boosts the competitiveness of the North American supply chain while maximizing the limited resources of all stakeholders to ensure trade compliance.” . . .
Currently this accelerated customs treatment is available for products in the automotive, aerospace, and electronics industries. Importers, shippers, and other logistics companies can also benefit from round-the-clock service from the customs officials, as Laredo has the only airport on the southern border with U.S. customs open 24 hours a day, seven days a week.
During their visit to the facility, members of the ACSCC, all experts in the policies and logistics surrounding U.S. supply chains, received a presentation on the Federal Inspection Station’s activities and spoke with both U.S. and Mexican customs officials to better understand their joint procedures. . . .
Looking forward, the officials based at the Federal Inspection Station see room for growth, especially as approval of the U.S.-Mexico-Canada Agreement (USMCA) could lead to a surge in trade between the neighboring countries. CBP and SAT officials expressed their desire to grow awareness of their collaborative program and to expand the list of qualified products for inspection. Experts from the Laredo airport have already been invited to pilot similar programs at other airports in the United States, and customs agents believe the joint facility is prepared to handle greater volumes of U.S. exports in the future. This innovative, bi-national process can serve as a model to other ports and cities seeking to expedite inspections for the benefit of U.S. industry.
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/DDTC: (No new postings.)

(Source: State/DDTC)

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DHS/CBP; CSMS #40683630, 18 Nov 2019)

A new draft chapter of the Entry Summary Status Notification CATAIR (V17) is now posted on CBP.GOV at the following location under the ‘Chapters: Drafts for Future Capabilities’ tab: 
This update includes two additional Quota Line Status Codes:
Q17: QTA Line Pending > 10 days
Q28: License Line Pending > 10 days 
These new quota line status codes will be sent out when a quota line is pending for more than 10 days (Q17) or when an agriculture license line is pending more than 10 days (Q28).  These statuses will be sent out once a line is pending more than 10 days and every week there after (on a weekly basis) until the pending line is resolved.

A follow-up CSMS message will be sent out when these codes are available in the CERTIFICATION environment and when an expected PRODUCTION deployment date is determined.

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OMB/OIRA Reviews of Proposed Ex/Im Regulations: Activities Not Exports, Re-exports, or Transfers

Office of Management & Budget; Office of Information and Regulatory Affairs (OIRA) Report of Executive Order Submissions Under Review:
International Traffic in Arms Regulations: Activities Not Exports, Re-exports, or Transfers
– AGENCY: State
Interim Final Rule
– RIN:


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Bloomberg: “Senators Knock ‘Slow’ Pace of Technology Export-Control Reviews”

Bloomberg Law, 18 Nov 2019) [Excerpts.]
Two U.S. senators are pressing the Commerce Secretary Wilbur Ross for answers about a lag in “critical” export-control reviews of emerging technology they fear might fall into the hands of China.
In a letter sent Nov. 18, Minority Leader Chuck Schumer (D-N.Y.) and Sen. Tom Cotton (R-Ark.) asked Ross for updates on the status of rule inspections mandated by the 2018 Export Control Reform Act, which bolstered Commerce’s statutory authority to administer export-control regulations.

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In a recently published Notice of Proposed Rulemaking the Department of State proposes an amendment to the International Traffic in Arms Regulations (“ITAR”) provisions defining activities that are not exports, re-exports, or retransfers. Such activities that will not be exports, re-exports, or retransfers under the proposed definition include (1) launching items into space, (2) providing technical data to U.S. persons within the United States or within a single country abroad, and (3) moving defense articles between U.S. states, possessions, and territories. Importantly, the proposed revisions will allow for the electronic storage and transmission of unclassified technical data through foreign communications infrastructure without requiring ITAR licensing when the technical data is sufficiently secured to prevent access by foreign persons. 

The proposed amendments also include the creation of a definition for “access information” and the revision of the “release” definition to include the improper provision of access information to foreign persons. The proposed amendment sets the stage for the Department of State to create a rule similar to the Department of Commerce Export Administration Regulations (“EAR”) “encryption carve-out,” which was finalized on June 3, 2016. The export community has anticipated a harmonization of the ITAR with the EAR encryption rule. … We will monitor these developments as the proposed amendment moves through the federal rulemaking process and provide updates as necessary. . . .

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3rdwave) [Excerpts.]
* Author: Ned Blinick, Chief Product Officer,
The risk from regulatory agencies governing international trade is increasing. The importer’s exposure to CBP and PGAs, such as FDA, USDA, and others, is rising. The penalties are not only directed at the company but to corporate executives as well.

This is not some far-off threat. The regulatory risk for the Importer and the”C” suite is the new reality brought about by the significant changes with CBP, Commerce, ICE, IRS, FDA, Fisheries and Wildlife, TTB, and every other agency that is linked 
to activity at the border. It is the consequence of ACE and its incredible capabilities to support massive data collection, predictive analytics, and artificial intelligence.

“The Department of Commerce just called – help!” . . . . This scenario is now playing out with more frequency because all the regulatory partners and CBP are sharing information. With this vast source of data these agencies more effectively profile and target suspected abusers.
The Changing Risk Profile for Importers. 
The entire compliance environment is being turned upside down. With the roll-out of CBP’s $4.5B ACE environment, the entire regime at the border has changed. As I already mentioned, ACE is now the clearing-house for all import related data – regardless of the regulatory agency. Whereas several years ago, import information was held in regulatory agency silos, ACE now provides cross-department gathering and centralized access to importers declaration at any border point. With this incredible data pool CBP, FDA, UDA, FSW, and other agencies are cross-referencing importer declarations and determining the accuracy and consistency of entries. With this data mining capability, these agencies are creating importer profiles and determining an importer’s risk level. . . .
From Informed Compliance to Enforced Compliance
CBP has moved significantly from focusing on informed compliance (under the Mod Act) to enforced compliance (under TFTEA – Trade Facilitation Trade Enforcement Act).
This will evidence itself in three fundamental ways:
  • Detection – more exams, inspections, and reviews for those importers with suspect profiles. These actions are possible because of the centralization of expertise in the CEEs, the ability to mine the vast amounts of data and use predictive analytics, and the ability to leverage industry intelligence and industry collaboration.
  • Deterrence – CBP and regulatory agencies are more aggressive in the use of penalties and fines to change importer behavior. They are increasing “bond” requirements as another lever to influence poor importer actions. And, they will be more aggressive in fine collections than they have been in the past. In some instances, they will use publicity (both corporate and personal) to deter future activity.
  • Disruption – CBP is using the full range of enforcement tools to disrupt the import activity of poor actors to ensure compliance.
What this means for the Trade Compliance “C” Suite.
With the new regime of TFTEA and ACE there is much greater emphasis placed on the importer and its management to ensure its own compliance. To ignore this fact places the organization and its management at potential risk.
An example of how things are changing: Historically an importer would/could depend on the customs broker to classify products with little fear of serious consequences of misclassification. Recent studies have shown that customs brokers “too often” misclassify products due to unfamiliarity with a product, lack of time, typing errors, etc. With the changes in the focus of CBP and PGAs, the practice of outsourcing product classification is much riskier because product misclassification is a serious red flag for an importer’s Reasonable Care practices. 
This single problem can lead to serious problems with regulatory agencies.
Importers with suspect compliance profiles can expect their shipments to incur delays due to greater scrutiny. This will result in disruption at the time of entry. However, even after the shipments have cleared the border, suspect importers can expect to receive a greater number of CF28s and 29s, Single Issue Audits, and Focused Assessments. The involvement of CBP and PGA auditors in a company is very time consuming, invasive, and invariably leads to some penalties or fines. Or worse, audits can lead to negative publicity for the organization and/or its management,
On the positive, importers who have strong records of compliance will be given preferential treatment at the border and subsequently in the frequency of focused audits.

Four Takeaways to Reduce Trade Compliance Risk:
  1. Ensure product master and account records are centralized, accurate, and up to date. Best practices strongly suggest that the importer take responsibility to classify its products to the 10-digit HS code and properly profile products for associated government agencies. Similarly, all relevant account details should be maintained, and all registration codes controlled.
  2. Have well documented standard operating procedures (SOPs) in place. These SOPs must reflect internal practices and external relationships. Best practices require manuals governing import processes and record management, customs broker responsibilities and review mechanics, supplier facility management and review procedures, and carrier oversight procedures.
    • Systematize processes to reflect SOPs. Have clear import processes to govern practices with suppliers, customs brokers, carriers, 3PLS, warehouses. 
    • Audit entries and ensure the accuracy of the information submitted to customs and PGAs. 
  3. Have record and document management systems to support all import activity.
  4. Understand how dramatically the rules governing importing have changed. CBP and PGAs are now focusing more on enforcement and penalties.
Take Control of Your Compliance Practices.

The risk to importers has risen with the completed implementation of ACE and the CEEs. ACE brings increased exposure of an importer’s regulatory compliance practices to CBP through the CEEs and the relevant PGAs.

With increased visibility to importer data, regulators can now profile an importer and target its activity appropriately and proportionately. In the past, CBP was much more forgiving and instructive following the guidelines of ModAct. Today, CBP and the PGAs are much more aggressive in their approach to trade compliance practices under the TFTEA mandate. This increases the risks for both an organization and its management.

To reduce the risk to the organization and its management, an importer must take greater control of its compliance practices. Control means ensuring data accuracy, comprehensive record management, and enforceable SOPs. Failure to act appropriately exposes the importer to significantly greater organizational and personal risk.

As CBP frequently points out in virtually every discussion – “Importing is a privilege. Ignorance of the import rules is no excuse. The organization and its management is responsible for the declarations made to customs and the PGAs on its behalf.”

Maintaining a trade compliance status-quo is a very risky position for an importer. The consequences are very uncomfortable to contemplate.

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COM_a311. Tuttle Law: “20 Nov 2019 (this Wednesday) is the Last Day to File Extension for List 1 Initial Exclusion”

(Source: Author)

The initial exclusions granted for List 1 ($34 billion) on December 28, 2018 are set to expire December 28, 2019. Requests to extend the expiration date on these initial granted exclusions are being accepted through November 30, 2019 (
84 FR 58427 of 10/31/2019).

Request forms are located under Docket USTR-2019-0019 at www.regulations.gov. The USTR will individually evaluate each exclusion comment and request for extension based on the information submitted. 

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MS_a112. Monday List of Ex/Im Job Openings: 106 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;
* Advanced Concepts & Technologies International, Lexington Park, MD; Foreign Disclosure Specialist 

* Ajilon; Princeton, NJ;
Import and Export Coordinator

* Ajilon; Rochelle Park, NJ; Import and Export Coordinator;

* 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

* 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;

* Boeing Defence UK; Bristol, UK;  Trade Control Specialist;
Requisition ID: 00000161462

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

* BVI;Waltham, MA Import and Export Specialist;

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;

* Chanel;
Piscataway, NJ;  Customs Compliance Manager; Requisition ID: Q00023895

* 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;

* 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; Wetzlar, Germany;  Trade Compliance Manager; Requisition ID:

* 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;

* 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 

Newport News Shipbuilding; Newport News, VA; International Trade Compliance Analyst 3; Requisition ID: 33213BR

* 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:

* 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

* 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: 3564

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

* 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

Total Logistics Resource; Portland, OR; Logistics Specialist; Requisition ID 1044
* Total Logistics Resource; Portland, OR; Ocean Export CSR; Requisition ID 1061 

* Triumph Group; Berwyn, PA; Director, International Trade Compliance; Requisition ID:

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

* 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_a214. 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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* Soichiro Honda (17 Nov 1906 – 5 Aug 1991; was a Japanese engineer and industrialist. In 1948, he established Honda Motor Co., Ltd. and oversaw its expansion from a wooden shack manufacturing bicycle motors to a multinational automobile and motorcycle manufacturer.)
  – There is a Japanese proverb that literally goes ‘Raise the sail with your stronger hand’, meaning you must go after the opportunities that arise in life that you are best equipped to do.
  – Success represents the 1% of your work which results from the 99% that is called failure.
Monday is Punday:
* Q. What do you call a magic dog?
   A: A Labracadabrador.
* Q: Did you hear about the actor who fell through the floorboards?
   A: He was just going through a stage.
* Q: What kind of music do mummies listen to?
   A: Wrap music.

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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.

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* 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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