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19-1223 Monday “Daily Bugle”

19-1223 Monday “Daily Bugle”

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this subscription link
Monday, 23 December
2019

[No items of interest noted today.]
  1. Items Scheduled for Publication in Future Federal Register Editions 
  2. Commerce/BIS: (No new postings.)  
  3. DHS/CBP: “Update on New Minimum Security Criteria (MSC) for Customs Trade Partnership Against Terrorism (CTPAT) Members 
  4. State/DDTC: Modifications Due to Christmas Holiday 
  5. State/DDTC: Commodity Jurisdiction Form DS-4076 Version 3.0 is Now Live! 
  6. UK: “Guidance on Exporting Firearms, Ammunition, and Related Equipment” 
  1. ST&R Trade Report: “USMCA Legislation Approved in House, Could See January Vote in Senate”
  1. Reeves & Dola: “Latest News on Transfer of Jurisdictional Control of Guns & Ammo from State to Commerce” 
  2. Dinsmore & Shohl: “Wait, I Might Be Participating in a Boycott? 
  3. Holland & Knight: “Is Your Company Prepared to Comply with the New USMCA?” 
  1. Monday List of Ex/Im Job Openings: xxx Posted This Week, xx New Openings 
  1. FD Associates Presents “ITAR for the Empowered Official & Compliance Personnel” 29-30 Jan in Tysons Corner, VA 
  2. Full Circle Compliance Presents: Export Compliance Training Seminars 
  1. Bartlett’s Unfamiliar Quotations 
  2. Are Your Copies of Regulations Up to Date? Find the Latest Amendments Here! 
  3. Weekly Highlights of the Daily Bugle Top Stories 

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EXIMITEMS FROM TODAY’S FEDERAL REGISTER

EXIM_a1
[No items of interest today.]

OGSOTHER GOVERNMENT SOURCES

OGS_a11
. Items Scheduled
for Publication in Future Federal Register Editions

(Source: Federal Register)

 

*
Treasury/OFAC: Notices: Blocking or Unblocking of Persons and Properties (Publication date: 26 Dec 2019)

 

back to top

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OGS_a22
. Commerce/BIS: (No new postings.)

(Source: Commerce/BIS)

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

(Source:
CSMS #41052241, 19 Dec 2019.)

 
Dear CTPAT member: As we get closer to the end of the year, we thought we would provide you with an update on the new Minimum Security Criteria (MSC), including program expectations from its members and the work that the program is conducting in order to update the security profile in the CTPAT portal to reflect the new MSC. Four key issues to highlight:
 
   (1) The final versions of the new MSC were uploaded to the CTPAT portal on Nov. 27, 2019.  Please go to the “Public Documents” section of the portal, select “Public Library,” and under “Type,” select “Guide.”  These versions and the versions published in the portal back in May of this year are very similar.  Once the new CTPAT website is finalized, the new MSC will be uploaded there as well.  The main difference between the early “Booklet” versions of the MSC (May 2019) and the new MSC Documents (Nov. 2019) is the addition of two new criteria that apply to all entities: the first one is that members must have a code of conduct in place (ID Number 11.5), and the second is that members must initiate their own internal investigation of a security breach as soon as they are aware of the incident (ID Number 7.37).  Additional criteria were developed for the sea carrier members. The MSC for highway carriers, long-haul highway carriers, and foreign manufacturers has been or will be translated into both Spanish and French. Some of the other criteria will also be translated into other foreign languages, including Chinese and Vietnamese.  Once the translations have been conducted, they will be posted in both the portal and the CBP website. 


 
   (2) All CTPAT members will need to comply with the new requirements by January 2020.  Since members are on a four-year validation cycle, most members will not undergo a revalidation in 2020 – but all members need to comply with the new requirements by January 2020.
 
   (3) The CTPAT portal and its security profile  – The CTPAT portal is being updated so that the future security profile reflects the new MSC.  We expect the new security profile to be ready by June 1, 2020. In the meantime, the program is putting together Excel-based security profiles for each business entity eligible for CTPAT.  These Excel-based files will be made available to the members on Dec. 20, 2019.  Members will need to familiarize themselves with the security profile questions.  Once the new security profile in the portal has been updated, members will need to update their security profiles in the portal. As a result of this work, members should be receiving several alerts from the program related to the CTPAT portal.  The first alert to be soon is that the security profile will be unavailable from March 1- June 1, 2020.


 
   (4) Resources – A lot of resources have been uploaded to the CTPAT portal in the “Public Documents/Public Library” section.  Please make use of these resources as you implement the new MSC.

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

 
The federal government will be closed on Tuesday and Wednesday, December 24-25, for the Christmas holiday. Due to minimal staffing during December 23-27, DDTC has cancelled the 3:00 p.m. courier drop-off/pick-up for the week. The DDTC Response Team and DDTC Help Desk will be open on Monday, Thursday, and Friday, but depending on volume, most responses may be delayed until the following week.

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

OGS_a55. State/DDTC: “Commodity Jurisdiction form DS-4076 Version 3.0 is now LIVE!”

 
The new collection format for Commodity Jurisdiction form DS-4076 is now available on the DDTC DECCS portal.  The changes address additional sources of jurisdiction considerations and refinements to the supporting information. 
All previous submissions to the application are currently available through the DECCS CJ Launching Pad.  For users with existing forms in ‘Draft’ status, please review the COMPLETE form before submitting, to verify accuracy of the entire form.  For completed submissions, the documentation of the original submission is available in PDF form.  This ensures the historical accuracy of the submissions, while keeping the system in line with the current version of the form.
 
If you have any questions regarding these changes, please contact the DDTC Help Desk at the following contact information: DDTC Help Desk, dtradehelpdesk@state.gov, 202-663-2838.

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

Overview. Firearms, and their parts, components, accessories or ammunition and related software and technology are controlled strategic goods. Unless an exception applies, you will need a licence to export any controlled firearms from the UK to another country. This applies even if the export is temporary, such as for an exhibition, a competition or for the purpose of a holiday. 

COMNEWS

NWS_a17.
ST&R Trade Report: “USMCA Legislation Approved in House, Could See January Vote in Senate”

(Source:
Sandler, Travis & Rosenberg Trade Report, 23 Dec 2019)[Excerpts.]
 

Legislation to implement the U.S.-Mexico-Canada Agreement updating NAFTA passed the House of Representatives Dec. 19 by a vote of 385 to 41. Senate Majority Leader Mitch McConnell, R-Ky., has said he will bring the bill up for Senate consideration in January after a trial concerning the impeachment of President Trump. Canada has yet to ratify the USMCA and Mexico must still approve recent revisions made by the U.S. As a result, the agreement is not likely to take effect until mid-2020 at the earliest. …

COMCOMMENTARY

COM_a18.
Reeves & Dola: “Latest News on Transfer of Jurisdictional Control of Guns & Ammo from State to Commerce”
 

(Source: Author) [Excerpts.]
 

* Author: Johanna Reeves, Esq., jreeves@reevesdola.com; Reeves & Dola LLP.  

 
On November 12, 2019, the U.S. Department of State notified Congress of its intention to transfer jurisdictional control of certain firearms and ammunition over to the U.S. Department of Commerce. The notification is required under Section 38(f)(1) of the Arms Export Control Act (22 U.S.C. 2778(f)(1)), which states that the President may not remove any item from the Munitions List until 30 days after the date on which the President has provided notice of the proposed removal. The Notification was published in the  November 13, 2019 Congressional Record (Senate).
 
The thirty-day clock was due to run December 11, 2019, which means the final rules could have been published some time before the end of the year or early January. But Senator Menendez, the Ranking Member in the Senate Foreign Relations Committee, has once again issued a hold to block the transition from going to final. Many will recall earlier this year when Senator Menendez placed a hold against the proposed Munitions List revisions when the State Department sent its first 38(f) notification in February. The Senator’s hold, although not legally binding, nevertheless resulted in stopping the revisions from going to final back then. The question now is whether we will again experience an indefinite pause on seeing the transition rules published and implemented. …
 
Excerpts from Senator Menendez’s press release are available HERE. The letter Senator Menendez sent to Secretary of State Mike Pompeo is available HERE.

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COM_a29. Dinsmore & Shohl: “Wait, I Might Be Participating in a Boycott?”

(Source: National Review, 20 Dec 2019) [Excerpts.]


 
* Author: Ivan Bilaniuk, Esq., ivan.bilaniuk@dinsmore.com, 202-559-3611,
Dinsmore & Shohl LLP
Recent enforcement actions initiated by the U.S. Bureau of Industry and Security’s (“BIS”) Office of Antiboycott Compliance (“OAC”) serve as a warning to U.S. persons (including U.S. companies) with business interests in and around the Middle East. It is easy for the complacent to run afoul of OAC’s Antiboycott Regulations when evaluating and responding to otherwise routine documents such as a letters of credit, shipping certificates, or purchase orders.
In mid-2019, Zurn Industries, LLC, a plumbing manufacturer, paid $54,000 to settle allegations it had failed to report to the U.S. Department of Commerce seemingly benign inquiries from the United Arab Emirates and Qatar about legal compliance. This was the first enforcement case brought by OAC since the Export Control Reform Act of 2018 provided permanent statutory authority for the Antiboycott Regulations. 
The Antiboycott Regulations prohibit U.S. persons, including “controlled in fact” foreign subsidiaries of U.S. companies, from complying with foreign [F/N 1] boycott requests regarding a business opportunity within “interstate or foreign commerce of the United States.” Such compliance with a boycott request could take the form of a refusal to do business, a selection of one bidder over another, or an avoidance of work with certain entities or persons due to their presence on a blacklist, if such action was taken for “boycott reasons.” [F/N 2]
Zurn allegedly committed 27 violations of the Antiboycott Regulations when it failed to report “boycott requests,” including requests for:
  • A certificate stating that “the carrying vessel is allowed by Arab authorities to call at Arabian ports during its voyage to the United Arab Emirates”; and
  • A certificate from the vessel “showing its name, flag and nationality and also confirming that it is allowed by Qatar authorities to call at Qatar ports by honouring Qatar laws and regulations during its present voyage to destination port.”
These seemingly innocuous legal compliance questions make no mention of Israel or terms such as “boycott” or “blacklist.” Yet, these requests have the purpose of furthering a foreign boycott of Israel. Failure to catch, report, and to the extent required, modify the boycott requests may be costly. The maximum civil monetary penalty is $300,000 per violation, or twice the value of the transaction in question, whichever is greater. [F/N 3] Zurn paid $54,000 to settle 27 alleged violations that had a total maximum civil penalty of at least $8.1 million. …
Though boycott requests can be difficult to spot to the untrained eye, merely failing to report the request is itself a violation for which a civil penalty may be assessed. Consenting to such a request constitutes a second independent violation for which a second civil penalty may be assessed. Declining a business opportunity with “boycott intent” is also prohibited. For example, you may not refuse to purchase from a certain supplier because you know the supplier is blacklisted in a country for boycott reasons.
The UAE and Qatar, along with many other Arab League countries such as Iraq, Kuwait, Lebanon, Libya, Saudi Arabia, Syria, and Yemen, participate in the boycott of Israel. The U.S. Treasury Department publishes a non-exhaustive quarterly list of “boycotting countries” in the Federal Register that currently lists these countries. [F/N 4] If a transaction involves a listed country, that is a red flag, and those documents and communications should be subject to greater scrutiny. But the Treasury List is not exhaustive, and countries that are not members of the Arab League, such as Pakistan, Bangladesh, Brunei, and Iran, also boycott Israel. 
In addition to the BIS Antiboycott Regulations, the U.S. Treasury Department administers a second set of similar antiboycott regulations. [F/N 5] Violations of the Treasury regulations result in tax consequences rather than civil penalties, intent is not required, and the scope is not limited to activities in “interstate or foreign commerce of the United States.” …
In short, if doing business in the Middle East, make sure your compliance program addresses antiboycott compliance. Be vigilant in communications and when reviewing documents from counterparties that pose facially harmless compliance questions, and consider engaging legal counsel as needed.


[1] The Antiboycott Regulations pertain to foreign boycotts-domestic boycotts are not covered.
[2] See, e.g., 15 C.F.R. § 760.2(1)-(8).
[3] 50 U.S.C. § 4843(b)(1).  The Anti-Boycott Act of 2018, a part of the Export Control Reform Act of 2018, also allows for revocation of export control licenses or a prohibition on a violator’s ability to export controlled items, in addition to criminal penalties of up to $1 million or 20 years in prison, or both.  50 U.S.C. § 4843(a)-(b).
[4] 84 FR 54730, Oct. 10, 2019.
[5] 26 U.S.C. § 999.

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

(Source:
Holland & Knight Alerts, 18 Dec 2019) [Excerpts.] 
 
* Principal Author:
Carlos Vejar, Esq.,
Holland & Knight LLP 

Highlights:

  • Final amendments to the United States-Mexico-Canada Agreement (USMCA) have been agreed to, clearing the path for its approval in the U.S., most likely during the first trimester of 2020.
  • Complete free trade on goods and services remains in place, with no clawback on tariffs or services reserves. However, USMCA is a 34-chapter Agreement, plus annexes and side letters, that comprise obligations related with many other disciplines such as intellectual property, e-commerce, labor, environment, anticorruption, investment, etc., where many new obligations can be found.
  • The USMCA will bring many changes to trade relations, so companies should give new chapters and disciplines an in-depth analysis, while reviewing cross references, footnotes, annexes and side letters as well as closely following new implementing legislations in the three USMCA countries.
Final amendments to the United States-Mexico-Canada Agreement (USMCA) were agreed to on Dec. 9, 2019, clearing the path for its approval in the U.S., most likely during the first trimester of 2020. Once approved by all three parties , the Agreement would enter into force three months after, most likely in the second half of 2020 (unless the parties agree otherwise) securing more than $1.3 trillion in annual trade with Mexico and Canada, and an estimate of close to 3 million U.S. jobs.
 
Much has been said about how the USMCA improves upon the North American Free Trade Agreement (NAFTA) and how much of it is original text . This, of course, is debatable given that much of its text maintains NAFTA existing obligations and that many of the new obligations are similar to those of the original Trans-Pacific Partnership Agreement (TPP) , although “few terms can have big repercussions,” as stated in a University of Ottawa Faculty of Law analysis on this subject . The bottom line is that there are substantive changes under USMCA that will impact how businesses are conducted in North America.
 
For starters, complete free trade on goods and services remains in place, with no clawback on tariffs or services reserves. However, USMCA is a 34-chapter Agreement, plus annexes and side letters, that comprise obligations related with many other disciplines such as intellectual property, e-commerce, labor, environment, anticorruption, investment, etc., where many new obligations can be found.
 

Changes Likely to Affect Companies
  

Aside from new chapters on Good Regulatory Practices, Digital Trade, and Small and Medium-Sized Enterprises, as well as those chapters addressing unfair trade practices (i.e. Currency Manipulation, State-Owned Enterprises, Non-Market Economies and Anticorruption), other significant specific changes were made regarding Investor State, Dispute Settlement, Auto Rules of Origin, Agriculture, Customs and Trade Facilitation, Intellectual Property Rights (IPR), Labor, Environment, Financial Services, Barriers to Trade, and Sanitary and Phytosanitary Measures. All of these changes raise a lot of questions and should be of concern to many private actors.
 
For example, USMCA does not contain investor-state dispute settlement obligations between Canada (or Canadian investors/investments) and the United States (or U.S. investors/investments). Therefore, Canadian and U.S. investors may want to look into forum shopping to obtain protection under another treaty or look into establishing their businesses in Mexico.
 
USCMA is a significant improvement from NAFTA regarding its original Labor Side Agreement obligations, as specific obligations will be subject to review by third-party experts, which may result in tensions and require serious improvement in companies’ existing labor conditions to avoid penalties or suffer the consequences of seeing their exports blocked. Export companies established in Mexico may want to seek for preventive compliance guidance.
The Rules of Origin Chapter will allow authorities to request all the accounting records of an exporter or importer to verify the USMCA rules of origin compliance, something not allowed under NAFTA unless authorities made a visit to a company’s premises where they could require access to such records.  
 
Now, all of it could be required and provided electronically, raising serious questions about the authority’s wide criteria to determine the origin based on a detailed review of up to thousands of documents. If the rules of origin are not complied with, payment of tariffs, fines and surcharges for exports made up to five years ago will be required. Exporters may want to revisit their exports under these new rules as well as any amendments made to the applicable rules of origin;
 
Contrary to what the new one-page chapter on Energy may suggest by reiterating Mexican Constitutional language, Chapter 8 relating to Mexican sovereignty over hydrocarbons, the USMCA will protect foreign investors and investments in Mexico in the energy sector. USMCA Article 32.11 remands  to other existing treaties’ existing protections (i.e., the CPTPP), incorporating by reference investment protections under the new USMCA, but such protection is not horizontal and some investments will have fewer protections than those they held under NAFTA.  Investors should confirm what specific protections will be available to them.
 
In Customs Administration and Trade Facilitation, the so-called deminimis margins will be raised both for Mexico and Canada, providing further certainties to express shipments. However, local implementation may present some additional burdens that exporters may need to examine.
 
Intellectual property obligations were revamped, and changes can be found in all major IP rights: Patents and data protection for biologic drugs and agricultural chemicals, copyright and related rights with mechanisms to avoid circumvention of technological protections, increased protection for trade secrets, confirming rights to use common names of products when conflicting with geographical indications, etc.
 

Conclusion and Considerations

The above are just a few specific examples of the many changes that USMCA will bring to trade relations (particularly with regard to new chapters and disciplines mentioned). Companies should give each a more in-depth analysis, while reviewing cross references, footnotes, annexes and side letters as well as closely following new implementing legislations in the three USMCA countries.
 

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

MSEX/IM MOVERS & SHAKERS

MS_a111. Monday List of Ex/Im Job Openings: 103 Jobs Posted This Week, Including 1 New Opening

(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 
jobs@fullcirclecompliance.eu
.  Listings are free.
 
* COMPANY; LOCATION; POSITION TITLE (WEBLINK); CONTACT INFORMATION; REQUISITION ID
 

#
” 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  

* Agility; Dallas, TX
Air/ Ocean Import Coordinator
;

* Ajilon; Rochelle Park, NJ; Import and Export Coordinator; 
* Ajilon; Woodbridge, NJ;
Import and Export Coordinator; Requistion ID: US_EN_7_849144_2724903

* Ajilon; Elizabeth, NJ;
Ocean Air Import and Export Specialist
;

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

*
Amazon Web Services; Seattle, WA, Washington, DC, Portland, OR; Export Compliance Specialist; Requisition ID: 997908

* American Honda Motor Co., Inc.; Torrance, CA; Assistant Manager-Customs; Mark Hirzel: mark_hirzel@ahm.honda.com; Requistion ID: AHM0004QR  

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

* Arrow Electronics; Zapopan, Mexico; Transportation Coordinator II; 
luci.desouza@arrow.com
; Requisition ID: R172262
 
* Arrow Electronics: Zapopan, Mexico; Transportation Coordinator II; 
luci.desouza@arrow.com
; Requisition ID: R172264

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

* 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

*BHGE; Houston, TX; Trade Export Control Compliance Specialist; Requistion ID: 19-04091

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

* Boeing; Bengaluru, Karnataka; Global Trade Control Specialist; Requisition ID: 00000121886

* 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
;


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

* Chanel;
Piscataway, NJ;  Customs Compliance Manager; Requisition ID: Q00023895
* CGI Federal Inc., Fairfax, VA, Trade Compliance Analyst; Ann Runfola (ann.runfola@cgifederal.com), Requisition ID #J0919-0237  

* Cobham Advanced Electronic Solutions; Exeter, NH; 
Import/Export Specialist
Requisition ID: 3043

* Cobham Advanced Electronic Solutions; San Diego; 
Manager, USG Compliance
; Requisition ID:2730

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

* Collabera;
Houston, TX; Trade Compliance Analyst; Requisition ID: 831120
* DHL Express; Erlanger, KY; Export Compliance Manager (L3); Requisition ID: 19001AZ
* DSG Global; Boston, MA; Trade Compliance Specialist
* Edwards; Irvine, CA; Associate Analyst, Global Trade Compliance; Requisition ID: 021628

* Elbit Systems of America; Merrimack, NH; 
Associate Trade Compliance
; Requisition ID: 2019-7273 

* Estée Lauder Companies, Melville, NY;  Director, Trade Compliance – US Import and Export; Requisition ID: 1919790

* Estée Lauder Companies, Melville, NY; Executive Director, Global Trade Compliance; Requisition ID: 1924550
* Estée Lauder Companies, Melville, NY; Director, US Special Projects Trade Compliance; Requisition ID: 1919791

* Expeditors; Bedfont, United Kingdom;
Customs Brokerage Clerk 

* Fanatics; Tampa, FL; Global Trade Compliance Specialist;

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


* General Atomics; San Diego, CA;  Government Compliance Manager; Requisition ID:
24752BR

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

* General Atomics; San Diego, CA; Import/Export Specialist
; Requisition ID:
24336BR

* GE Aviation; Lynn (Boston), Evendale (Cincinnati); Grand Rapids, MI; Senior Counsel – Manager Export Compliance; Requisition ID: 3382028
* GE Aviation; Evendale (Cincinnati),OH ; Lynn (Boston), MA; Grand Rapids, MI; ITC Operations Leader; Requistion ID: 3382030

* Hexagon Positioning Intelligence; Trade Compliance Specialist; Requisition ID: 2019-1661

* 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

* L3Harris; Clifton, NJ; Senior Trade Compliance Specialist;
Requisition ID:
SAS20190509-33185

* L3Harris; Tewksbury, MA; Export Compliance Administrator; Requisition ID: AS20191112-113054

* 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:
493288BR

* Lockheed Martin Aeronautics; Fort Worth, TX; International Trade Compliance Intern; Requisition ID:
487961BR

* Mars; Aimargues, France; Global Trade Officer and Public Affairs

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

* Medtronic;
Columbia Hights, MN; Associate Export Controls Analyst;
Requisition ID:
19000EXL

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

* Miller Canfield; Troy, Mi;
Associate Attorney – Mergers & Acquisitions; 
brennans@millercanfield.com

* 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, Scotland; Export Control Officer; Requisition ID: 164429MET_1576227347 

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

* 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  

* Agility; Dallas, TX 
Air/ Ocean Import Coordinator
;

* Ajilon; Rochelle Park, NJ; Import and Export Coordinator; 
* Ajilon; Woodbridge, NJ; 
Import and Export Coordinator; Requistion ID: US_EN_7_849144_2724903

* Ajilon; Elizabeth, NJ; 
Ocean Air Import and Export Specialist
;

AM General; Auburn Hills, MI; International Compliance Analyst  


Amazon Web Services; Seattle, WA, Washington, DC, Portland, OR; Export Compliance Specialist; Requisition ID: 997908

* American Honda Motor Co., Inc.; Torrance, CA; Assistant Manager-Customs; Mark Hirzel: mark_hirzel@ahm.honda.com; Requistion ID: AHM0004QR  

* Arrow Electronics; Denver, CO; Transportation Import/Export Specialistamanda.elam@arrow.com; Requisition ID: 172946
* Arrow Electronics; Zapopan, Mexico; 
Transportation Coordinator II
luci.desouza@arrow.com
; Requisition ID: R172262
  * Arrow Electronics: Zapopan, Mexico; 
Transportation Coordinator II
luci.desouza@arrow.com
; Requisition ID: R172264

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

* 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

*BHGE; Houston, TX; Trade Export Control Compliance Specialist; Requistion ID: 19-04091

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

* Boeing; Bengaluru, Karnataka; Global Trade Control Specialist; Requisition ID: 00000121886

* 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
;


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

* Chanel; 
Piscataway, NJ;  Customs Compliance Manager; Requisition ID: Q00023895
* CGI Federal Inc., Fairfax, VA, Trade Compliance Analyst; Ann Runfola (ann.runfola@cgifederal.com), Requisition ID #J0919-0237  

* Cobham Advanced Electronic Solutions; Exeter, NH; 
Import/Export Specialist
Requisition ID: 3043

* Cobham Advanced Electronic Solutions; San Diego; 
Manager, USG Compliance
; Requisition ID:2730

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

* Collabera;
Houston, TX; Trade Compliance Analyst; Requisition ID: 831120
* DHL Express; Erlanger, KY; Export Compliance Manager (L3); Requisition ID: 19001AZ
* DSG Global; Boston, MA; Trade Compliance Specialist
* Edwards; Irvine, CA; Associate Analyst, Global Trade Compliance; Requisition ID: 021628

* Elbit Systems of America; Merrimack, NH; 
Associate Trade Compliance
; Requisition ID: 2019-7273 

* Estée Lauder Companies, Melville, NY;  Director, Trade Compliance – US Import and Export; Requisition ID: 1919790

* Estée Lauder Companies, Melville, NY; Executive Director, Global Trade Compliance; Requisition ID: 1924550
* Estée Lauder Companies, Melville, NY; Director, US Special Projects Trade Compliance; Requisition ID: 1919791

* Expeditors; Bedfont, United Kingdom; 
Customs Brokerage Clerk 

* Fanatics; Tampa, FL; Global Trade Compliance Specialist;

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


* General Atomics; San Diego, CA;  Government Compliance Manager; Requisition ID: 
24752BR

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

* General Atomics; San Diego, CA; Import/Export Specialist 
; Requisition ID:
24336BR

* GE Aviation; Lynn (Boston), Evendale (Cincinnati); Grand Rapids, MI; Senior Counsel – Manager Export Compliance; Requisition ID: 3382028
* GE Aviation; Evendale (Cincinnati),OH ; Lynn (Boston), MA; Grand Rapids, MI; ITC Operations Leader; Requistion ID: 3382030

* Hexagon Positioning Intelligence; Trade Compliance Specialist; Requisition ID: 2019-1661

* 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

* L3Harris; Clifton, NJ; Senior Trade Compliance Specialist
Requisition ID:
SAS20190509-33185

* L3Harris; Tewksbury, MA; Export Compliance Administrator; Requisition ID: AS20191112-113054

* 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: 
493288BR

* Lockheed Martin Aeronautics; Fort Worth, TX; International Trade Compliance Intern; Requisition ID: 
487961BR

* Mars; Aimargues, France; Global Trade Officer and Public Affairs

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

* Medtronic;
 Columbia Hights, MN; Associate Export Controls Analyst
Requisition ID: 
19000EXL

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

* Miller Canfield; Troy, Mi; 
Associate Attorney – Mergers & Acquisitions; 
brennans@millercanfield.com

* 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, Scotland; Export Control Officer; Requisition ID: 164429MET_1576227347 

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


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

* The Ohio State University; Columbus, Ohio; Senior Export Control Officer;Jessa Albertson; Requisition ID: 455560

* OpenText; San Mateo, CA; Export Compliance Analyst;

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

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

* Pittleman & Associates; Washington, D.C.; Sanctions/Export Control Attorney

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

* PolyOne, Avon Lake, OH; Trade Compliance Analyst  
* Raytheon; Andover, MA; Global Trade (GT) Licensing Manager And Empowered Official; Requisition ID: 143920BR  

* Raytheon; Andover, MA;  Sr An Global Trade Licensing; Requisition ID:
147196BR

* Raytheon;Dellas, VA ;
 Sr. Analyst Global Trade Licensing; 
Requisition ID:
152453BR

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

* Rolls-Royce; Peterborough, ON, Canada; Export Control Officer; Requisition ID: JR6056661

* SABIC; Houston TX; 
Senior Analyst, Trade Compliance

Danielle.Cannata@sabic.com
; Requisition ID: 8411BR

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


* Saudi Aramco; Dhahran, Saudi Arabia; 
Paralegal
; 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

* 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;   

* Thomas Jones Consulting; Washington, DC; 
Jr. International Trade, Export Controls & Economic Sanctions Associate 

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

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

info@torrestradelaw.com   
*
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: 
17504 

* United Technologies; Haute-Garonne, France; Export Control Officer;
Requisition ID: 
17485

* U.S. Department of State; Washington, DC; Directorate of Defense Trade Controls (DDTC), Office of Defense Trade Controls Compliance (DTCC),Supervisory Compliance Specialist; Requisition ID: HRSC/T/PM-2020-0004

* Wealth Ocean; Newport Beach, CA; Marketing & International Trade Specialist 

# Newport News Shipbuilding; Newport News, VA;
International Trade Compliance Analyst 3; Requisition ID: 33212BR


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

* The Ohio State University; Columbus, Ohio; Senior Export Control Officer; Jessa Albertson; Requisition ID: 455560

* OpenText; San Mateo, CA; Export Compliance Analyst;

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

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

* Pittleman & Associates; Washington, D.C.; Sanctions/Export Control Attorney

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

* PolyOne, Avon Lake, OH; Trade Compliance Analyst  
* Raytheon; Andover, MA; Global Trade (GT) Licensing Manager And Empowered Official; Requisition ID: 143920BR  

* Raytheon; Andover, MA;  Sr An Global Trade Licensing; Requisition ID:
147196BR

* Raytheon;Dellas, VA ;
Sr. Analyst Global Trade Licensing;
Requisition ID:
152453BR

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

* Rolls-Royce; Peterborough, ON, Canada; Export Control Officer; Requisition ID: JR6056661

* SABIC; Houston TX; 
Senior Analyst, Trade Compliance
;
Danielle.Cannata@sabic.com
; Requisition ID: 8411BR

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


* Saudi Aramco; Dhahran, Saudi Arabia;
Paralegal
; 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

* 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;   

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

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

info@torrestradelaw.com   
*
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:
17504 

* United Technologies; Haute-Garonne, France; Export Control Officer;
Requisition ID:
17485

* U.S. Department of St
ate; Washington, DC;
Directorate of Defense Trade Controls (DDTC), Office of Defense Trade Controls Compliance (DTCC),
Supervisory Compliance Specialist
; Requisition ID:
 
HRSC/T/PM-2020-0004

* Wealth Ocean; Newport Beach, CA;
Marketing & International Trade Specialist    
  
 
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TEEX/IM TRAINING EVENTS & CONFERENCES

TE_112.
FD Associates Presents “ITAR for the Empowered Official & Compliance Personnel” 29-30 Jan in Tysons Corner, VA
(Source: 
FD Associates
)
 
* What:  Seminar, “ITAR for the Empowered Official & Compliance Personnel” — 
Agenda
* When:  Wed-Thu, 29-30 Jan 2020
* Where: 
 
The Tower Club
, 8000 Towers Crescent Dr Suite 1700, Vienna, VA 22182
* Sponsor:  
FD Associates
* Presenters: 
Jenny Hahn, President, FD Associates. P
resenter will also be available for private counseling session
 after the workshop
.
  
*
Register 
HERE
, call 1-703-847-5801, or email 
info@fdassociates.net
.

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

TE_a213. Full Circle Compliance Presents: Export Compliance Training Seminars
(Source: Full Circle Compliance)

U.S. and EU Sanctions & Embargoes

Tuesday, 4 February 2020 in Amsterdam

Designing an ICP for Export Controls & Sanctions

Tuesday, 3 March 2020 in Amsterdam

Implementing an ICP for Export Controls & Sanctions

Wednesday, 4 March 2020 in Amsterdam

ENEDITOR’S NOTES

EN_a114. Bartlett’s Unfamiliar Quotations

(Source: Editor)


*
John Jay (23 Dec 1745 – 17 May 1829; was an American statesman, patriot, diplomat, Founding Father of the United States, abolitionist, negotiator, and signatory of the Treaty of Paris of 1783, second Governor of New York, and the first Chief Justice of the U.S. Supreme Court).

– “No power on earth has a right to take our property from us without our consent.”
 

*
Giuseppe Tomasi di Lampedusa (23 Dec 1896 – 26 Jul 1957; was an Italian writer and the last Prince of Lampedusa. He is most famous for his only novel, Il Gattopardo, which is set in his native Sicily during the Risorgimento.)
– “If we want things to stay as they are, things will have to change.”

Monday is pun day:

* What does Santa suffer from if he gets stuck in a chimney? Claustrophobia.
* How you can tell that Santa enters your house? You can sense his presents.
* What do you call Santa’s little helpers? Subordinate clauses.

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

EN_a215. Are Your Copies of Regulations Up to Date?

(Source: Editor)


The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register.  The latest amendments are listed below.
 
Agency 
Regulations 
Latest Update 
DHS CUSTOMS REGULATIONS: 19 CFR, Ch. 1, Pts. 0-199.  5 Apr 2019:  5 Apr 2019: 84 FR 13499-13513: Civil Monetary Penalty Adjustments for Inflation.
DOC EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774.  13 Nov 2019: 84 FR 61674-61676Addition of Entities to the Entity List, Revision of an Entry on the Entity List, and Removal of Entities from the Entity List.
DOC FOREIGN TRADE REGULATIONS (FTR): 15 CFR Part 30.   Last Amendment: 24 Apr 2018: 83 FR 17749-17751: Foreign Trade Regulations (FTR): Clarification on the Collection and Confidentiality of Kimberley Process Certificates 
DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM): DoD 5220.22-M. Implemented by Dep’t of Defense.  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 here.)  
DOE ASSISTANCE TO FOREIGN ATOMIC ENERGY ACTIVITIES: 10 CFR Part 810.   23 Feb 2015: 80 FR 9359, comprehensive updating of regulations, updates the activities and technologies subject to specific authorization and DOE reporting requirements. 
DOE EXPORT AND IMPORT OF NUCLEAR EQUIPMENT AND MATERIAL; 10 CFR Part 110. 
25 Nov 2019: 84 FR 64740-64754: Rules of Practice in Explosives License and Permit Proceedings; Revisions Reflecting Changes Consistent With the Homeland Security Act of 2002
DOJ ATF ARMS IMPORT REGULATIONS: 27 CFR Part 447-Importation of Arms, Ammunition, and Implements of War.  14 Mar 2019: 84 FR 9239-9240: Bump-Stock-Type Devices.

DOS INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR): 22 C.F.R. Ch. I, Subch. M, Pts. 120-130.  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.

DOT FOREIGN ASSETS CONTROL REGULATIONS (OFAC FACR): 31 CFR, Parts 500-599, Embargoes, Sanctions, Executive Orders.
22 Nov 2019:

84 FR 64415-64417: Venezuela Sanctions Regulations

USITC HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES (HTS, HTSA or HTSUSA),

1 Jan 2019: 19 USC 1202 Annex. 

 

  – HTS codes for AES are available here.
  – HTS codes that are not valid for AES are available here.

  

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