Our client is a $130M public company that provides software products and services to federal and commercial clients. They have become the world market leader in commercial applications with successful installations on five continents and major operating units in Colorado, California, and France. We are seeking a Manager of Import/Export Compliance to join their team who will be responsible for all aspects of compliance with import/export regulations. While current headquarters are in Lanham, Maryland, the company will be moving to Columbia, Maryland in the coming months.
Position: The Import/Export Compliance Manager plans, directs and oversees the corporate export compliance function in conjunction with all other organizational functions of the company. This person will perform company-wide training and compliance assessments to ensure full compliance with all export control laws, regulations and policies. Read More
August 09, 2008 | By Danielle McClellan | Permalink
Electro-Glass Products was found guilty of violating the Arms Export Control Act in July 2007; in September 2007 the conviction caused the company to be debarred. The DDTC has recently posted the policy regarding new approvals for companies requesting Electro-Glass Products.
Transaction Exceptions will be granted to companies requesting Electro-Glass Products with respect to the following:
Overriding US foreign policy or national security interests;
Law enforcement interests that are consistent with foreign policy or national interests of the United States; or
Other compelling interests that are consistent with the foreign policy or national security interests of the United States. Read More
The DDTC has updated the frequently asked questions on commodity jurisdiction on their website. The FAQ’s listed were chosen based on numerous questions that the DDTC Response Team has been answering frequently.
The State Department’s DDTC issued a correction for 22CFR Part 121.1(b) of the United States Munitions List. On page 19780 of the list, in the first column, in Sec. 121.1(b), in the first line, “(b)” will now read “*(b)”.
The Bureau of Industry and Security, US Department of Commerce has denied export privileges to Winter Aircraft Products SA of Madrid for a period of 10 years. The company was denied privileges because the BIS found that the company had taken actions with intent to transship aircraft part subject to the Regulations without a license.
Although the company did not actually follow through with the transshipment, their intent was enough to deny them exporting privileges from the US. It is now an export violation to directly or indirectly export, reexport or even “think” of doing business with this company beginning on May 19, 2008.
Last year President Bush signed defense trade cooperation treaties with Britain and Australia to make trade in military items easier. The treaties are intended to eliminate the many export licenses companies must obtain before they can sell their products. These treaties will create “approved communities” consisting of companies whom can freely buy and sell MOST military items under circumstances. This should eliminate about two-thirds of the export licenses that the US Department will have to issue for military goods going to Britain and Australia.
This week President Bush has made it clear that he wants senate to put a rush on the ratifications of both treaties. Unfortunately, for both Bush and exporters the Senate has made it very clear that they will not be rushed. On May 21, 2008 members of the Senate Foreign Relations Committee explained that they need to see all the treaties details and the implementing regulations before anything will be ratified. Currently these details are being drafted, but will not be ready until the end of the summer. Read More
The Department of State has issued to Congress that Cuba, Eritrea, Iran, North Korea, Syria, and Venezuela are not fully cooperating with the United States antiterrorism efforts. John D. Negroponte, Deputy Secretary of State has issued the decision to retain the certification of North Korea pursuant to Section 40A of the Arms Export Control Act.
There will be an ongoing review of the designation of North Korea and the outcome of the review may warrant a new assessment and possible change in certification.
The United States Government has decided to take another small step to aid the peoples of Southern Sudan by agreeing to approve certain exports of defense articles to Southern Sudan to support the peace arrangement between Southern Sudan and the murderous Government of Sudan which, along with its Janjaweed henchmen, is known to support or be involved in the murdering and burning of babies, women and children as part of its genocide against certain groups in Sudan.
The Department of State alongside with Foreign Operations has authorized the US to provide non-lethal defense services to the Government of Southern Sudan. This will include military assistance, military education and training, and defense services controlled under the International Traffic in Arms Regulations. It has been determined by State that this is in the best interest of the United States and Southern Sudan and that the assistance may be provided pursuant to section 666(e) of the ITAR.
TFC Manufacturing Inc., a California-based aerospace fabrication facility has been charged with violating the “deemed export” rule. The Commerce Department’s Bureau of Industry and Security has required the company pay a $31,500 penalty.
From March to April 2006, TFC Manufacturing Inc. released unlicensed US technology for the production of aircraft parts classified under ECCN 9E991. The company gave the information to an employee who was a national of Iran, under the Export Administration Regulations; this release of technology to a national of Iran is deemed to be an export and is prohibited without a license.
Kabba & Amir Investments, Inc., d.b.a. International Freight Forwarders (IFF) of Canada have been fined $6,000 for export violations. The company is a freight forwarding company. In June 2000, IFF took possession of shipment of X-Ray Film Processors, items subject to the Regulations, and exported them to Cuba without a license.
The company worked with known and unknown co- conspirators to export the processors to Cuba via Canada without obtaining a BIS export license. IFF violated the regulations when they took possession of the items in the United States and took them to Canada.
After several reviews, and IFF claiming that they were unaware that a license was necessary, BIS found that they do not have to prove that the company knew or did know that they needed a license. As long as IFF pays their fine within 30 days of their final charging letter they will not be denied export privileges, if they do not, their export privileges will be denied for three years.
The Export Compliance Training Institute’s Economic Sanctions and Export Controls Conference at Canary Wharf, London included a keynote address from Secretary of Commerce Mario Mancuso on May 13, 2008. Mancuso discussed US policy efforts to meet US national security challenges targeting financial measures and trade controls.
Mancuso explained, “Globalization is having profound implications for financial markets, technology trade, and national security.”
After attending the Export Compliance Training Institute’s seminar, Mancuso held meetings with the UK government, industry and academic leaders. He hopes that this visit will mark a BIS effort to elevate international engagement and diplomacy with key partners and markets on national security, high technology and strategic trade issues.
Willbros Group Inc. and Willbros International Inc., a wholly owned subsidiary, have agreed to pay over $32 million in penalties, disgorgement and interested in criminal case with the Department of Justice and with the Securities and Exchange Commission. The companies are both publicly traded and provide construction, engineering and other services in the oil and gas industry. Read More
The Treasury Department’s Office of Foreign Assets Control has posted amendments to General License Number 14 and posted a new general license, General License number 15 under the Burmese Sanctions regulations.
General License Number 14 previously only authorized the transfer of funds in support of not-for- profit humanitarian or religious activities in Burma only if they involved US or third-country NGO’s. The amendment will expand the authorization for a period of 120 days to allow funding to any organization or individual engaged in not-for-profit humanitarian or religious activities in Burma. This amendment is a result of the devastation left by Cyclone Nargis, in .Myanmar, Burma
General License Number 15 allows US financial institutions to process transfers of funds, unlimited in amount, for noncommercial, personal remittances to or from Burma, or for or on behalf of an individual ordinarily resident in Burma. Before the issuance of this license noncommercial, personal remittances to Burma were permitted only insofar as total remittances did not exceed $300 per Burmese household in any consecutive three month period. This new license has no such limitations.
The “soon” is now, to paraphrase the late, great football coach George Allen. For quite a while, the Census Bureau has been saying soon it will publish the rewritten rules for the submission of Shipper’s Export Declarations (SEDs) and the Automated Export System (AES). The new rules enter into force on July 2, 2008, and on that day the SED will no longer be valid. The SED will be replaced by Electronic Export Information (EEI) that must be submitted via the AES (or AESDirect) electronic reporting system.
Nearly six years ago on September 30, 2002 the President signed the Foreign Relations Act that authorized the Commerce Department to eliminate the paper SED for all exports and require that exporters submit export information electronically. (Commerce is the mother agency of the Census Bureau’s Foreign Trade Division, which is the organization that administers the AES EEI regulations, technically known as 15 CFRP Part 30—Foreign Trade Regulations.) In the June 2, 2008 The Federal Register, the Census Bureau published the new FTR, to entirely replace the former Foreign Trade Statistics Regulations (FTSR).
So, background information aside, let’s look at the key highlights of the new FTR. Generally speaking, the FTR is quite similar to its FTSR predecessor. Based on my first read of the new FTR, here are some key changes that enter into force on July 2, 2008:
Electronic Filing Required for EAR99 Items: Formerly you could use paper SEDs for items classified as EAR99 in the Export Administration Regulations (EAR). Now everything has to be submitted via the AES EEI mechanism now. Read More
The Export Compliance Training Institute is actively seeking speakers for our Export Compliance Seminars.
We are looking for professionals with in-depth knowledge of United States trade laws and regulations and demonstrated public speaking ability. Successful applicants will be both dynamic speakers and knowledgeable about the practical implications of the rules and how they impact companies’ compliance practices and procedures.
Interested persons should send cover letter, resume and anything else which could help to demonstrate your qualifications (video, references, etc.) to:
The Export Compliance Training Institute
Attn: Jill Kincaid, Manager
243-L Neff Avenue
Harrisonburg, VA 22801 USA
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