ECTI Speaking Opportunities

September 8th, 2010 by Danielle McClellan

The Export Compliance Training Institute has earned a solid reputation as a provider of high-quality training on compliance with United States export regulations.  This is evidenced again and again by the feedback we get from our seminar participants (visit LearnExportCompliance.com/reviews to view comments).  The backbone of the success of our programs is a group of instuctors who have a rare combination of qualities:

  • A mastery and comprehensive knowledge of the current regulations
  • A history of real-world experience in helping companies develop, evaluate, maintain and improve their export compliance programs and procedures; and
  • The gift of being able to engage their audience in a complex, serious (and some might say dry?) topic with compelling examples from their experiences and moments of lightness and levity.

We are always interested in adding to our instructor staff with professionals who have these characteristics and enjoy sharing their knowledge of US export controls.  If you are aware of anyone who might be interested in joining our speaking staff, or if you have seen anyone who possesses this unique combination of talents and is an engaging speaker and want to pass that information along, please contact us at jill@learnexportcompliance.com or +1 540 433 3977.

EU New Trade Sanctions on Iran

September 7th, 2010 by John Black

As some of you know, the European Union has implement new trade sanctions on Iran.  For an interesting analysis of the new EU sanctions go to:

http://learnexportcompliance.indigofiles.com/Iran_EU_sanctions_update_July_2010.pdf

DDTC Publishes Proposed Change for Employees of Non-US End-Users and Consignees

September 7th, 2010 by John Black

One it is only a proposed rule, so it does not help anybody yet.  But if DDTC ever implements this proposed change, it will have made a big step in the direction of making life easier for countries who deal with US defense articles.  This proposal, if implemented, would, for example, eliminate the requirement that foreign (i.e., non-US) end-users and consignees on Technical Assistance Agreements and Manufacturing License Agreements first identify the nationalities of their dual national and third country national employees in the agreement application and thereafter limit access to US defense articles to only those nationalities approved on the application.  Of course, all burdens eliminated by one hand must be replaced by burdens imposed by the other hand—we will look at the details of the proposal below. Read the rest of this entry »

Great Scott Batman, Another Illegal Valve Exporter!

September 7th, 2010 by John Black

You don’t have to have Batman’s “bat senses” to figure out that the pump and valve industry is doing their part to keep US Government export enforcement personnel busy.  This time, the culprit is Tyco Valves & Controls (TVC) with 26 violations for illegal exports of ECCN 2B350 butterfly valves, ball valves, and valve assemblies to China, the UAE, Mexico, India, Israel, Brazil, Singapore, Chile, Jordan and El Salvador. The violations occurred between January 2005 and March 2007.

In this case, the US Government did not have to bring in Batman to find these illegal exports.  TVC voluntarily disclosed its violations to the Department of Commerce and agreed to pay a $218,000 penalty to settle the charges.

Stop Using License Exception TSR Now!: You Need to Get a New TSR Written Assurance

September 7th, 2010 by John Black

BIS Expands Controls on Foreign-Made Products and Changes TSR Written Assurance

In the July 30, 2010, Federal Register the Bureau of Industry and Security (BIS) published a revision to the Export Administration Regulations (EAR) that does two things.  First, it changes the requirements for what has to be in the written assurance for exports and reexports under License Exception TSR.  Second, it changes the destination countries for which the EAR asserts jurisdiction for foreign-made direct products of US technical data or software. Read the rest of this entry »

BIS Says: “BIS Has No Authority to Determine Whether an Item is on the CCL”

September 7th, 2010 by John Black

As most of you already know, the Commerce Department Bureau of Industry (BIS) does not have the authority to issue an official ruling as to whether an item is on the Commerce Control List or the US Munitions List.  The Directorate of Defense Trade Controls in the State Department is the only government agency that has the authority to determine whether an item is on the CCL or the USML.  DDTC issues Commodity Jurisdiction Determinations (CJ) (or lesser known GJs) to provide an official determination as to whether something is on the USML or the CCL.

In fact, even if the CCL specifically says it controls an item, the CCL actually might not control that item.  For example, ECCN 1A001 paragraph c says it controls parts that are specially designed for missiles.  In fact, you will find that those 1A001 items specially designed for missiles are usually in Category IV(h) of the USML.

In the August 2, 2010, Federal Register BIS published a notice clarifying these facts stating that commodity classifications and advisory opinions that BIS issues may not be relied upon as determinations as to whether an item is subject to the Export Administration Regulations (EAR) or on the CCL. Read the rest of this entry »

DDTC Changes Proviso Reconsideration/Clarification Requirements for Licenses

September 7th, 2010 by John Black

DDTC announced on its website the new procedures you have to follow to request a reconsideration or clarification of the provisos on an approved license.  Under the new procedures, you have a choice: Either submit a General Correspondence (GC) request or submit a Replacement Authorization license application.

Importantly, this new procedure applies only to licenses, not to agreements.  If you want to request proviso reconsideration or clarification for an approved agreement, you have to follow the procedures in the new Electronic Agreements Guidelines.  And, as you will see, if you want proviso reconsideration or clarification for a paper agreement, you have to first re-baseline that agreement as an electronic agreement.

For details on how to request proviso reconsideration or clarification for licenses go to:

http://www.pmddtc.state.gov/licensing/documents/gl_proviso.pdf

Agreements and CJs Have to Be Submitted Electronically from Now On

September 7th, 2010 by John Black

From now on, if you want to submit an application for a Technical Assistance Agreement, Manufacturing License Agreement, Warehouse and Distribution Agreement, or a Commodity Jurisdiction Determination (CJ), you must submit via the electronic D-Trade2.

(OK, technically, you can submit a paper CJ application until September 2, 2010—Maybe you can send yours in for late delivery on the last day and be the last person to submit a paper CJ request.) Read the rest of this entry »

Global Trade Manager/ITAR Postion Available

August 19th, 2010 by Danielle McClellan

Location: Carlsbad, California

Candidate must ensure that the international business activities of all ViaSat operating units are conducted in full compliance with all relevant US Government regulatory requirements.  This must be accomplished concurrent with providing the highest level of customer service to our internal and external customers, and in a manner that ensures program objectives are fulfilled.

We are seeking a dynamic candidate, who can “think outside the box” and can direct an Import/Export program with a real team approach and the ability to deliver timely compliant solutions to import/export issues.

Outstanding communication and issue resolution skills are required.  Must also be proficient in Microsoft Office as well as an excellent working knowledge of the ITAR.

Required.  Extensive knowledge of the ITAR, EAR and OFAC Regulations.  Outstanding communication skills both written and verbal.  Ability to prepare TAA’s, MLA’s, Dept of State export licenses, AES filings, and any other specific required documentation called for in an Import/Export environment

US Citizenship Required

For more information and to apply, go to www.viasat.com/careers and search job requisition number: 4846

Trade and Regulatory Compliance Analyst Opening

August 9th, 2010 by Danielle McClellan
Job ID 2078
Job Location Bay Area CA – San Francisco
Job Category Legal
Date Posted Aug 4, 2010
The world is changing. Join the Riverlution! At Riverbed, we bring the world closer together so every person and every company can find the fastest way to the possible. Imagine if you could run applications up to 100 times faster over your WAN, reduce network traffic by up to 95%, and collaborate anywhere as if you were in the same room- you can!

Riverbed is the IT performance company. WAN optimization solutions from Riverbed liberate businesses from common IT constraints by increasing application performance, enabling consolidation, and providing enterprise-wide network and application visibility – all while eliminating the need to increase bandwidth, storage or servers

Riverbed offers the rewarding experience of working with the best minds in the industry who are changing the world through cutting edge technology and applications. We need cross-functional thinkers with the ability to see and link the pieces of the big picture together across all functions to make our business grow and flourish. Join us on this journey, and help us create the world of the future. We offer competitive salary and an attractive benefits package.

Under the direction of the Associate General Counsel, the Trade and Regulatory Compliance Analyst will support Riverbed’s import/export trade compliance and product regulatory compliance efforts. This includes supporting the development and maintenance of a formal trade compliance program relating to both import and export of products, as well as supporting Riverbed’s product compliance efforts. While the position reports into the legal department, the Trade and Regulatory Compliance Analyst must be able to work across multiple organizations, including operations, sales operations, support, engineering and product management. Additionally, the position must maintain good working relationships and actively cooperate with internal and external customers, business partners, outside consultants and applicable government agencies. The Trade and Regulatory Compliance Analyst will be responsible for documenting processes, training of internal departments, record-keeping, developing documentation for customers and partners, and responding to ad hoc trade compliance issues. This is a generalist position, responsible for supporting a wide range of trade and regulatory issues under the direction of the legal department and with assistance from other Riverbed departments and outside consultants as necessary.

ESSENTIAL FUNCTIONS
•Classify products for import and export using the Harmonized Tariff Schedule, Export Administration Regulations, and other established regulatory information.
•Research, report and implement international trade data in order to ensure global import, export and supply chain compliance.
•Provide training to our internal customers.
•Respond to inquiries from Customs Brokers and Freight Forwarders regarding HTS classification, ECCN classifications, documentation requirements, and other import and export regulations to ensure timely clearance.
•Assist engineering and product management in documenting product regulatory compliance for customers and partners.
•Publish trade and regulatory compliance information to customers and partners to enable easier self-service for trade and regulatory-related questions.
•Correspond with foreign vendors and purchasing to obtain documentation and information necessary for supply chain security and timely customs clearance of import and export transactions.
•Maintain and distribute performance reports to provide awareness and measure effectiveness of import, export and supply chain compliance programs.
•Assist in developing and maintaining policies, procedures and instructions manual to assure compliance with import and export laws, regulations, administrative practices and supply chain security.
•Assist in identifying new procedures and methods to expedite the import and export of shipments and deliveries to customers, and identify cost savings plans for the efficient and compliant operation of global trade.
•Perform other work-related duties as assigned.

EDUCATION, EXPERIENCE AND SKILLS REQUIRED
•Five + years experience in international trade and compliance and/or IT product regulatory/homologation compliance.
•Strong working knowledge and experience with import and export regulations and audit practices.
•Bachelors Degree or higher.
•Excellent communication skills (verbal, written, presentation) with ability to implement and conduct training programs.
•Proficient in Microsoft Office.

DESIRABLE QUALIFICATIONS
•Licensed U.S. Customs Broker.
•Certified U.S. Export Compliance Officer.
•Familiarity with trade issues specific to encryption.
•Global logistics experience.
•Information technology product homologation experience.
•Familiarity with international regulations applicable to IT equipment, such as WEEE, RoHS and REACH.
•Desire to learn.
•Self-starter with the ability to meet or exceed deadlines, prioritize, multi-task, and maintain flexibility in fast-paced, changing environment.

Riverbed Technology, Inc. is a San Francisco company near CalTrain, Muni and BART, with excellent salary, options and benefits. We are proud to be an EEO/AA employer M/F/D/V

www.riverbed.com

Apply Now