Smoking Hot: Proposed Changes to USML Categories I, II, and III

2018/05/30

By: Rick Phipp

On top of the background buzz regarding the ZTE zigzag, the latest shoe has dropped in the ongoing export control reforms. Three shoes actually, since we can now read about the proposed move of certain items controlled in Categories I, II, and III on the U.S. Munitions List (USML) over to the Commerce Control List (CCL). Long awaited by U.S. gun and ammunition manufacturers and exporters, these proposed rules describe how articles the President determines no longer warrant control under USML would be controlled on the CCL and by the Export Administration Regulations (EAR) and describe more precisely articles warranting export and temporary import control on the USML.

As part of export control reforms under the Obama administration, the executive branch completed transfers of items in the following categories from the USML to the CCL and created Category XIX (gas turbine engines):

  • Category IV (launch vehicles, guided and ballistic missiles, rockets, torpedoes, bombs, and mines);
  • Category V (explosives and energetic materials, propellants, incendiary agents, and their constituents);
  • Category VI (surface vessels of war and special naval equipment);
  • Category VII (ground vehicles);
  • Category VIII (aircraft and related articles);
  • Category IX (military training equipment and training);
  • Category X (personal protective equipment);
  • Category XI (military electronics);
  • Category XII (fire control, laser, imaging, and guidance equipment);
  • Category XIII (materials and miscellaneous articles);
  • Category XIV (toxicological agents, including chemical agents, biological agents, and associated equipment);
  • Category XV (spacecraft and related articles);
  • Category XVI (nuclear weapons related articles);
  • Category XVIII (directed energy weapons); and
  • Category XX (submersible vessels and related articles).

Left remaining were changes to Categories I-III (firearms, close assault weapons and combat shotguns, guns and armament, and ammunition/ordnance).

Under the proposed rules published by BIS and the State Department, a number of new ECCNs are created to address transferred items and the relevant USML categories are revised to describe more precisely the articles warranting continued control on the USML. The interagency review process focused on identifying items that were either (i) inherently military and otherwise warranted control on the USML, or (ii) if of a type common to non-military firearms applications, possessed parameters or characteristics that provide a critical military or intelligence advantage to the U.S., and are almost exclusively available from the U.S. If one or both points were met, the article remained on the USML.  Essentially, commercial items widely available for purchase and less sensitive military items were transferred in the proposed rules. Links to the proposed rules are as follows: State Department and Commerce Department.

There will be a 45-day period following publication in the Federal Register in which the agencies will accept comments regarding the proposed rules. Exporters and manufacturers of articles currently controlled under USML Categories I-III should review the proposed rules to consider how they may be impacted. Comments may be submitted via the Federal eRulemaking Portal: http://www.regulations.gov or via email to DDTCPublicComments@state.gov with the subject line, “ITAR Amendment – Categories I, II, and III.”

Source


Tips on How to Resolve AES Fatal Errors

2018/05/30

(Source: census@subscriptions.census.gov)

When a shipment is filed to the AES, a system response message is generated and indicates whether the shipment has been accepted or rejected.  If the shipment is accepted, the AES filer receives an Internal Transaction Number (ITN) as confirmation.  However, if the shipment is rejected, a Fatal Error notification is received.

To help you resolve AES Fatal Errors, here are some tips on how to correct the most frequent errors that were generated in AES for this month.

 

Fatal Error Response Code:  643

  • Narrative: Quantity 2 Must Be Greater Than Zero
  • Reason: The Schedule B/HTS number reported requires a second Quantity to be reported and the Quantity 2 is missing or reported as zero.
  • Resolution: Quantity 2 must be greater than zero.

Verify the Quantity 2, correct the shipment and resubmit.

 

Fatal Error Response Code:  649

  • Narrative: Quantity 1 Cannot Exceed Shipping Weight
  • Reason:  Shipping Weight is reported in kilograms.  When the Unit of Measure 1 requires kilograms, the first net quantity (Quantity 1) cannot exceed the Shipping Weight.  Ensure the Shipping Weight includes the weight of the packaging materials.
  • Resolution: The first net quantity (Quantity 1) in kilograms cannot exceed the Shipping Weight in kilograms. Verify the Quantity 1 and Shipping Weight, correct the shipment and resubmit.

For a complete list of Fatal Error Response Codes, their reasons, and resolutions, see Appendix A – Commodity Filing Response Messages.

It is important that AES filers correct Fatal Errors as soon as they are received in order to comply with the Foreign Trade Regulations.  These errors must be corrected prior to export for shipments filed predeparture and as soon as possible for shipments filed post departure but not later than five calendar days after departure.

For further information or questions, contact the U.S. Census Bureau’s Data Collection Branch.


DDTC Posts Name Change for Oculus Info Inc.

2018/05/30

(Source: State/DDTC)

Oculus Info Inc. Changes Name to Uncharted Software Inc.

Effective immediately, Oculus Info Inc. has changed as follows: Uncharted Software Inc. Due to the volume of authorizations requiring amendments to reflect this change, the Deputy Assistant Secretary for Defense Trade Controls is exercising the authority under 22 CFR 126.3 to waive the requirement for amendments to change currently approved license authorizations.

The amendment waiver does not apply to approved or pending agreements. All currently approved DSP authorizations identifying Oculus Info Inc. will not require an amendment to reflect the change to Uncharted Software Inc. A copy of this website notice must be attached to the currently approved license by the license holder.

Pending authorizations received by DDTC identifying the old name on the license will be adjudicated without prejudice. A copy of this website notice must be attached to the approved license by the license holder.

New license applications received after June 18, 2018 identifying the old names on the license will be considered for return without action for correction.

All currently approved agreements will not require an amendment to be executed to reflect the name change. Change of name may be made as part of the next major amendment. The agreement holder is responsible for amending their agreement. No new DSP-83s need to be executed.

Pending agreement applications that require amending must be brought to the attention of the assigned Agreements Officer by the agreement holder. The necessary changes will be made prior to issuance when the Agreements Officer has been notified.

Notice: https://www.pmddtc.state.gov/sys_attachment.do?sysparm_referring_url=tear_off&view=true&sys_id=5c019058db1253403b1272131f9619b5


DDTC Posts Address Change for Quyntess BV

2018/05/30

(Source: State/DDTC)

Effective immediately, Quyntess BV, Stephensonweg 11, NL-4207HA Gorinchem, The Netherlands has changed as follows: Quyntess BV, Wijnhaven 15, NL-3011WH Rotterdam, The Netherlands. Due to the volume of authorizations requiring amendments to reflect this change, the Deputy Assistant Secretary for Defense Trade Controls is exercising the authority under 22 CFR 126.3 to waive the requirement for amendments to change currently approved license authorizations.

The amendment waiver does not apply to approved or pending agreements. All currently approved DSP authorizations identifying Quyntess BV, Stephensonweg 11, NL-4207HA Gorinchem, The Netherlands will not require an amendment to reflect the change to Quyntess BV, Wijnhaven 15, NL-3011WH Rotterdam, The Netherlands. A copy of this website notice must be attached to the currently approved license by the license holder.

Pending authorizations received by DDTC identifying the old address on the license will be adjudicated without prejudice. A copy of this website notice must be attached to the approved license by the license holder.

New license applications received after June 14, 2018 identifying the old address on the license will be considered for return without action for correction.

Pending agreement applications that require amending must be brought to the attention of the assigned Agreements Officer by the agreement holder. The necessary changes will be made prior to issuance when the Agreements Officer has been notified.

Notice: https://www.pmddtc.state.gov/sys_attachment.do?sysparm_referring_url=tear_off&view=true&sys_id=7af09058db1253403b1272131f961936


White House Releases Frequently Asked Questions Regarding the Re-Imposition of Sanctions Relating to the Joint Comprehensive Plan of Action (JCPOA)

2018/05/30

The White House released this document to help companies understand how pulling out of the Iran nuclear deal will affect them. Some questions answer in the document are:

  • Effective May 8, 2018, what sanctions snap back into place?
  • Which sanctions will be re-imposed after the 90-day wind-down period ending on August 6, 2018?
  • Which sanctions will be re-imposed after the 180-day wind-down period ending on November 4, 2018?

Full Document: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/jcpoa_winddown_faqs.pdf


The Fall and Rise of ZTE

2018/05/30

By: Danielle Hatch

In early 2017 China’s largest telecommunications company agreed to pay a nearly $900 million penalty to the US after entering a guilty plea for illegally shipping goods to Iran and North Korea. ZTE was charged with 380 violations of the EAR, including (1) Conspiracy (2) Acting with Knowledge of a violation in Connection with Unlicensed Shipments of Telecommunications Items to North Korea via China and (3) Evasion. The company also entered into a settlement with OFAC for violating the Iranian Transactions and Sanctions Regulations (“ITSR”; 31 CFR Part 560). More Information on these charges can be found here.

A March 2017 Order suspended the 7-year denial of ZTE’s export privileges as well as $300 million of the nearly $900 million penalty if ZTE complied with several probationary conditions. The conditions required ZTE, among other things, to submit six audit reports related to their compliance with US export regulations as well as truthful disclosures of any requested information (Section 764.2(g) of the EAR).

One of the many requirements of The Settlement Agreement and March 2017 Order was that ZTE provide BIS with a status report on specific employees related to the violations found during the investigation or identified in two letters (sent November 30, 2016 and July 20, 2017) that ZTE sent to employees regarding the violations. During BIS’s investigation there were 9 specific employees named related to violations, later, ZTE would identify a total of 39 employees who would have action taken against them related to the violations.

ZTE’s November letter to employees was sent while BIS was investigating the company’s violations and ZTE explained that they had self-initiated employee disciplinary actions that it had begun to take as well as additional actions that they would take in the future that would, be “necessary to achieve the Company’s goals of disciplining those involved and sending a strong message to ZTE employees about the Company’s commitment to compliance.”

ZTE’s July letter was similar to the November letter and once again asserted the company’s commitment to compliance and claimed that the disciplinary actions had sent a strong message to ZTE employees. The letter “confirmed that the measures detailed by ZTE with respect to discipline have been implemented” specifically to the nine named employees identified during the investigation. It should be noted that the individuals that were identified by enforcement agents were those that were signatories on an internal ZTE memorandum on how to evade US export controls or were identified on that memorandum as a “project core member” and/or had met with ZTE’s then CEO to discuss means to continue to evade US laws. In a nutshell, BIS wanted to see that ZTE had reprimanded the 39 employees and officials that were related to the violations through the two letters that they sent.

Cue the problem, which ultimately caused BIS to propose activation of suspended sanctions. ZTE didn’t really send those letters of reprimand as timely as they had led BIS to believe. Come to find out, the November 30, 2016 letter wasn’t sent to employees until February 2, 2018. Not to mention, all but one of the identified individuals received their full 2016 bonus, ZTE originally said this compensation would either be cancelled or decreased.

On March 6, 2018, ZTE indicated, via outside counsel that it had made false statements in the November and July letters. On March 13, 2018 BIS notified ZTE of a proposed activation of the sanctions conditionally-suspended under the Settlement Agreement and the March 2017 Order based on the company breaking the cooperation provision related to providing the US government with false statements. The notice letter to ZTE gave the company an opportunity to respond, of which they provided the following (found in FR 17646):

“In its letter, ZTE confirmed the false statements and, as discussed further infra, posed certain questions in rhetorical fashion. ZTE then proceeded to summarize its response upon ‘‘discovering’’ the failure to implement the stated employee disciplinary actions prior to March 2018, including its decision to notify BIS of the failures. The company also described the asserted remedial steps it had taken to date, including the issuance in March 2018, of the letters of reprimand that were to have been sent in 2016–2017. ZTE additionally asserted that, for current employees whose 2016 bonus should have been reduced (by 30% to 50%), it would deduct the corresponding amount from their 2017 annual bonuses ‘‘to the extent permitted under Chinese law.’’ ZTE also said it will pursue recovery from (certain) former employees of bonus payments for 2016 that the company had informed the U.S. Government would be reduced, but, contrary to those statements, were paid in full. Finally, ZTE reiterated what it described as the company’s serious commitment to export control compliance and summarized its plan to continue its internal investigation of the matter.”

Ultimately, the US Government found that this was the last straw for ZTE. They released the following statement and activated the suspended denial order in full and to suspend the export privileges for ZTE for a period of seven years (until March 13, 2025).

“In issuing the March 13, 2018 notice letter to ZTE, and in considering ZTE’s response, I have taken into account the course of ZTE’s dealings with the U.S. Government during BIS’s multi-year investigation, which demonstrate a pattern of deception, false statements, and repeated violations. I note the multiple false and misleading statements made to the U.S. Government during its investigation of ZTE’s violations of the Regulations, and the behavior and actions of ZTE since then. ZTE’s July 20, 2017 letter is brimming with false statements in violation of § 764.2(g) of the Regulations and is the latest in a pattern of the company making untruthful statements to the U.S. Government and only admitting to its culpability when compelled by circumstances to do so. That pattern can be seen in the November 30, 2016 letter, which falsely documented steps the company said it was taking and had taken, as well as in the 96 admitted evasion violations described in the PCL, which detailed the company’s efforts to destroy evidence of its continued export control violations.”

Here’s where the story gets interesting…

On May 13, 2018 President Donald Trump pledged in a tweet to help give ZTE “a way back into business, fast,” “Too many jobs in China lost. Commerce Department has been instructed to get it done!” Trump tweeted, adding that he was working with Chinese President Xi Jinping to help the company resume operations.

A day later, amid criticism over why Chinese jobs were a priority during trade and investment negotiations with China, Trump tweeted: “ZTE, the large Chinese phone company, buys a big percentage of individual parts from U.S. companies. This is also reflective of the larger trade deal we are negotiating with China and my personal relationship with President Xi.”

Just last week it was released that a deal was in the works between Commerce and China that would involve China buying more US farm goods and removing tariffs on imported US agricultural products in exchange for the denial order against ZTE to be reconsidered. ZTE would still face “harsh” punishment, including enforced changes of management and changes at the board level.

Rumors are swirling that there was a “handshake deal” on ZTE between U.S. Treasury Secretary Steven Mnuchin and Chinese Vice Premier Liu He during talks in Washington last week that would remove the ban in exchange for the purchase of more US agricultural products. Another person said China may eliminate tariffs on US agriculture products it assessed in response to US steel duties, and that ZTE could still be forced to replace its leadership, among other penalties. Both sources said the deal, which has not been confirmed, will likely be finalized before or during a planned trip by US Commerce Secretary Wilbur Ross to Beijing next week to help reach a broader trade pact to avert a trade war.

Additional Details:

Federal Register: https://www.gpo.gov/fdsys/pkg/FR-2018-04-23/pdf/2018-08354.pdf

Article: https://www.reuters.com/article/usa-china-zte-talks/update-1-u-s-china-nearing-deal-to-remove-u-s-sales-ban-against-zte-sources-idUSL3N1ST1WX

Article: https://www.reuters.com/article/us-zte-ban/chinas-zte-says-main-business-operations-cease-due-to-u-s-ban-idUSKBN1IA1XF


Turkish Banker Receives 32 Months for Violating U.S. Sanctions Against Iran Involving Billions of Dollars

2018/05/30

By: Ashleigh Foor

On January 3, 2018, a five-week jury trial wrapped up and convicted Mehmet Hakan Atilla, 47, a resident and citizen of Turkey, to 32 months for conspiring with others in a scheme to violate U.S. economic sanctions imposed on the Islamic Republic of Iran. The violation involved billions of dollars’ worth of Iranian oil proceeds held at Atilla’s employer (Turkish Bank-1).

Atilla, a Turkish banker, Reza Zarrab, an international gold trader, and others defrauded U.S. financial institutions by using them to conduct transactions on behalf of the government of Iran and other Iranian entities which were barred by U.S. sanction. They did so by making these transactions falsely appear as if they involved food, therefore falling within humanitarian exceptions to the sanctions regime.

Atilla lied to U.S. Treasury officials about Turkish Bank-1’s activities and its supposed compliance efforts to avoid subjecting the bank to U.S. sanctions. Atilla and his co-conspirators’ deceptions led U.S. banks to unknowingly process international financial transactions in violation of the IEEPA, and to launder through the U.S. financial system funds promoting the scheme.


Summary of the Presidential Memorandum: “Ceasing U.S. Participation in the JCPOA and Taking Additional Action to Counter Iran’s Malign Influence and Deny Iran All Paths to a Nuclear Weapon”

2018/05/30

By: Ashleigh Foor

(Source: The White House)

On May 8, 2018, President Trump addressed the United States in a Presidential Memorandum, “Ceasing U.S. Participation in the JCPOA and Taking Additional Action to Counter Iran’s Malign Influence and Deny Iran All Paths to a Nuclear Weapon”. He started by stating that the safety and security of the United States and the American people is his highest priority. He then stated that since the inception of the Islamic Republic of Iran in 1979, the revolutionary theocracy has declared its hostility toward the United States and remains the world’s leading state sponsor of terrorism, listing other offenses such as human rights abuses and proving assistance to Hezbollah, Hamas, the Taliban, al-Qa’ida, and other terrorist networks.

“There is no doubt that Iran previously attempted to bolster its revolutionary aims through the pursuit of nuclear weapons and that Iran’s uranium enrichment program continues to give it the capability to reconstitute its weapons-grade uranium program if it so chooses,” stated the President. Therefore, as President, he has approved an “integrated strategy for Iran that includes the strategic objective of denying Iran all paths to a nuclear weapon.”

Trump then goes on to explain the preceding administration’s participation in the Joint Comprehensive Plan of Action (JCPOA) as an attempt to meet the threat of Iran’s pursuit of nuclear capabilities. Although some believed the JCPOA would moderate Iran’s behavior, he said, Iran has only escalated its destabilizing activities. “Iran’s behavior threatens the national interest of the United States,” said the President. On January 12, 2018, Trump outlined two paths moving forward – that the JCPOA’s “disastrous flaws would be fixed by May 12, 2018, or, failing that, the United States would cease participation in the agreement.” He states that these issues were not fixed and that he is making good on his pledge to end the United States’ participation in the JCPOA. “Further, I have determined that it is in the national interest of the United States to re-impose sanctions lifted or waived in connection with the JCPOA as expeditiously as possible,” Trump stated.

The changes are outlined below:

Section 1.  Policy.  It is the policy of the United States that Iran be denied a nuclear weapon and intercontinental ballistic missiles; that Iran’s network and campaign of regional aggression be neutralized; to disrupt, degrade, or deny the Islamic Revolutionary Guards Corps and its surrogates access to the resources that sustain their destabilizing activities; and to counter Iran’s aggressive development of missiles and other asymmetric and conventional weapons capabilities.  The United States will continue to pursue these aims and the objectives contained in the Iran strategy that I announced on October 13, 2017, adjusting the ways and means to achieve them as required.

Sec. 2.  Ending United States Participation in the JCPOA.  The Secretary of State shall, in consultation with the Secretary of the Treasury and the Secretary of Energy, take all appropriate steps to cease the participation of the United States in the JCPOA.

Sec. 3.  Restoring United States Sanctions.  The Secretary of State and the Secretary of the Treasury shall immediately begin taking steps to re-impose all United States sanctions lifted or waived in connection with the JCPOA, including those under the National Defense Authorization Act for Fiscal Year 2012, the Iran Sanctions Act of 1996, the Iran Threat Reduction and Syria Human Rights Act of 2012, and the Iran Freedom and Counter-proliferation Act of 2012.  These steps shall be accomplished as expeditiously as possible, and in no case later than 180 days from the date of this memorandum.  The Secretary of State and the Secretary of the Treasury shall coordinate, as appropriate, on steps needed to achieve this aim.  They shall, for example, coordinate with respect to preparing any recommended executive actions, including appropriate documents to re-impose sanctions lifted by Executive Order 13716 of January 16, 2016; preparing to re-list persons removed, in connection with the JCPOA, from any relevant sanctions lists, as appropriate; revising relevant sanctions regulations; issuing limited waivers during the wind-down period, as appropriate; and preparing guidance necessary to educate United States and non-United States business communities on the scope of prohibited and sanctionable activity and the need to unwind any such dealings with Iranian persons.  Those steps should be accomplished in a manner that, to the extent reasonably practicable, shifts the financial burden of unwinding any transaction or course of dealing primarily onto Iran or the Iranian counterparty.

Sec. 4.  Preparing for Regional Contingencies.  The Secretary of Defense and heads of any other relevant agencies shall prepare to meet, swiftly and decisively, all possible modes of Iranian aggression against the United States, our allies, and our partners.  The Department of Defense shall ensure that the United States develops and retains the means to stop Iran from developing or acquiring a nuclear weapon and related delivery systems.

Sec. 5.  Monitoring Iran’s Nuclear Conduct and Consultation with Allies and Partners.  Agencies shall take appropriate steps to enable the United States to continue to monitor Iran’s nuclear conduct.  I am open to consultations with allies and partners on future international agreements to counter the full range of Iran’s threats, including the nuclear weapon and intercontinental ballistic missile threats, and the heads of agencies shall advise me, as appropriate, regarding opportunities for such consultations.

Sec. 6.  General Provisions.

(a)  Nothing in this memorandum shall be construed to impair or otherwise affect:

(i)   the authority granted by law to an executive department or agency, or the head thereof; or

(ii)  the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals.

(b)  This memorandum shall be implemented consistent with applicable law and subject to the availability of appropriations.

(c)  This memorandum is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.


President Posts Executive Order Prohibiting Certain Additional Transactions with Respect to Venezuela

2018/05/30

(Source: The White House)

President Trump posted an executive order on May 21, 2018 with the purpose of taking further steps in regard to the national emergency declared in Executive Order 13692 of March 8, 2015 and relied upon for additional steps taken in Executive Order 13808 of August 24, 2017 and Executive Order 13827 of March 19, 2018. This order is, Trump said, “particularly in light of the recent activities of the Maduro regime, including endemic economic mismanagement and public corruption at the expense of the Venezuelan people and their prosperity, and ongoing repression of the political opposition; attempts to undermine democratic order by holding snap elections that are neither free nor fair; and the regime’s responsibility for the deepening humanitarian and public health crisis in Venezuela…” The order is as follows:

Section 1.

(a) All transactions related to, provision of financing for, and other dealings in the following by a United States person or within the United States are prohibited:

(i) the purchase of any debt owed to the Government of Venezuela, including accounts receivable;

(ii) any debt owed to the Government of Venezuela that is pledged as collateral after the effective date of this order, including accounts receivable; and

(iii) the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela of any equity interest in any entity in which the Government of Venezuela has a 50 percent or greater ownership interest.

(b) The prohibitions in subsection (a) of this section apply except to the extent provided by statutes, or in regulations, orders, directives, or licenses that may be issued pursuant to this order, and notwithstanding any contract entered into or any license or permit granted before the effective date of this order.

Sec. 2.

(a) Any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions set forth in this order is prohibited.

(b) Any conspiracy formed to violate any of the prohibitions set forth in this order is prohibited

Sec. 3. For the purposes of this order:

(a) The term “person” means an individual or entity;

(b) The term “entity” means a partnership, association, trust, joint venture, corporation, group, subgroup, or other organization;

(c) the term “United States person” means any United States citizen, permanent resident alien, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches of such entities), or any person within the United States; and

(d) the term “Government of Venezuela” means the Government of Venezuela, any political subdivision, agency, or instrumentality thereof, including the Central Bank of Venezuela and Petroleos de Venezuela, S.A. (PdVSA), and any person owned or controlled by, or acting for or on behalf of, the Government of Venezuela.

Sec. 4. The Secretary of the Treasury, in consultation with the Secretary of State, is hereby authorized to take such actions, including promulgating rules and regulations, and to employ all powers granted to the President by IEEPA as may be necessary to implement this order. The Secretary of the Treasury may, consistent with applicable law, re-delegate any of these functions to other officers and executive departments and agencies of the United States Government. All agencies of the United States Government shall take all appropriate measures within their authority to carry out the provisions of this order.

Sec. 5. This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.

Sec. 6. This order is effective at 12:30 p.m. eastern daylight time on May 21, 2018.


Job Posting: Export Control Director

2018/05/30

The University of Nebraska has integrated the four export control programs into one with staff distributed across the four campuses, and an overall director. This model allows each campus to access special expertise available only on one campus, share and solve complex problems together, and reduce redundancy for evaluation of collaborative research projects.

This export control director will continue the work that a team or research leaders from each campus has conducted over the last year to integrate into one University of Nebraska Export Control Program with common policies, job descriptions, education programs, and standard operating procedures. This Director will oversee the director of each campus Export Control program, and will also serve as the director of the Export control program for the University of Nebraska Medical Center’s Export Control program and personnel.

The University of Nebraska is composed of four universities under one President and Board of Regents with primary campuses and ancillary campuses and facilities across the state and programs around the world. These universities, the University of Nebraska–Lincoln, University of Nebraska Medical Center, University of Nebraska at Omaha, and University of Nebraska at Kearney, along with its Department of Defense designated University Affiliated Research Center, the National Strategic Research Institute, and the Global Center for Health Security, oversee a diverse research and education portfolio that stretches around the world.

We are looking for someone with an advanced degree (MS, PhD, JD, MD, MBA, MPA), five years of project-level quality control, risk assessment administrative experience required OR five years of administrative experience with an emphasis on project level quality control and risk assessment is required. Experience reading, drafting and/or negotiating contracts or other formal documents and experience performing assessment and inspections in highly technical environment is preferred. Knowledge of export control compliance systems (i.e. Visual Compliance, SNAP-R, AES Direct) is beneficial and experience working in an academic research university is desired. Excellent project management skills desired. Salary will be commensurate with past experience but expected in the $90-120,000 annually. Due to U.S. Export Control Restrictions, only U.S. Citizens may apply.

Inquiries about the position should be directed to: Marsha Morien, MSBA, UNMC Export control officer: mmorien@unmc.edu. Review of applications begins on June 15th and will continue until the position is filled. If you need assistance with your application, please call (402) 472-3701.

To apply and review a full position description: http://careers.nebraska.edu/postings/583

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

The University of Nebraska does not discriminate based on race, color, ethnicity, national origin, sex, pregnancy, sexual orientation, gender identity, religion, disability, age, genetic information, veteran status, marital status, and/or political affiliation in its programs, activities, or employment.

The University of Nebraska is an Equal Opportunity/Affirmative Action employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, age, national origin, disability, gender identity, sexual orientation, or protected veteran status.

The University of Nebraska strives to fully employ measures to achieve broad diversity in the University’s student body and workforce as permitted by state and federal law. Board of Regents policy resolution: https://www.nebraska.edu/administration/university-ofnebraska-online-worldwide/44-board-of-regents/policy-resolutions/237-diversity.html