Export Trade Compliance Manager

SUMMARY:

The Export Trade Compliance Manager will direct and manage the company’s export compliance program according to regulations by the U.S. Bureau of Industry and Security (BIS), U.S. Census Bureau, the U.S. Office of Foreign Assets Controls (OFAC), and U.S. Customs and Border Protection (CBP). This role will foster a culture of compliance excellence throughout the organization and minimize the company's exposure to penalties by monitoring regulatory changes, devising and updating policies and procedures to adjust to new regulations, as well as coordinating and disseminating relevant information to stakeholders. Drive trade program efforts that benefit the company and distributors such as Free Trade Agreements (FTAs).

MAJOR RESPONSIBILITIES:

• Lead and manage the organization's export compliance activities by setting, implementing, and overseeing policies and procedures that support the company’s commitment to comply with all U.S. export regulations.
• Seek opportunities and optimize compliance measures as needed to meet business and regulatory demands.
• Conduct internal audits, investigate potential incidences of non-compliance, establish corrective measures, and communicate results to stakeholders.
• Spearhead the company’s compliance activities to meet the requirements of the U.S. Bureau of Industry and Security (BIS) Connected Vehicle Rule.
• Establish an internal task force with Product Management and the NA company to align initiatives in collaboration with the Corporation and internal stakeholders, including the analysis and availability of documentary evidence, due diligence measures, devising project schedules to meet authorization submission requirements, and serving as the point of contact for BIS inquiries.
• Keep current with regulatory changes, share updates with executive management, and adapt company activities as needed.
• Provide guidance and operational and regulatory support to all departments, including off-site locations as well as to the Legal department as a subject matter expert (SME) in aspects of export trade regulations such as contracts, agreements, business arrangements, and special projects.
• Interface with the company to obtain and determine Export Control Classification Numbers (ECCNs) for new technologies in future vehicle models.
• Seek out and handle confidential product information from the company Product Planning to ascertain ECCNs, analyze the information, and assign classifications to all new service parts and accessories.
• Research export license requirements and submit and manage export licenses as needed.
• Collaborate on ECCN determinations for all Alliance vehicles.
• Provide critical support to other departments to determine ECCNs and licensing requirements for all “one-off” export shipments by reviewing the Commerce Control List (CCL), gathering technical specifications, reviewing applicable control categories and classifications, performing independent research, and obtaining information from manufacturers.
• Develop, implement, and maintain company’s online Export Control Awareness Course.
• Determine job functions that require export training and coordinate with Human Resources (HR) to assign courses as needed.
• Provide customized training to internal business units and set business rules with external service providers with respect to export compliance.

• Keep the Export Compliance Manual current with all applicable changes resulting from regulatory updates.
• Lead and manage direct report.
• Provide guidance to a team of export professionals in all aspects of export compliance and related operational matters.
• Oversee the accuracy and timeliness of the Electronic Export Information (EEI) filings in the Automated Commercial Environment (ACE), makes determinations on denied party screening results, and assists in Global Trade Management (GTM) system enhancements from a compliance perspective.
• Serve as a SME and engages in the Uyghur Forced Labor Prevention Act (UFLPA) working group with all companies to drive forward compliance efforts.
• Interface with North American Company Government and Regulatory Affairs in D.C. to collaborate and raise concerns on proposed regulations affecting the company’s activities from an export control perspective and provide feedback on proposed changes affecting the automotive industry.
• Provide support to direct report on Free Trade Agreements (FTAs) and annual solicitation project.

REQUIRED SKILLS & PERSONAL QUALIFICATIONS:

• Up to date with a rapidly changing and increasingly complex regulatory environment requiring a high level of due diligence.
• Expertise to review transactions for “end-use,” “end-user,” and “grey area” restrictions as well as expanded foreign direct product rules, Harmonized Tariff Schedule (HTS) level sanctions, new export control regimes, and trade sanctions.
• Working knowledge and practical application of export regulations such as the Export Administration Regulations (EAR) 15 CFR 300-799, Foreign Trade Regulations (FTR) 15 CFR 30, as well as understanding of trade sanctions per the Office of Foreign Assets Control (OFAC) regulations 31 CFR, and import regulations per Customs Duties 19 CFR.
• Ability to make Export Control Classification Number (ECCN) determinations for one-off items and testing equipment, research a variety of sources, and review technical information from manufacturers to arrive to the appropriate classification.
• Makes licensing determinations based on the ECCN, end-use, and end-user.
• Expertise in Free Trade Agreements (FTAs) such as United States-Mexico-Canada Agreement (USMCA), United States-Chile Free Trade Agreement (UCFTA), United States-Australia Free Trade Agreement (UAFTA), United States-Colombia Trade Promotion Agreement (COTPA), and others as applicable.
• Proficiency in filing the Electronic Export Information (EEI) to oversee forwarders’ submissions and manage potential self-filing functions.
• Ability to lead procedural changes and interface with all levels of employees in departments such as Legal, Logistics, Customs, Accounting, Information Technology (IT), Service, Pricing, Distribution Centers, and external contacts such as U.S. government agencies, all companies, suppliers, distributors, and service providers.
• Strong written and verbal communication skills.
• Drive to maintain expertise and professional certifications.
• Proactive attitude and high level of attention to detail.
• U.S. Customs Broker License, preferred and National Customs Brokers and Forwarders Association (NCBFAA) Certified Export Specialist (CES) certification, required or Export Compliance Training Institute (ECTI) Export Compliance Professional (ECoP) Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR) certifications or other relevant export compliance certification(s), required.

EDUCATION & EXPERIENCE REQUIREMENTS:

• Bachelor's degree required with 8-10 years of work experience.