Export Compliance Manager

GENERAL PURPOSE AND SCOPE:

The Senior Manager Export Compliance and Empowered Official is the Austal USA designated party responsible for ensuring Austal’s regulatory compliance pertaining to the International Transfer of Arms Regulations (ITAR), Export Administration Regulations (EAR), the Arms Export Control Act (AECA), Office of Foreign Assets Controls (OFAC). This individual is responsible for overseeing the preparation of all export licenses including Technical Assistance Agreements (TAAs), DSP-5s and Manufacturing License Agreements (MLAs) with the Department of State and Department of Commerce. Executes the licenses on behalf of Austal under the written authority of Austal USA’s President.

REPORTS TO:  The Senior Manager Export Compliance and Empowered Official reports to the President on substantive export control matters.  Reports to the Vice President of Legal Affairs & Chief Compliance Officer with regard to routine department duties and responsibilities.

SUPERVISES:  N/A

AUTHORITIES / RESPONSIBILITIES:

• Responsible to develop and maintain  the export compliance program.
• Responsible to develop and maintain Export Compliance Manual.
• Responsible for oversight of export control administrators / specialists.
• Responsible for providing guidance to all company personnel including the senior staff and the Government Security Committee (GSC) members of the Austal USA Board of Managers concerning the requirements and obligations of exporting defense articles, technical data, defense services and dual-use items as defined in the International Traffic in Arms Regulations (ITAR) as well as exports pursuant to the Export Administration Regulations (EAR).
• Acts as primary point of contact for export control matters with the State and Commerce Departments.
• Briefs the Government Security Committee on past quarter activities and current issues at the quarterly GSC meeting.
• Process and execute all End User Certificates, End User Undertaking, End User Declarations, and other forms of end user guarantees for non-U.S. countries.
• Process and execute all International Imports and appropriate documentation.
• Apply and maintain Exemptions under ITAR and Exceptions under EAR when available for all Exports.
• Approve / disapprove all Foreign Visitors Requests.
• Approve / disapprove all International Shipments.
• Provide and administer export compliance training to all new hires for orientation course, advanced export compliance training for all network users, refresher annual course, tailored to specific departments or groups on need basis. Maintain all necessary training and update as needed.  
• Manage the preparation, submission and execution of export license applications, technical assistance agreements, annual registration, Commodify Jurisdiction requests, and necessary correspondence to the Department of State under DDTC DECCS online tool.
• Manage the preparation, submission and execution of export license applications, Classification Requests Applications under CCAT application with the Department of Commerce under SNAP-R module.
• Coordinate with appropriate program personnel to review provisos on licenses and agreements to ensure contract and customer requirements can be met by the license or agreement. Ability to reach back to the appropriate Government personnel to request provisos re-consideration under amendment module.
• Investigate all possible export violations, determine if they have occurred and prepare, submit, and close out voluntary disclosures to the DoS and DoC.
• Ensure the Export Compliance Department maintains export related record keeping functions and files.
• Stay current on applicable export laws and regulations issued by various government agencies and translate them into business practices.
• Advise management on trade compliance initiatives, objectives and associated risks and assists with the development of international business strategies.
• Provide guidance to company employees on export compliance with the International Traffic and Arms Regulations (ITAR), Export Administration Regulations (EAR), Office of Foreign Assets Control (OFAC) and other import/export laws.
• Monitor regulatory changes in conjunction with internal policies and programs.
• Deal with external consultants and export counsel regarding export matters.

QUALIFICATIONS / KNOWLEDGE / EXPERIENCE:

• A minimum of 10  years hands-on experience managing ITAR and EAR compliance in a DoD environment export compliance position with a multinational company.
• Experience as an Empowered Official preferably with a company operating under Special Security Agreement (SSA) with the Defense Counterintelligence and Security Agency (DCSA).
• BS Degree is preferred but substantial highly relevant experience may be substituted.
• Specific experience and expertise with regard to the export of technical data and defense services.
• Excellent analytical skills and a proven ability to interpret and apply export regulations to real world compliance issues.
• Strong communications (both verbal and written) and interpersonal skills.
• Excellent organizational, prioritization and planning skills.
• Ability to independently develop, lead and drive projects and initiatives to closure.
• Proficiency in the following Computer skills: Excel, Word, PowerPoint, PDF.
• Proficiency in DECCS and SNAP-R online  licensing system is required.
• Must be able to obtain and hold a Secret Security Clearance.
• US Citizenship Required

TOOLS:   DECCS

                SNAP-R

                STELLA

                ELISA

International Trade Administration Consolidated Screening List for Unverified, Denied, Military End User List

                Sanctions List Search Tool

                BIS Import Certificate

DIRECTION EXERCISED:

• Exercise direction over export compliance administrators.

DISCRETION EXERCISED:

• The Empowered Official has the independent authority to: (a) enquire into any aspect of a proposed export or temporary import by Austal USA, (b) verify the legality of the transaction and the accuracy of the information to be submitted; and (c) refuse to sign any license application or other request for approval without prejudice or other adverse recourse. They have the authority to independently investigate any suspected violation and address those investigations directly with the President.

LIAISES WITH: 

• External:  U.S. Navy, U.S. Coast Guard, Department of State, Department of Commerce, OFAC, Government Security Committee, U.S. Department of Defense activities, U.S. and Foreign Suppliers,  foreign governments and militaries.
• Internal: All employees and all departments with regard to export and import t compliance matters.

ADDITIONAL GUIDELINES:

Candidates must meet the following employment eligibility guidelines to be considered for employment with Austal USA:

• 18 years of age or older at time of application
• Able to provide proof of U.S. Person Status
• No felony convictions of Theft/Deception or Violent crimes within seven years from disposition date
• No felony convictions of Drug crimes within three years from disposition date
• Willing to submit to a drug screen
• Willing to submit to a background check
• Must be able to obtain and maintain appropriate security clearance.

Equal Employment Commitment

Any qualified individual with a disability who is having difficulty in completing an application because of incompatible technology or other disability-related application issues may contact us at the following phone number for assistance: 251-445-1932.
Austal shall abide by the requirements of 41 CFR §§ 60-1.4(a), 60-300.5(a) and 60-741.5(a). These regulations prohibit discrimination against qualified individuals based on their status as protected veterans or individuals with disabilities and prohibit discrimination against all individuals based on their race, color, religion, sex, sexual orientation, gender identity, or national origin. Moreover, these regulations require that covered prime contractors and subcontractors take affirmative action to employ and advance in employment individuals without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, protected veteran status or disability.  Austal’s commitment to equal employment opportunity applies at all levels of employment, in all job titles, including the executive level, and to all employment actions, including but not limited to decisions concerning recruitment, hiring, training, and promotion.