Export Control and Contract Compliance Manager

This position will require access to ITAR and/or EAR controlled technical data, technology or source code, and requires that all individuals in this role be authorized to access such information

General Description:

The Export Control and Contract Compliance Manager is in charge of coordinating the daily aspects of export compliance surrounding the Company’s products, including compliance with Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR) and managing internal compliance to those regulations and to Government and customer contract clauses. This position reports to the Chief Financial Officer of the Company. The position requires a strong technical background and specialized knowledge of various disciplines as they relate to export control regulations and internal compliance management.  The Export Control and Contract Compliance Manager interacts with a variety of professionals outside of the Company including, export compliance consultants, attorneys, governmental representatives, and customers; therefore strong verbal and written communication skills are also required. This role also requires strong inter-personal attributes including high ethical standards as well as an understanding of the business implications of decisions. 

 Primary Responsibilities:

• Implement the Company’s Export Compliance Manual and Technology Control Plan
• Manage the export compliance program in accordance with the Company’s Export Compliance Manual, the Technology Control Plan, and with applicable laws and regulations
• Oversee and ensure internal compliance of all protocols and procedures related to the export compliance program
• Oversee and administer the export licensing process to ensure authorizations are obtained from the U.S. government in a fully compliant manner
• Oversee denied party and visitor vetting
• Oversee and ensure contract compliance concerning all non-technical terms and conditions
• Oversee and ensure internal compliance of all protocols and procedures related to non-technical contract compliance

Education and Experience Requirements:

• Bachelor’s degree in a related field
• Minimum ten years’ experience in the following areas:

o   Exporting within a defense environment o   Government Contracting (FAR, DFAR)

o   Non-Governmental Contracting o   Compliance management

 

Specific Tasks and Focus Areas:

 

• Implement the Company’s Export Compliance Manual and Technology Control Plan
  • Develop export policies and procedures as required
• Manage the export compliance program in accordance with the Company’s Export Compliance Manual, the Technology Control Plan, and with applicable laws and regulations
  • Serve as the Company empowered official and primary point of contact with government agencies on export compliance matters.
    • Determine requirements of exporting goods and services under International
      Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), Office of Foreign Assets Control (OFAC), U.S. Customs regulation, and other trade regulations.
    • Determine appropriate export classifications for all Company products, services, and technologies.
      • Perform export jurisdiction and classification analysis for all new commodities.
        • Manage the collection of export classification information from suppliers
        • Maintain the classification database of goods recording the U.S. Munitions Category, Commerce Control Category, and Harmonized Tariff Schedule codes of the United States for technical data and products containing both hardware and software.
      • Coordinate the company’s trade compliance requirements pertaining to the company’s ITAR and EAR export licensing and compliance requirements.
      • Assist with the collection and organization of documentation required to obtain Technical Assistance Agreements, Commodity Jurisdictions, Classification Requests, and other requests for approval to the Office of Defense Trade Controls, U.S. Department of State, the Bureau of Industry and Security, U.S. Department of Commerce, and the Office of Foreign Assets Control.
      • Manage annual renewal and ongoing updates pertaining to ITAR registration.
    • Oversee and ensure internal compliance of all protocols and procedures related to the export compliance program.
      • Directly responsible for conducting training for Company employees on export policies and procedures as required.
      • Ensure that policies and procedures are incorporated into quality program, as appropriate.
      • Conduct periodic assessments of company and broker performance and export activities and direct other business and program activities that impact export compliance.
        • Conduct and participate in internal export compliance audits on a periodic basis.
      • Investigate all matters of potential non-compliance.
        • Coordinate a report of findings with senior management
        • Coordinate preparation of voluntary disclosures with outside advisors/counsel.
        • Manage implementation of corrective actions, as necessary.
      • Ensure maintenance of DTRADE certificates.
    • Oversee and administer the export licensing process to ensure authorizations are obtained from the U.S. government in a fully compliant manner.
      • Investigate any aspect of a proposed export or temporary export to verify the legality of any transaction and the accuracy of the information to be submitted/
      • Prepare and administer any necessary license applications and agreements requiring U.S. government approval for the export or ITAR or EAR regulated Company products, services, and technologies.

Specific Tasks and Focus Areas:

• Liaison with government officials as necessary.
• Review and approve all exports of controlled technical information.

• Review and approve all shipping documentation for all international shipments of hardware.
• Work with shipping to maintain procedures to monitor shipments against export licenses.
• Provide procedural guidance and assist personnel in resolving complex export related issues.
  • Identify EAR License Exceptions.
• Coordinate with foreign customers.
• Implement company procedure for export, if applicable.
• Oversee denied party and visitor vetting
  • Create visitor vetting protocol and update as necessary
  • Provide training as necessary
  • Ensure company compliance
• Oversee and ensure contract compliance concerning all non-technical terms and conditions
  • Review work of Contract Specialist regarding non-technical contract terms and conditions on all incoming contract and contract changes for both Purchasing and Sales.
  • Review work of Contract Specialist regarding financial, governmental Federal Acquisition Regulation (FAR) and Defense Federal Acquisition Regulation Supplement (DFARS), and industry terms and conditions for applicability.
  • Review annual review of the Standard Set of Terms and Conditions.
  • Review annual review of Negotiated Set of Terms and Conditions.
• Oversee and ensure internal compliance of all protocols and procedures related to non-technical contract compliance
  • Develop policies and procedures related to non-technical contracts as needed to support compliance of government contract regulations.
  • Develop IBM BlueWorks Live process models, as required, to document Export Compliance
  • Provide Cross-training for REDAR employees for specific Export Compliance topics

 

“AA/EOE/W/M/Vet/Disable”

R.E. Darling Co., Inc. is an equal opportunity employer. All qualified applicants will receive consideration of employment without regard to race, religion, color, national origin, gender, gender identity, sexual orientation, age, status as protected veteran, among other things, or status as qualified individual with disability.