Reports to Senior Legal Counsel and Global Logistics Manager
General Summary of Job Responsibilities:
Responsible for monitoring import and export transactions and coordinating with logistics firms to ensure compliance with US customs rules and export rules.
Summary of Key Responsibilities, Duties, and Accountabilities:
- Provide leadership for global trade compliance that supports global business objectives and satisfies international legal requirements both imports and exports.
- Serve as the company’s primary liaison with U.S. Customs and Border Protection, Bureau of Industry and Security, and other applicable government agencies relative to import and expo1t control.
- Review and monitor import/export transactions and coordinate same with internal personnel and external logistics firms. Coordinate with business units to ensure compliance with local, regional and global trade compliance requirements.
- Provide advice and guidance to senior management and company personnel on the application of government import and export regulations for the countries in which the company operates e.g. U.S., EU, Brazil, Singapore, Mexico, etc,). Provide guidance with regard to content origin for all preferential treatment, domestic content, and Free Trade Agreement programs and regularly review and validate HTS classifications, duty drawback opportunities, and trade program eligibility.
- Act as the primary internal interface for regulatory changes that affect trade compliance; Set appropriate company import and export policies and disseminate this information to appropriate functions within the organization. Responsible for managing the current trade compliance staff and establishing a compliance structure and network across the regions.
- Work with internal product managers and the company’s import broker to maintain existing and develop new product descriptions needed to determine classification codes of company products (including any new products) under Harmonized Tariff System and maintain a master list of same.
- Partner with corporate functions such as Finance, Tax, Research & Development, Operations and all Company sites to ensure that personnel in all functions understand Import / Export compliance as it relates to their work. Specifically, ensures the integration of necessary GTC work activities into other functions’ work streams to deliver compliance reliability and coordinates supply chain risk assessment and mitigation strategies.
- Support internal and external audit commitments including assessments, requests for information, process enhancements, and corrective actions.
- Responsible for leading the development of and ensuring adequate training is provided to all internal and external stakeholders on relevant international regulations.
- Periodically review and update the company product list to confirm proper classification of company products under US Commerce Control List as controlled or not controlled (EAR99).
- Oversee the tracking of products passing through the company’s Foreign Trade Zone (“FTZ”) that are treated as exempt from duties or on TIB status.
- Attend FTZ audits and coordinate with Port of Houston with respect to the FTZ.
- Manage the identification and collection of information for Conflicts Minerals Matrix for the annual reporting on Form SD to SEC (including identifying products that contain conflicts minerals and suppliers that provide such materials). Maintain records related to global imports for 5 years after the date of entry.
- Knowledge and compliance of US trade sanctions and anti-boycott rules.
- Confirm and periodically review the company’s freight forwarding firms process (including the use of software tools) to screen all parties to whom it will ship products on behalf of the company and to notify the company’s Legal Department immediately if, upon screening a specific entity, it is a “match” with one of the entities on a restricted or denied party list.
- Coordinate with the company’s import broker to ensure that shippers complete an Import Security Filing (ISF) form at least 24 hours before loading at origin a shipment destined for U.S., which is sent to both this position and import broker to ensure that information is correct – country of origin, correct classification code (under Harmonized Tariff System), etc.
- Coordinate information gathering with company personnel and suppliers at all locations to satisfy statutorily required filings/paperwork.
- Assist Senior Legal Counsel in handling matters and special projects with respect to import/export.
Summary of Key Requirements:
- Education: BA/BS Degree.
- Preferred Certifications: Customs License Broker
- Experience: IO+ years of experience working in and establishing import/export compliance systems with international responsibilities
- Must qualify as a “U.S. Person” as defined in the IT AR and EAR. Understanding of U.S. trade regulations (IT AR, EAR, OF AC, etc.), and similar LAT AM, AP AC, and EU regulations.
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