The Senior Counsel, Global Trade and Compliance advises Safran USA and affiliates on strategic and daily export and import compliance requirements, anticorruption, and related legal issues. This includes the EAR, ITAR, FTR, OFAC, and CBP regulations. Will advise affiliate companies on managing export transactions and developing duty avoidance strategies. Engages purchasing, finance, human resources, and other functions to strategically integrate export, import, and anticorruption compliance into the achievement of Safran business objectives. Engages US Departments of Commerce, Homeland Security, State and Treasury to address and resolve regulatory issues as necessary. Oversees Safran USA's annual export-import compliance training provided to US affiliates. Has one direct report: Export-Import Compliance Manager.
Duties and Responsibilities:
- Investigate, research, and provide legal guidance on corporate and strategic transactions, including acquisitions, contracts, and other issues and circumstances which may arise in the company's day-to-day business activities.
- Advise on SUSA and affiliate company daily import transactions, engaging personnel in multiple functions to build support for compliance objectives while advancing business processes. This is a hands-on role.
- Maintains expertise in federal regulatory areas including U.S. export controls, U.S., Mexico, Canada and EU customs and administration, trade agreements, and tariffs.
- Designs and administers corporate desk-level procedures and training.
- Working with the Export-Import Compliance Manager, assists companies in identifying regulatory changes, export classification determinations, sanctioned end users, export license determinations, application and administration.
- Assists companies in import classification, valuation, country of origin determinations, anti-dumping, reconciliation, recordkeeping, post-entry audits, and related activities.
- Working with the Export-Import Compliance Manager, designs, conducts, and implements export and import audits to assess compliance.
- As necessary, assists companies in drafting voluntary disclosures and prior disclosures involving US and foreign affiliates
- Ensures charitable operations and donations are managed in accordance with Group procedures
- Demonstrates strong judgment, initiative, discretion, creativity and strategic thinking.
- Recognizes issues and stakeholders impacted by compliance requirements.
- Oversees outside counsel on export and import compliance matters.
- Strong knowledge of the EAR, ITAR, FTR, OFAC and CBP regulations. Knowledge of the FCPA a plus.
- Ability to take the complex and make it simple.
- Prior experience with “hands-on” completion of EAR, ITAR and OFAC export license applications and Technical Assistance Agreements utilizing online agency application systems.
- Experience vetting ownership and bona fides of companies potentially subject to OFAC sanctions (e.g., Russia) and EAR sanctions (MEU Rule).
- Hands-on export classification experience (preferably in the manufacturing environment); ability to administer and review SUSA Export Product Classification Questionnaires.
- Ability to determine EAR and ITAR jurisdiction applying proper legal principles.
- Ability to design 1-4 day annual export – import conferences on current subject matter.
- Effective teaching ability to include audiences at all levels of regulatory expertise.
- Familiarity with and strong interest in US foreign and export control policy, particularly with regard to sanctioned nations.
- Seven or more years of combined US Government, corporate, and law firm experience in the practice of US export controls, import compliance, and sanction laws.
- Law degree from an accredited law school required.
- Legally authorized to work in the US without company sponsorship.
- Ability to speak French a plus.
- Proficient in Microsoft Word, Excel, Outlook, PowerPoint and similar software applications.