Director of Trade Compliance

Winchester Interconnect•Boston, MA

About The Position

The Director of Trade Compliance is responsible for leading the company’s global trade compliance and export control program, ensuring full adherence to U.S. laws and regulations governing defense articles, dual-use items, technology, and services. This role serves as the company’s senior subject matter expert on export controls, sanctions, and jurisdiction/classification determinations, with direct accountability for ensuring the organization operates only with authorized parties, in approved jurisdictions, and in compliance with all applicable regulations. This position is expected to build, lead, and scale a trade compliance function, including establishing team structure, defining roles and responsibilities, and overseeing day-to-day execution of compliance operations. The Director partners closely with Sales, Engineering, Supply Chain, Operations, and Legal to provide authoritative guidance on EAR vs. ITAR jurisdiction determinations, ECCN and USML classification of products, software, and technology, dual-use technology controls and licensing requirements, and end-use / end-user permissibility and country restrictions.

Requirements

10+ years of experience in export controls within aerospace, defense, advanced manufacturing, or similarly regulated industries
Bachelor’s degree required
Proven expertise in EAR, ITAR, and OFAC regulations, with strong working knowledge of FAR/DFARS, U.S. Customs, and global trade compliance requirements across EU, APAC, and EMEA jurisdictions
Demonstrated expertise in jurisdiction and classification analysis, including EAR vs. ITAR determinations, ECCN classification (including complex categories such as 5D002, 9x515, etc.), and USML categorization and CJ strategy
Strong technical fluency to interpret engineering data and map to control regimes
Proven experience with dual-use technologies, software controls, and deemed export requirements
Experience building or scaling a compliance function and managing direct reports
Hands-on experience with licensing (BIS & DDTC), compliance investigations, and regulatory engagement
Recognized authority on defense trade compliance requirements, with decision ownership over restricted party determinations, end-use/end-user approvals, country eligibility, technical data controls, deemed export risk assessments, and military and dual-use classification frameworks
Owns and leads the enterprise export compliance program, including final approval authority for ECCN/USML classifications, export licensing strategy, use of exemptions/exceptions, Technical Assistance Agreements (TAAs), commodity jurisdiction requests, and voluntary disclosures
Leads and directs complex compliance investigations, including those involving unauthorized technology access and deemed exports, with full accountability for risk assessments, root cause analysis, and implementation of corrective and preventive actions (CAPA)
Serves as the senior compliance authority to influence and direct cross-functional stakeholders, providing clear, risk-based guidance and enforcing alignment with regulatory requirements in a fast-paced, engineering and operations environment
Acts as the primary compliance authority supporting U.S. Government subcontracting requirements, including interpretation and enforcement of customer flow-down obligations and contractual compliance commitments (preferred)

Nice To Haves

Juris Doctor (JD) a plus.

Responsibilities

Establish and lead the company’s global trade compliance organization, including hiring, developing, and managing staff
Define governance structure, escalation paths, and compliance ownership across business units
Serve as the primary interface with executive leadership on compliance risk posture
Own and approve EAR/ITAR jurisdiction determinations, including CJ strategy where required
Lead and oversee technical classification of hardware, software, and technology (ECCN/USML)
Ensure robust documentation of classification rationale (engineering basis, control parameters, applicable notes)
Provide expert guidance on dual-use technologies, including encryption (e.g., 5D002), aerospace/space (e.g., 9A515/9E515), and other controlled categories
Validate classification consistency across business units and legacy determinations
Oversee export licensing strategy and execution (BIS, DDTC), including license applications, TAAs / agreements, and license exceptions/exemptions
Ensure compliance with ITAR, EAR, OFAC, DFARS, FAR, Customs, and FTR
Embed export controls into engineering, product lifecycle, and program management processes
Ensure pre-release classification of software and technology prior to external access (critical for deemed export control)
Provide real-time guidance on transactions, technical data sharing, and international collaboration
Lead investigations in concert with Legal and Corporate Trade involving unauthorized access to controlled technology, deemed export violations, and classification errors or gaps
Conduct root cause analysis and implement corrective actions
Oversee voluntary disclosures where required
Establish internal controls and audit-ready documentation standards
Lead internal audits and support external regulatory audits
Develop targeted training on classification methodology, technical data handling, and deemed export requirements
Lead and continuously enhance the company’s global trade compliance and export control program across all business units, with full accountability for program effectiveness and risk posture.
Ensure compliance-wide compliance with all applicable U.S. export/import laws and defense trade regulations, including ITAR, EAR, OFAC, DFARS, FAR, Customs, and Foreign Trade Regulations.
Serve as the company’s primary compliance authority, with decision ownership over customer and partner eligibility, approved countries and restricted jurisdictions, restricted party screening outcomes, end-use and end-user determinations, export licensing requirements, and handling, access, and transfer of controlled technical data.
Develop, implement, and enforce trade compliance policies, procedures, and internal controls to mitigate regulatory and operational risk across the enterprise.
Own and oversee export authorization activities, including final approval authority for export license applications, Technical Assistance Agreements (TAAs) and related authorizations, license exemptions and exceptions, and commodity classifications (ECCN/USML).
Partner with Sales, Business Development, and Program leadership to evaluate new business opportunities and enforce compliance with export control and sanctions regulations prior to engagement.
Direct and approve compliance review of customer, supplier, distributor, and international partner transactions to ensure adherence to U.S. Government restrictions and internal policies.
Establish and lead enterprise-wide restricted party screening and due diligence programs, ensuring consistency, accuracy, and audit readiness.
Own internal compliance audit strategy and execution, ensuring effectiveness of controls and sustained audit readiness across all sites.
Lead and direct investigations involving potential export control violations, including unauthorized technology access and deemed exports, with full accountability for root cause analysis and corrective and preventive actions (CAPA).
Approve and oversee preparation and submission of voluntary disclosures, in concert with legal and corporate trade and in accordance with regulatory requirements.
Establish and drive enterprise training strategy for export controls, including classification, technical data handling, and deemed export compliance.
Collaborate with Engineering, Operations, Supply Chain, Legal, HR, and Commercial Leadership to embed compliance as a required control within business processes and decision-making.
Monitor regulatory developments and emerging risks impacting the aerospace and defense sector and provide proactive, risk-based guidance to executive leadership.
Oversee compliance alignment with cybersecurity, controlled unclassified information (CUI), and customer-specific defense requirements.