Export Trade Compliance Manager

Subaru•Camden, NJ

1d•Hybrid

About The Position

Directs and manages Subaru of America's (SOA's) export compliance program according to regulations by the U.S. Bureau of Industry and Security (BIS), U.S. Census Bureau, the U.S. Office of Foreign Assets Controls (OFAC), and U.S. Customs and Border Protection (CBP). Fosters a culture of compliance excellence throughout the organization and minimizes SOA's exposure to penalties by monitoring regulatory changes, devising and updating policies and procedures to adjust to new regulations, as well as coordinating and disseminating relevant information to stakeholders. Drives trade program efforts that benefit SOA and distributors such as Free Trade Agreements (FTAs).

Requirements

Up to date with a rapidly changing and increasingly complex regulatory environment requiring a high level of due diligence.
Expertise to review transactions for “end-use,” “end-user,” and “grey area” restrictions as well as expanded foreign direct product rules, Harmonized Tariff Schedule (HTS) level sanctions, new export control regimes, and trade sanctions.
Working knowledge and practical application of export regulations such as the Export Administration Regulations (EAR) 15 CFR 300-799, Foreign Trade Regulations (FTR) 15 CFR 30, as well as understanding of trade sanctions per the Office of Foreign Assets Control (OFAC) regulations 31 CFR, and import regulations per Customs Duties 19 CFR.
Ability to make Export Control Classification Number (ECCN) determinations for one-off items and testing equipment, research a variety of sources, and review technical information from manufacturers to arrive to the appropriate classification.
Makes licensing determinations based on the ECCN, end-use, and end-user.
Expertise in Free Trade Agreements (FTAs) such as United States-Mexico-Canada Agreement (USMCA), United States-Chile Free Trade Agreement (UCFTA), United States-Australia Free Trade Agreement (UAFTA), United States-Colombia Trade Promotion Agreement (COTPA), and others as applicable.
Proficiency in filing the Electronic Export Information (EEI) to oversee forwarders’ submissions and manage potential self-filing function.
Ability to lead procedural changes and interface with all levels of employees in departments such as Legal, Logistics, Customs, Accounting, Information Technology (IT), Service, Pricing, Distribution Centers, and external contacts such as U.S. government agencies, Subaru of Indiana Automotive (SIA), Subaru Corporation (SBR), North American Subaru Inc. (NASI), suppliers, distributors, and service providers.
Strong written and verbal communication skills.
Drive to maintain expertise and professional certifications.
Proactive attitude and high level of attention to detail.
Bachelor's degree required with 8-10 years of work experience.

Nice To Haves

U.S. Customs Broker License, preferred
National Customs Brokers and Forwarders Association (NCBFAA) Certified Export Specialist (CES) certification, required or Export Compliance Training Institute (ECTI) Export Compliance Professional (ECoP) Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR) certifications or other relevant export compliance certification(s), required.

Responsibilities

Leads and manages the organization's export compliance activities by setting, implementing, and overseeing policies and procedures that support Subaru of America's (SOA's) commitment to comply with all U.S. export regulations.
Seeks opportunities and optimizes compliance measures as needed to meet business and regulatory demands.
Conducts internal audits, investigates potential incidences of non-compliance, establishes corrective measures, and communicates results to stakeholders.
Spearheads SOA’s compliance activities to meet the requirements of the U.S. Bureau of Industry and Security (BIS) Connected Vehicle Rule.
Establishes an internal task force with Product Management and North American Subaru, Inc. (NASI) to align initiatives in collaboration with Subaru Corporation (SBR) and internal stakeholders, including the analysis and availability of documentary evidence, due diligence measures, devising project schedules to meet authorization submission requirements, and serving as the point of contact for BIS inquiries.
Keeps current with regulatory changes, shares updates with executive management, and adapts company activities as needed.
Provides guidance and operational and regulatory support to all SOA departments, including off-site locations (ex: Parts Collection Center [PCC], ports), as well as to the Legal department as a subject matter expert (SME) in aspects of export trade regulations such as contracts, agreements, business arrangements, and special projects.
Interfaces with SBR to obtain and determine Export Control Classification Numbers (ECCNs) for new technologies in future vehicle models.
Seeks out and handles confidential product information from SBR and SOA Product Planning to ascertain ECCNs, analyze the information, and assign classifications to all new service parts and accessories.
Researches export license requirements and submits and manages export licenses as needed.
Collaborates with Toyota Motor North America (TMNA) on ECCN determinations for all Alliance vehicles.
Provides critical support to SOA’s departments to determine ECCNs and licensing requirements for all “one-off” export shipments by reviewing the Commerce Control List (CCL), gathering technical specifications, reviewing applicable control categories and classifications, performing independent research, and obtaining information from manufacturers.
Develops, implements, and maintains SOA’s online Export Control Awareness Course.
Determines job functions that require export training and coordinates with Human Resources (HR) to assign course as needed.
Provides customized training to internal business units and sets business rules with external service providers with respect to export compliance.
Keeps the SOA Export Compliance Manual current with all applicable changes resulting from regulatory updates.
Leads and manages direct report.
Provides guidance to a team of export professionals in all aspects of export compliance and related operational matters.
Oversees the accuracy and timeliness of the Electronic Export Information (EEI) filings in the Automated Commercial Environment (ACE), makes determinations on denied party screening results, and assists in Global Trade Management (GTM) system enhancements from a compliance perspective.
Serves as a SME and engages in the Uyghur Forced Labor Prevention Act (UFLPA) working group with SBR, Subaru of Indiana Automotive (SIA), and SOA to drive forward compliance efforts.
Interfaces with NASI Government and Regulatory Affairs in D.C. to collaborate and raise concerns on proposed regulations affecting the company’s activities from an export control perspective and provides feedback on proposed changes affecting the automotive industry.
Provides support to direct report on Free Trade Agreements (FTAs) and annual solicitation project.