Compliance Analyst

Description

The United States Department of State, Bureau of Political-Military Affairs, Office of the Directorate of Defense Trade Controls (PM-DDTC) is responsible for the regulation of defense trade through the Arms Export Control Act (AECA) and its implementing regulations, the International Traffic in Arms Regulations (ITAR). DDTC regulates temporary and permanent exports and the temporary import of defense articles, defense services, and technical data involving items on the United States Munitions List (USML). DDTC regulates the brokering of defense articles, defense services, and technical data. DDTC maintains the registration of manufacturers, exporters and brokers and issues export authorizations. DDTC administers the commodity jurisdiction process, a formal USG decision process to determine which specific items are controlled by the USML or by the Department of Commerce’s Export Administration Regulations. DDTC ensures compliance with the ITAR and AECA through its support of criminal enforcement actions undertaken by the Department of Justice, civil enforcement actions initiated in-house, disclosure program through which companies are encouraged to report violations they have discovered, and pre- and post-license checks to confirm that goods are being shipped as authorized by the export license.

• Facilitates the registration of exporters, manufacturers, and brokers under Parts 122 and 129 of the ITAR under close supervision.
• In accordance with established office policies and procedures, reviews information submitted by registrants to meet the requirements of Section 122.2 concerning criminal violations or indictments under relevant statutes (Section 120.27), as well as foreign ownership and control, and notices of changes submitted as required under Section 122.4 concerning foreign ownership and control.
• Facilitates attendant review of mergers and acquisitions involving registrants.
• Resolves routine matters with regard to company registration and requests for change in registration and refers unique matters to supervisor and senior staff for resolution.
• Reviews and take action on license request that are the subject of a “Watch List” hold for enforcement reasons. The Watch List has entities that are suspected, alleged, indicted or convicted of civil and criminal violations of the AECA and ITAR and certain “enumerated statutes.” Action on a license hold is based on all available information (e.g., Watch List entry, office files and computer database searches), coordination with law enforcement and consultation with the supervisor.
• Takes initial action on all incoming voluntary disclosures from the defense industry on civil violations of the AECA and ITAR. Reviews and writes summaries of incoming voluntary disclosures to be triaged by the supervisor. For disclosures of a minor violation, create a computer record and draft a response for the chief’s signature. For incomplete disclosures, draft a letter with response deadline for the chief’s signature, maintain a tracking system and insure receipt of full disclosure information. For all other violations, create a computer record and assign to appropriate employee.
• Reviews various cases involving violations of the AECA or ITAR and after consultation with supervisor, plans an approach, conducts fact-finding, performs record searches and documents conclusions. Using generally established format as a guide, prepares letters of response for supervisor to pursue and close each case.
• Reviews and takes action on voluntary disclosures assigned by the supervisor, initially working minor violations. Follow office policies, procedures, and guidance received from the supervisor or senior specialist. Plan an approach, conduct fact-finding, perform search of records, attend meetings and then document findings. Initiate discovery of additional facts. Consult with supervisor and take action. Prepare letter for supervisor signature responding to the violation, including requirement for corrective action to close each case. Perform any follow-up as directed by supervisor.
• Performs record searches, reviews and analyzes license approvals, produces comprehensive reports of finding and provide information that support criminal investigations by the DHS ICE, FBI, and U.S. Attorneys.
• Participates in the Company Visit Program through periodic, domestic travel around the U.S to pre-selected defense companies. Gather information, prepare plan, conduct visit and report on findings.
• Maintains a list of parties debarred and ineligible to participate in the export of defense articles and services under the ITAR for use by the Department and the defense industry.
• Monitors compliance cases involving statutory debarment of individuals or companies convicted of violating the AECA. Reviews case files, indictments and court orders. Reports findings to supervisor. As directed, processes requests for reinstatement of export privileges upon termination of debarment.
• Engages with the Committee on Foreign Investment in the U.S. (CFIUS) process.
• Reviews requests from the regulated public for advisory opinions regarding application of the ITAR, and prepares responses for review, approval and signature by supervisor.
• Reviews compliance issues arising from registration, mergers and acquisitions, CFIUS, and other contexts, and takes appropriate action as directed by supervisor.
• Performs special projects or tasks as assigned by supervisor or senior specialist.
• Performs all other duties as assigned, including escorting and administrative tasks.
• Reviews license requests referred from DTCL to ensure appropriate compliance with registration requirements. Initiates inquiry with and obtains appropriate documentation from US parties or other DDTC elements. Prepares final action for senior staff approval.
• Updates and maintains State Department’s Watch List database of entities of concern, both to comply with the AECA and to support foreign policy implementation via arms export licensing. Helps identify and implement technical improvements to the system.
• Helps monitor team efforts to expand and refine abilities, respond to shifts in workload, and maintain high quality work products.
• Coordinates and liaises with interagency non-proliferation and export control community on arms trafficking/proliferation matters involving the AECA and ITAR, as well as international export control outreach.
• Coordinates with the Office of Defense Trade Controls Licensing on compliance and enforcement matters, including license suspensions, revocations, denials, and eligibility to participate in defense trade.
• Helps coordinate plans and operations within DDTC to help identify and prevent violations of U.S. export laws and regulations and support remedial action, such as civil enforcement and/or prosecution of individual or corporate violators of the AECA/ITAR.
• Working with other DTCC staff, conducts pro-active outreach to the U.S. and foreign defense community to promote compliance with U.S. export laws and regulations. Speaks at government and industry conferences. Participates in Company Visit program activities. Responds to inquiries concerning compliance matters.

Requirements

• Bachelor’s Degree or combination of post- high school education and five years of experience with regulatory compliance or civil or criminal enforcement.
• Good judgment and ability to work with supervision.
• Good interpersonal skills and ability to resolve disputes in a timely and professional manner.
• Good written and verbal communication skills and presentation skills. The candidate should be prepared to provide writing samples.
• Good organizational skills including the ability to assist on multiple projects consistent with established timeframes.
• Ability to synthesize information and develop recommendations for management based on an analysis of the information.
• Has working knowledge of Microsoft Office Suite programs and be able to operate all office equipment including but not limited to: telephones, copy machines, fax machines, scanners, printers, and computers.
• May be required to travel within domestic and/or international.
• Requires at the minimum, a security clearance of Secret with the ability to obtain a Top Secret or Top Secret/SCI at the request of the COR.