Export & Defense Compliance Manager

Description

Graham Corporation and Subsidiaries 

Job Title: Manager, Export & Defense Compliance 

Reports To: Chief Financial Officer

FLSA Status & EEO Code: Full Time Exempt

Division/Department: GHM Corporation/Export Compliance

Level of Work: Level II, III

Job Hours: Full time, requiring approx. 40 hours a week.

Position Summary:

Graham Corporation (“Graham”) seeks a Manager, Export & Defense Compliance who will be responsible for the ongoing execution (including training and auditing) and oversight of the company’s global export compliance program to ensure compliance with the International Traffic In Arms Regulations (ITAR), Export Administration Regulations (EAR), Antiboycott laws, Office of Foreign Assets Controls (OFAC), Foreign Trade Regulations, the National Industrial Security Program Operating Manual (NISPOM) and Controlled Unclassified Information (CUI) regulations. 

The Manager, Export & Defense Compliance will report directly to Graham’s CFO. The Manager, Export & Defense Compliance will fulfill the Directorate of Defense Trade Controls (“DDTC”) role of “Empowered Official” with the legal empowerment to sign license applications and other requests for approval on Graham’s behalf.

Key Responsibilities:

• Regulatory Compliance Oversight - full compliance with ITAR, EAR, CUI and other export control regulations; monitor changes to ensure up-to-date; develop and implement policies, procedures, controls as needed.
• Export Control Management - manage export control compliance program; determine product classifications; support export license applications.
• CUI Compliance - oversee NIST 800-171 framework and DFARS 252.204-7012 requirements; ensure safeguarding with respect to marking, storing, transmitting, accessing; develop policies and procedures.
• Prepare and submit export license applications and other required documentation to government agencies.
• Manage the classification of products and technologies to ensure compliance with regulatory requirements.
• Monitor changes in export regulations and update internal policies and procedures as necessary.
• Provide training and guidance to employees on export compliance requirements and best practices regarding ITAR, EAR, OFAC and CUI.
• Serve as the primary escalation point for all export and DoD information security - related compliance questions.
• Provide strategic and comprehensive advice and guidance concerning the requirements and obligations of export and import of defense articles, technical data, defense services, brokering, payments of fees & commissions under the ITAR and military, commercial, dual use items, military items transferred to the EAR and CUI compliance.
• Provide advice regarding countries, entities and individuals the subject of OFAC restrictions. 
• Assist Graham’s business units as required, with determining export jurisdiction and classification of new product development.
• Oversee the company Department of State Defense Export Control and Compliance System account.
• File the company’s annual Department of State registration.
• Support Graham’s business units with any queries regarding ITAR licensing (preparation, submission, implementation of approval) and compliance protocols regarding: 
•           Form DECCS licenses
•           Technical Assistance Agreements
•           Commodity Jurisdictions
•           Use of ITAR license exemptions
•           All other ITAR licensing matters as they occur
• Support Graham’s business units with any queries regarding EAR licensing (preparation, submission, implementation of approval) and compliance protocols regarding:
•          748P licenses for export and re-export
•          Commodity Classifications
•          Use of EAR License exceptions 
•          All other EAR licensing matters as they occur
• Maintain an Export and Import Control Database and Tracking system for management of licenses, agreements, correspondence and training for the company.
• Conduct internal export and DoD information security compliance audits of specific location(s) on an annual basis to include review of all work instructions, policies and procedures of the company locations related to export and DoD information compliance activities of the individual functional department
• Investigate all matters of potential non-compliance, coordinate a report of finding with the Company’s Compliance Committee.
• Oversee/direct and follow up on corrective actions as necessary to address audit findings.
• Interface with government agencies, such as the Bureau of Industry and Security (BIS) and the DDTC, as necessary to ensure compliance with regulatory requirements.
• Act as Graham’s point of contact regarding export and defense compliance questions. Collaborate with department heads and business unit leaders as needed.
• Support Graham in conducting mergers and acquisitions due diligence and in the preparation of filings with the DDTC and CFIUS related to the M&A activities as appropriate.

Requirements

Qualifications: Qualifications:To qualify for this position, an individual must possess the following knowledge, training, experience and abilities:

• Bachelor’s degree. Business, International Relations preferred.
• Minimum 10 years related work experience directly related to export/import regulations (ITAR, EAR, FTR, OFAC, FCPA), Export Control Reform, Compliance programs, Export jurisdiction and classifications self-classification, export licensing and license exemptions/exceptions, Technical Assistance Agreements (“TAAs”), Commodity Jurisdiction requests. Commodity Classification Requests, and Technology Control Plans. 
• Demonstration of:
•          Strong writing, communication, training and research skills with attention to detail;
•          Ability to work independently with general guidance and as a team player; 
•          Strong organizational skills and ability to establish priorities among a wide array of projects; and
•          Attention to Detail: High attention to detail in reviewing documentation, export classifications, and regulatory        requirements.
•          Problem Solving: Skilled at resolving compliance issues and provide strategic recommendations.
•          Sound judgment, professional demeanor, good work ethic and business acumen.
• Strong Microsoft Excel and Word skills – with Project a plus.
• Working knowledge of export regulations referenced required. Expertise in U.S. Munitions List and corresponding EAR classifications required. 
• Experience with Facility Security Officer requirements and compliance with the National Industrial Security Program Operating Manual and CUI.

Other:

• Must be willing to work overtime as required.
• Travel up to 10% of working time.
• Graham will consider remote work requirements for highly qualified candidates.
• Professional certification in export compliance, such as Certified Global Trade Compliance Specialist (CITCS), is preferred.

Physical and Mental Demands: The physical demands and work environment characteristics described here are representative of those that must be met by an employee to successfully perform the essential functions of the position. Reasonable accommodations may be made to enable individuals with disabilities to perform the essential functions.

• Physical demands: While performing the duties of this position, the incumbent is primarily required to sit, stand, walk, stoop, and bend. Required to speak and communicate clearly with others. 
• Mental demands: While performing the duties of this position, the incumbent is required to read, write, analyze data and reports, exercise judgment, develop plans, procedures and goals, present information to others and work under pressure.
• Work Environment: This job primarily operates in a clerical office setting. This role routinely uses standard office equipment such as computers, phones, photocopiers and filing cabinets. 

Work Authorization/Security Clearance:

Must be a U.S. citizen. Ability to obtain U.S. government security clearance is required.

This job description is not all-inclusive but rather serves as a general guideline of the current needs of the position and can be modified at the discretion of management to meet current business needs. Experience and education requirements are the primary basis for awarding this position, however substitutions that are essentially equivalent may be made as they relate to the essential functions, duties, and responsibilities of this position