Export Compliance Manager

The Aerial Export Compliance Manager is responsible for leading the Company's export compliance program and ensuring that all exports of defense articles, technical data, and services comply with U.S. export control laws and regulations, including the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). Aerial is a military and defense manufacturer, and the vast majority of the Company's work is with the U.S. Government and the Department of War. This position will develop and maintain export compliance policies, training, and audits, manage export licensing, and serve as the Company's ITAR Empowered Official with authority to sign export license applications and agreements submitted to the U.S. Department of State.

JOB DUTIES AND ESSENTIAL FUNCTIONS:

• Develop, implement, and manage the Company's export compliance program, working closely with the senior leadership team to develop and update policies and guidance.

• Maintain the Company's ITAR registration with DDTC, including timely renewals and required notifications of changes.

• Develop, implement, and maintain Technology Control Plans governing access to ITAR- and EAR-controlled technical data, drawings, specifications, and defense articles in engineering, manufacturing, inspection, and shipping areas, including visitor and foreign person access controls.

• Conduct restricted party screening of customers, suppliers, subcontractors, and visitors, and ensure export compliance requirements are flowed down to suppliers and subcontractors supporting defense programs.

• Conduct internal compliance training and general export awareness training for all relevant employees.

• Provide expert advice and guidance on the export of defense articles, technical data, and defense services under the ITAR, and on dual-use, commercial, and military items subject to the EAR.

• Provide expert advice on shipments and compliance with the FTR, and on countries, entities, and individuals subject to OFAC restrictions.

• Support the senior leadership team in addressing export issues on existing defense programs, DoD prime and subcontracts, and new business opportunities.

• Determine and certify the appropriate legal authority for exports of defense articles, technical data, and defense services, as well as dual-use or military commodities and technologies regulated by the EAR.

• Review all aspects of proposed exports and temporary exports (including proposals, contracts, purchase orders, presentations, and product development) to verify the legality of transactions and the accuracy of information to be submitted.

• Prepare and administer license applications and agreements requiring U.S. Government approval for the export of technical data, hardware, and services; coordinate potential imports; and serve as liaison with U.S. Government officials as necessary.

• Manage ITAR licensing (preparation, submission, and implementation of approvals) and compliance, including DECCS license applications, Technical Assistance Agreements, Commodity Jurisdictions, and all other ITAR licensing matters as they arise.

• Manage EAR licensing (preparation, submission, and implementation of approvals) and compliance, including BIS-748P license applications for export and reexport, Commodity Classifications, determination of licensing obligations, use of license exceptions, and all other EAR licensing matters as they arise.

• Ensure implementation of the Company export compliance manual across all Company locations, including training on ITAR and EAR procedures, customs requirements, export/import documentation, license management, and recordkeeping, and update the manual as export regulations change.

• Maintain an export and import control database and tracking system for licenses, agreements, correspondence, and training.

• Conduct and participate in periodic internal export compliance audits, and investigate all matters of potential non-compliance, report findings to senior management, and prepare voluntary disclosures in coordination with outside advisors and counsel, as directed.

• Direct corrective actions as necessary to maintain compliance.

• Other duties as assigned by management.