Director, Trade Compliance

Description

This position is on-site at our headquarters in Bryan, TX, but candidates in Washington, D.C. will be considered for our D.C. office.

Position Summary:

The Director, Trade Compliance, owns the design, implementation, and day-to-day execution of BlueForge Alliance's enterprise import/export and trade compliance program across BFA and its affiliated entities. This role is the organization's authoritative subject-matter expert on the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), OFAC economic sanctions, and U.S. Customs and Border Protection (CBP) import requirements - and is accountable for translating that regulatory complexity into workable controls that let mission work move at speed without exposing the enterprise to enforcement risk. Because BFA operates at the center of the defense industrial base involving submarine industrial base initiatives, technology transition, supplier development, and international partnership activity (including AUKUS-related work with foreign vendors and suppliers), this position carries high consequence. The Director will build the program, own the controls, train the workforce, and personally serve as the organization's signatory authority for export authorizations. This position is expected to be formally appointed as an Empowered Official (EO) under 22 CFR A7 120.67 on a near-immediate basis following hire and completion of BFA's appointment process. In addition to the following details, by being a BlueForger, you will be expected to uphold and exemplify our values of Belonging, Selfless Service, Integrity, Leadership, Respect, and Excellence. We uphold these values upon a backbone of humility driven by a culture of safety, vulnerability, and purpose.

Essential Duties and Responsibilities:
• Export Controls - ITAR & EAR

o Serve as the enterprise authority on ITAR and EAR applicability, jurisdiction, and classification; make and document USML category / ECCN determinations and manage commodity jurisdiction (CJ) and CCATS requests as needed.

o Prepare, review, and upon EO appointment sign DDTC authorizations including DSP-5, DSP-73, DSP-85, Technical Assistance Agreements (TAAs), Manufacturing License Agreements (MLAs), Warehouse and Distribution Agreements, amendments, and general correspondence.

o Administer BFA's DDTC registration (DS-2032) and maintain registration currency across affiliated entities; manage DECCS submissions, provisos, and license administration.

o Evaluate and apply ITAR exemptions with rigor and documentation, including A7126.4 (U.S. Government transfers), A7125.4 (technical data), and the AUKUS exemption at 22 CFR A7 126.7 and its excluded-technology list, in coordination with government sponsors and program teams.

o Administer EAR compliance for dual-use items, including license determinations, license exception analysis (e.g., STA, TSU, ENC), Part 744 end-use/end-user screening, and encryption reporting obligations.

o Own deemed export controls: foreign national access assessments, Technology Control Plans (TCPs), badging/escort and IT access controls, and coordination with Security, HR, and IT.

o Manage ITAR Part 129 brokering analysis and registration where applicable, and Part 130 political contributions, fees, and commissions reporting.
• Sanctions & Restricted Party Screening

o Own the OFAC sanctions compliance program, including SDN and sectoral screening, the 50 Percent Rule analysis, blocked-property and rejected-transaction reporting, and general/specific license evaluation.

o Administer enterprise restricted party screening across suppliers, subrecipients, partners, event attendees, visitors, and personnel - including BIS Entity List, Denied Persons, Unverified List, Military End User/MEU, DDTC Debarred Parties, and SAM exclusions - and manage escalation and hit-resolution workflow.

o Advise on Section 1260H, NDAA Section 5949, and related restricted-source and supply chain prohibitions relevant to defense industrial base work.
• Imports, Customs & Duty Management

o Own U.S. import compliance and CBP reasonable care obligations, including HTS classification, valuation, country-of-origin determination and marking, free trade agreement qualification (e.g., USMCA), and ACE/ISF filing accuracy.

o Manage customs broker relationships, powers of attorney, entry review and post-entry corrections, Post Summary Corrections, protests, prior disclosures, and responses to CBP Forms 28/29 and Requests for Information.

o Design and administer duty drawback, duty deferral, Foreign Trade Zone, and tariff-mitigation strategies; assess Section 232 and Section 301 tariff exposure and exclusion opportunities.

o Advise on Buy American Act, Trade Agreements Act, Berry Amendment, and DFARS specialty metals (252.225-7009) sourcing restrictions in coordination with Contracts and Supply Chain.
• Program Leadership, Governance & Risk

o Build, maintain, and continuously improve BFA's written Export Compliance Program / Import Compliance Manual, procedures, work instructions, and record retention program (22 CFR A7 122.5; 15 CFR Part 762; 19 CFR Part 163).

o Design and deliver role-based trade compliance training for executives, program managers, engineers, contracts, supply chain, HR, and travelers; drive measurable trade compliance literacy across the enterprise.

o Conduct internal audits, self-assessments, and transaction testing; investigate potential violations; and lead the analysis, preparation, and submission of voluntary self-disclosures to DDTC, BIS, OFAC, or CBP in coordination with the CLO and outside counsel.

o Maintain a trade compliance risk register; report program health, metrics, findings, and remediation status to the CLO, executive leadership, and Board committees as directed.

o Serve as BFA's primary interface with DDTC, BIS, OFAC, CBP, and DCSA/government sponsors on trade compliance matters; manage outside trade counsel and consultants against defined scope, budget, and quality standards.

o Select, configure, and administer trade compliance technology (screening, classification, license management, and trade data tooling) and integrate controls into ERP, procurement, and travel workflows.

o Build and maintain strong relationships with internal and external stakeholders.

• Performs other related duties as assigned.

Supervisory Responsibilities:

• Manages, develops and trains staff.
• Oversee the daily workflow of the department.
• Provides constructive feedback for timely performance evaluations.
• Directs and supervises customs brokers, freight forwarders, outside trade counsel, and consultants as an extension of the compliance function.
• Serves as a functional leader to non-reporting personnel across Programs, Supply Chain, Contracts, Security, and IT on trade compliance execution.

Requirements

Required Skills/Abilities:
• Excellent analytical, organizational, and problem-solving abilities.
• Ability to manage multiple projects simultaneously and meet deadlines.
• Proficient in trade compliance and restricted party screening platforms, DECCS, ACE, ERP/procurement systems, and Microsoft Office Suite.
• Exceptional interpersonal and communication skills, with the ability to work effectively with cross-functional teams and stakeholders.
• Demonstrated ability to render clear, defensible written regulatory analysis and to translate technical export/customs requirements into plain-language guidance for non-specialists.
• Sound, independent judgment and the personal fortitude to escalate, halt, or decline a transaction consistent with Empowered Official obligations.
• Ability to work directly with engineers and technical staff to understand hardware, software, and technical data sufficiently to reach accurate jurisdiction and classification determinations.
• Discretion and sound judgment in handling export-controlled, proprietary, and confidential information.
• Strong ethical standards and integrity.
• Detail-oriented, proactive, and adaptable to changing priorities.

Education, Certifications, and Experience:
• Bachelor's degree in Business Administration, International Trade, Supply Chain, Engineering, Political Science, or a related field. J.D. or Master's degree is a plus.
• Minimum of 8 years of progressive trade compliance experience spanning ITAR, EAR (dual-use), OFAC sanctions, imports/customs (CBP), HTS classification, duty/drawback, and logistics compliance.
• Demonstrated hands-on experience preparing and managing DDTC licenses and agreements (DSP-5, DSP-73, TAA/MLA) and BIS license applications.
• Experience in the defense industry, aerospace, government contracting, or with a federal agency is strongly preferred; shipbuilding/maritime or submarine industrial base exposure is a plus.
• Prior service as an ITAR Empowered Official is strongly preferred; candidates must meet and be able to satisfy all criteria of 22 CFR A7 120.67 at or shortly after hire.
• Licensed U.S. Customs Broker (LCB) credential is a strong plus.
• Certified U.S. Export Compliance Officer (CUSECO), Certified Export Specialist (CES), Certified Customs Specialist (CCS), or comparable credentials are preferred.
• Experience building or substantially maturing a trade compliance program in a growing or multi-entity organization is highly desirable.
• Experience preparing voluntary self-disclosures and managing regulatory inquiries or audits is highly desirable.

Physical Requirements:
• Prolonged periods of sitting at a desk and working on a computer.
• Ability to lift up to 20 pounds.

Travel Expectations:
• Expected travel: Up to 25%.
• ** If based in at the Bryan, HQ, then periodic travel to the DC office for meetings may be required.