Trade Compliance Manager

Position Overview: The Trade Compliance Manager serves as Vatn’s day-to-day owner of the company's global trade compliance program, administering compliance with the ITAR, the EAR, and associated U.S. sanctions and customs requirements. The successful candidate will have practical experience safeguarding controlled technical data and hardware in an operating environment, along with a strong grasp of the defense industry landscape, including contractor obligations and associated risk frameworks. The position owns jurisdiction and classification determinations, license and agreement preparation, and the tracking of provisos, conditions, and reporting obligations through the life of each authorization. The individual in this role will manage a wide range of compliance matters, including restricted party screening, technology control plans and deemed export controls for foreign person access, recordkeeping, supply chain and contract flow-downs, export classification of shipments and AES filings, internal audits, training, and voluntary disclosures, while providing practical guidance to leadership, program teams, and engineers. They will ensure that program activity, international engagement, and hiring are structured to support operational needs and meet technical and regulatory requirements. The ideal candidate is a proactive, detail-oriented compliance professional with experience in the defense ecosystem and comfort working in a fast-paced engineering and manufacturing environment, able to translate regulatory requirements into decisions engineers and program managers can act on. This is Vatn's first dedicated trade compliance role, and the successful candidate will be as comfortable building procedures, tooling, and training from a limited existing baseline as administering an established program. This role is critical to helping Vatn operate compliantly, protect controlled technology, and scale rapidly across product lines, programs, and international customer engagements.

Key Responsibilities: Program Ownership & Governance Maintain and administer Vatn's Global Trade Compliance Program, covering the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), U.S. economic sanctions, anti-boycott rules, and the Foreign Trade Regulations. Develop and maintain trade compliance policies, procedures, work instructions, training, and audit mechanisms supporting continuous compliance. Conduct periodic self-assessments and report program status, metrics, and open risks to leadership. Maintain DDTC and related registrations, including renewals and § 122.4 notifications for material changes in ownership, address, or senior officers. Serve as a designated Empowered Official following an initial onboarding period, with signature authority for license applications and agreements on behalf of the company. Classification & Licensing Determine and maintain export classification (ITAR USML categories, EAR ECCNs) for company technology, hardware, software, and technical data. Conduct export jurisdiction analysis and prepare commodity jurisdiction (CJ) requests to DDTC and classification requests (CCATS) to BIS where jurisdiction or classification is unsettled. Prepare, submit, and track export license applications (e.g., DSP-5, Technical Assistance Agreements, Manufacturing License Agreements) and EAR license requests or exceptions as needed. Manage post-approval obligations: proviso and condition compliance, agreement execution and party amendments, annual sales and brokering reports, and expiring agreement close-out. Maintain a license and classification compliance matrix, keeping it current as programs and technology evolve. Provide guidance and interpretation of U.S. government export regulations to leadership and technical teams. Contracts Support Review contracts, teaming agreements, NDAs, and proposals for export control clauses, flow-down requirements, and compliance risk. Work directly with the Director of Contracts to classify deliverables and assess foreign national involvement in contract performance before commitments are made. Flag export control risk during proposal development, not just after contract award. Manage receipt and handling of government-furnished and prime-supplied technical data, including distribution statement obligations and DD Form 2345 / Joint Certification Program requirements. Support supplier and vendor flow-downs, including classification guidance to suppliers and screening of the supply base. Technology Control & Party Screening Develop and maintain Technology Control Plans (TCPs) for programs involving foreign national access or international collaboration. Own screening of customers, vendors, partners, visitors, and employees against denied and restricted party lists (e.g., BIS Entity List, OFAC SDN List, DDTC debarred parties, SAM exclusions), including periodic rescreening. Conduct end-use and end-user diligence and red-flag review on international opportunities, including § 126.1 prohibited and proscribed destinations, embargoes, and intermediary or brokering arrangements. Partner with IT and Security on access controls for export-controlled technical data across engineering, PLM/CAD, and collaboration environments, including encryption and cloud storage standards. Trade Operations: Shipping, Import, Dangerous Goods, & Travel Authorize and document physical exports of hardware, including temporary export and import authorizations (DSP-73, DSP-61) for demonstrations, exercises, and repair or return. Manage freight forwarders and customs brokers, including EEI/AES filings, license decrementation, and accuracy of export and import documentation. Own U.S. import and customs compliance, including HTS classification, country-of-origin and valuation determinations, entry accuracy, duty treatment, and CBP recordkeeping obligations. Own the company's dangerous goods program for lithium-battery-powered vehicles and components, including 49 CFR (HMR), IATA DGR, and IMDG requirements - classification, UN-specification packaging, marking and labeling, and shipper's declarations. Maintain the DG training matrix and certification currency for hazmat employees in Shipping & Receiving, Production, and Engineering, and qualify forwarders and carriers for dangerous goods handling. Coordinate with Engineering on UN 38.3 test documentation, state-of-charge requirements, and packaging design for battery-powered systems. Administer procedures governing international travel with controlled technical data, company laptops, and hand-carried hardware. Support international partnerships, field exercises, demonstrations, and customer engagements - ensuring compliant movement of people, information, and materials. Training & Compliance Culture Develop and deliver ITAR/EAR awareness training, particularly for employees in Contracts, Engineering, and Program Management who routinely touch export-controlled information. Provide new-hire onboarding and role-based refresher training, and maintain completion records. Serve as the go-to point of contact for day-to-day trade compliance questions from those teams. Record-keeping & Audit Support Maintain export and import compliance records in accordance with regulatory retention requirements (five years under ITAR § 122.5, and CBP recordkeeping rules for import records). Support internal compliance reviews and government audits. Conduct internal reviews of potential violations and support preparation of voluntary self-disclosures to DDTC or BIS when necessary. Cross-Functional Engagement & External Representation Work closely with engineering, operations, production, finance, and growth teams to determine export and import needs and to develop practical strategies that meet business requirements while ensuring full regulatory compliance. Serve as the coordination point between Contracts, Engineering, Program Management, and Security on trade compliance matters, and participate in program reviews and planning cycles as the trade compliance representative. Serve as the working-level point of contact with DDTC, BIS, and CBP, and support interactions with contracting officers and prime contractor compliance counterparts. Coordinate with outside trade counsel on novel jurisdictional questions, disclosures, and enforcement matters. Escalate anything ambiguous or high-risk - a new technology transfer scenario, an unclear classification, a foreign national access question without precedent - to company leadership, including seeking a DDTC advisory opinion where precedent is genuinely absent.

Qualifications: Required 4-7 years, or equivalent depth, of experience in export control and trade compliance (ITAR/EAR) within a defense contractor, aerospace, or other regulated technology environment Working knowledge of ITAR (22 CFR 120-130) and EAR (15 CFR 730-774) Direct experience with export licensing processes (DSP-5/73, TAA/MLA, EAR license exceptions), including hands-on filing and management of authorizations in DDTC's Defense Export Control and Compliance System (DECCS) Must be a U.S. Person as defined by ITAR (22 CFR 120.62) due to routine exposure to export-controlled systems, technical data, and facilities Eligibility and willingness to be designated as an Empowered Official under 22 CFR 120.67 following an initial onboarding period Strong written and verbal communication skills - this role translates regulatory requirements for non-compliance audiences (contracts, engineering, program management) daily Ability to pass a background check appropriate to a defense contractor environment Preferred Experience supporting maritime, naval, or unmanned systems programs Experience reviewing or supporting U.S. government contracts, including Foreign Military Sales (FMS) and Direct Commercial Sales (DCS) to foreign government end users Export compliance certification (e.g., Export Compliance Professional (ECoP)) or contracts-related certification (e.g., NCMA CFCM/CPCM) Experience with AES (Automated Export System) filing Experience with U.S. import and customs compliance, including HTS classification, CBP entry, and temporary import procedures Dangerous goods certification (49 CFR HMR, IATA DGR, and/or IMDG), particularly for lithium battery shipments Experience developing or administering Technology Control Plans and foreign national access programs Working knowledge of FAR/DFARS, sufficient to identify and address export control implications in government contract clauses and flow-down requirements Prior experience in a CMMC/NIST SP 800-171 environment Ability to obtain and maintain a U.S. security clearance Bachelor's degree in a related field (business, international affairs, engineering, or paralegal/legal studies), or equivalent hands-on experience Vatn is an equal opportunity employer.