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Head of Export Control & Sanctions Compliance China
In a nutshell
You implement policies and procedures in all entities in China to safeguard compliance with ASML’s Global Export Control & Sanctions Strategy, you manage adherence to these policies and procedures, in order to assure compliance with dual-use export control laws and regulations of the jurisdictions to which ASML with its business dealings are subjected to. This includes:
1. Monitor development of Export Control & Sanction regulations in China as well as of the international regulations applicable to ASML.
2. Maintain and improve Internal Compliance Plans in China and potential other regions / sites in your area of responsibility
3. Maintain and improve the ExportControl Framework, execute and monitor controls in China necessary to ensure compliance
4. Pro-actively advise local management on Export Control & Sanctions topics
5. Coordinate the Export Control & Sanctions aspects of Chinese business cases with the central Export Control function, monitor progress of the approval process and ensure correct and consistent implementation of Export Control & Sanctions requirements
6. Prepare and submit export license applications, ensure timely license reporting and engage with the licensing authorities where and when necessary
7. Responsible for maintaining licenses in our compliance tool, SAP Global Trade Services (GTS)
8. Provide guidance to stakeholders on Sanctioned Party List (SPL) and legal control related blocks in SAP GTS / Oracle
9. Assess and follow-up on End-use Statement requirements with involved stakeholders
10. Stimulate and establish good working relationships at different levels with relevant departments within ASML by giving trainings and participating in departmental meetings that contribute to increasing awareness and compliance
11. Perform periodic risk assessments including reviews of the impact of new regulations
12. Contribute to periodic reporting on export controls & sanctions to senior management
13. Participating in reviews of export control or sanctions related incidents
Risk Mitigation Export Controls & Sanctions
You also implement policies to pro-actively manage risk identification for Export Controls & Sanctions and mitigate such risk through knowledge of the business facts in combination with the export control laws and regulations in the jurisdictions ASML operates in, and advice and convince the business to adopt the proposed mitigating measures. You maintain and improve the implementation of the framework of controls (Export control framework) that ASML uses to manage and mitigate risks.
Together with the team you ensure open and transparent relationships with licensing and enforcement authorities in the jurisdictions in which ASML operates. This includes supporting ASML in governmental audits.
You will also establish a strong relationship with ASML employees to ensure cooperation and assistance in the successful implementation of export control related (initiated) projects. You will provide advice on export control risks and controls/measures, and if required, will work closely with external advisors.
You also represent ASML externally in interest groups, peer meetings and government bodies in China . Through direct persuasion or through business interest organizations, you attempt to influence the actions, policies, or decisions of relevant officials, legislators or members of licensing agencies in written or oral communications.
Masters degree in law or equivalent combination of education and/or experience
1. Min. 12 years of experience, of which at least 6 in a Export Controls within a multinational corporation, law firm or consulting company.
2. In-depth knowledge and experience with both the Chinese Export Control and Sanctions regulations as well as the U.S. Export 3. Administration Regulations (EAR) is a requirement.
4. Background in and knowledge of the export control aspects of engineering and software development would be an asset.
5. Knowledge working in a multidisciplinary environment and in multi-cultural teams.
1. Strong drive with a hands-on, structured, accurate and result oriented working style
2. Excellent communication skills with the ability to motivate and drive others, build relationships and influence other functional areas
3. Able to cope with a multicultural, dynamic and changing and complex environment
4. Strong analytical skills, with the ability to translate complex business issues into simple problem statements, clear processes and actions
5. Good time management skills and able to manage towards tight deadlines
6. Show ownership of issues from start to finalization
7. Eye for detail
Fluent in English and Mandarin, both oral and written