- Simpang Ampat Pulau Pinang Malaysia
Working Location
Job Description
Responsibilities
Job Title: Trade Compliance Program Manager
Location: Sungai Jawi, Penang, Malaysia
Employment Type: Full-Time
Position Overview
We are seeking an experienced Trade Compliance Program Manager to build, register, and
lead our Internal Compliance Program (ICP) under Malaysia’s Strategic Trade Act 2010 (STA).
Currently, our high-performance AI server shipments operate on single-use eSTA permits via
DagangNet. The core objective of this role is to establish an audited ICP with the Ministry of
Investment, Trade and Industry (MITI) Strategic Trade Secretariat (STS) to transition our
operational model from single permits to Bulk and Multiple-Use Export Permits. You will
serve as the officially Nominated Compliance Officer, managing regulatory audits, customer
screening, KYC frameworks, and post-deployment field verifications.
Key Responsibilities
1. ICP Registration & MITI STS Authority Relations
• ICP Development & Audit: Build, document, and register our company’s Internal
Compliance Program (ICP) to meet MITI STS requirements, moving the business off
per-shipment single permits to 2-year Bulk and Multiple-Use permits.
• Regulatory Lead & Liaison: Act as the primary, official point of contact for MITI STS
officers during compliance reviews, on-site audits, and permit approvals.
• Permit Operations: Manage day-to-day eSTA permit filings via DagangNet during the
transition phase, ensuring seamless customs declarations (K2) and classification of
advanced dual-use hardware (NVIDIA GPUs, high-speed interconnects).
2. End-to-End Customer Screening & Due Diligence Framework
• KYC & Screening System: Design and maintain a comprehensive end-user screening
process to check prospective buyers, distributors, and integrators against international
restricted party lists, sanctions, and anti-diversion protocols.
• End-Use / End-User Validation: Obtain, verify, and archive legally binding End-User
Statements (EUS) and export documentation required under STA guidelines.
• Pre-Sales Screening: Conduct background verification, technical end-use evaluation,
and initial site reviews prior to sales commitment.
3. On-Site Inspection & Physical Verification (Pre-Sales & Post-Sales)
• Pre-Sales Site Visits: Perform physical on-site audits of customer office premises and
storage facilities, taking geotagged photographic evidence to verify operational
legitimate presence.
• Post-Sales Deployment Inspections: Travel to customer data centers, colocation
facilities, and deployment sites to physically verify that AI server racks are installed
and operating at declared, approved locations.
• Visual Audit Trail: Create and maintain a strict repository of photographic, video, and
serial number verification logs for post-sales tracking and MITI audit readiness.
4. Internal Governance & Record Keeping
• Corporate Audits: Build a system (with resources) to conduct regular internal audits of
shipment manifests, server serial tracking, and end-user documentation.
• Record Retention: Enforce strict record-keeping standards ensuring all export
declarations, permit approvals, and verification logs are retained for the mandatory 6-
year period.
• Internal Training: Conduct company-wide training for sales, logistics, and engineering
teams regarding export controls and red flag indicators.
Key Requirements
• Experience: 5+ years of experience in sales, within server manufacturer or data center
hardware sectors in Malaysia. We are not completely looking for a candidate limited to
trade compliance experience only.
• MITI & STA Expertise: Hands-on mastery of Malaysia’s Strategic Trade Act 2010, MITI
STS guidelines, and direct experience registering an ICP for Bulk/Multiple permits.
• Systems Proficiency: Expert user of DagangNet (eSTA / ePermit portal) for strategic
trade filings. (Training provided)
• Field Readiness: Willingness to travel to customer offices, data centers, and
deployment sites locally and regionally for pre- and post-sales visual verification.
• Technical Hardware Awareness: Familiarity with high-performance server
architectures, GPU systems (NVIDIA), and dual-use classification guidelines.
• Language & Communication: Fluent in English, Mandarin and Bahasa Malaysia with
strong presentation skills for interacting with regulatory officers and corporate clients
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