First Sale for Export Administrator

Position Summary 

Xylem is seeking a detail-oriented First Sale for Export (FSFE) Program Administrator to manage the global FSFE program across all business units. This individual will serve as the central authority for ensuring the compliant execution of FSFE transactions and will be responsible for developing, implementing, and maintaining policies, procedures, and recordkeeping practices that meet U.S. Customs and Border Protection (CBP) requirements. The FSFE Program Administrator will help drive internal audits, support external government originating audits, and work closely with global procurement, logistics, tax, and finance stakeholders. 

Key Responsibilities 

• Program Governance 

• Help to develop, implement, and maintain a robust FSFE compliance program aligned with CBP regulations and Xylem’s global trade policies. 

• Serve as a global subject matter expert for FSFE transactions and valuation compliance. 

• Assist in developing and implementing policies and standard work instructions for the documentation, qualification, and execution of FSFE transactions across the enterprise. 

• Audit and Documentation Management 

• Ensure that all FSFE-related records—including purchase orders, invoices, incoterms, contracts, proof of export, and value reconciliations—are accurately maintained and readily retrievable for a minimum of five (5) years. 

• Help in the coordination of internal audits and readiness assessments to ensure ongoing compliance and audit preparedness. 

• Support CBP audits or inquiries related to FSFE, working closely with legal, business management, customs brokers, and external advisors as needed. 

• Cross-Functional Engagement 

• Collaborate with global sourcing, procurement, logistics, tax, and finance teams to ensure implementation of FSFE principles . 

• Provide training and guidance to internal stakeholders and global trade coordinators on FSFE requirements, documentation, and best practices. 

• Partner with regional and site-level compliance staff to monitor local adherence and support corrective actions as needed. 

• Continuous Improvement and Monitoring 

• Monitor changes in trade regulations and CBP rulings impacting FSFE to ensure the program remains compliant and competitive. 

• Identify and implement process improvements, automation opportunities, and KPIs to enhance the effectiveness and efficiency of the FSFE program. 

• Participate in industry working groups and maintain a network of trade compliance peers to stay informed of emerging trends and enforcement actions. 

• Other Trade Compliance Responsibilities as Needed 

While this role’s primary responsibility will be to administer Xylem’s FSFE program, the successful candidate may also be asked to perform other tasks related to trade compliance, including but not limited to classification, interaction with Customs brokers, denied party screening, and supporting other projects or issues that may arise. 

Qualifications 

• Bachelor’s degree in International Business, Supply Chain, Finance, Accounting, or related field. 

• 5+ years of experience in global trade compliance, including demonstrated expertise with U.S. Customs valuation rules and First Sale for Export transactions. 

• Strong understanding of U.S. import regulations, documentation requirements, and recordkeeping obligations under 19 CFR. 

• Experience with ERP systems (SAP preferred), trade compliance software, and data analysis tools. 

• Proven ability to lead cross-functional initiatives and manage complex compliance programs. 

• Exceptional organizational skills, attention to detail, and ability to work independently in a fast-paced environment. 

• Strong written and verbal communication skills with the ability to interface at all levels of the organization. 

Preferred Qualifications 

• U.S. Customs Broker License or Certified Customs Specialist (CCS) certification. 

• Experience with Customs Reconciliation filings and valuation adjustments. 

• Exposure to global FSFE practices beyond the U.S., including EU customs regimes.