We advise importers on the regulatory regimes administered by U.S. Customs and Border Protection (CBP), including tariff classification under the HTSUS, customs valuation, country-of-origin analysis, free trade agreement qualification, Section 301, Section 232, and IEEPA tariff exposure, antidumping and countervailing duty matters, and forced-labor compliance under the UFLPA.

Areas of work:

• Tariff classification and binding ruling requests

• Customs valuation, including first sale and related-party pricing

• Country of origin and substantial-transformation analysis

• USMCA and other free trade agreement qualification

• Section 301, Section 232, and IEEPA tariff strategy

• Antidumping and countervailing duty compliance

• UFLPA and forced-labor compliance

• C-TPAT and other Trusted Trader programs

• Prior disclosures and penalty mitigation

• CBP audits and focused assessments

• Court of International Trade litigation

We counsel companies on the Export Administration Regulations administered by the Bureau of Industry and Security (BIS) and the International Traffic in Arms Regulations administered by the Directorate of Defense Trade Controls (DDTC), including controls on semiconductors, advanced computing, and other strategic technologies.

Areas of work:

• Commodity jurisdiction and ECCN / USML classification

• Export and reexport license applications

• License-exception qualification

• Deemed-export analysis and technology control plans

• Encryption controls and self-classification reports

• Entity List, Unverified List, and Military End-User List screening

• Foreign Direct Product Rule analysis

• ITAR registration, brokering, and licensing

• Voluntary self-disclosures to BIS and DDTC

• Internal investigations and administrative enforcement defense

We represent clients in matters involving sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), including the Russia, Belarus, Iran, Cuba, Venezuela, China-related, North Korea, and Global Magnitsky programs, and secondary-sanctions exposure for non-U.S. persons.

Areas of work:

• Transactional sanctions diligence and clearance

• Specific license applications to OFAC

• General License qualification analysis

• 50 Percent Rule and ownership analysis

• Blocked-property reporting and rejected-transaction reports

• Voluntary self-disclosures to OFAC

• Sanctions provisions in commercial agreements

• Internal investigations and enforcement defense

• Sanctions risk assessments

We design, assess, and remediate trade compliance programs benchmarked against current government guidance, including BIS export-compliance guidelines, OFAC's Framework for OFAC Compliance Commitments, and DOJ's Evaluation of Corporate Compliance Programs.

Areas of work:

• Compliance program assessments and gap analyses

• Written policies and standard operating procedures

• Restricted-party screening vendor selection and configuration

• Red-flag identification and escalation protocols

• Anti-boycott compliance under 15 C.F.R. Part 760 and 26 U.S.C. § 999

• Internal audits and compliance assessments

• Training for legal, commercial, engineering, and operations teams

• Integration with corporate ethics and compliance functions

We work with importers and manufacturers on supply-chain design strategies to mitigate tariff exposure and reduce regulatory risk, including country-of-origin restructuring, first-sale valuation, foreign-trade zone strategies, and duty drawback.

Areas of work:

• Country-of-origin and substantial-transformation planning

• First-sale valuation analysis

• Foreign-trade zones and bonded warehouses

• Duty drawback (manufacturing, unused merchandise, rejected merchandise)

• Tariff engineering through product modification and reclassification

• Vendor diligence and qualification

• Trade-compliance terms in supply and distribution agreements

• Section 301 exclusion strategy and country-of-origin restructuring

We advise strategic and financial buyers, sellers, and investors on trade-regulatory aspects of mergers, acquisitions, financings, and joint ventures, including diligence, risk allocation, post-closing integration, and coordination with CFIUS counsel.

Areas of work:

• Customs, export controls, and sanctions diligence

• Acquisition-driven voluntary self-disclosures

• Risk allocation in transaction documents

• License transfer, reissuance, and DDTC registration changes

• OISP and CFIUS assessments

• Post-closing integration and remediation

• Coordination with CFIUS counsel

• Investor diligence on trade-regulatory exposure

We represent clients before U.S. Customs and Border Protection, the Bureau of Industry and Security, the Directorate of Defense Trade Controls, the Office of Foreign Assets Control, and the U.S. Department of Justice, in administrative proceedings, settlement negotiations, and litigation.

Areas of work:

• CBP audits, penalty proceedings, and seizure cases

• BIS administrative enforcement and charging letters

• DDTC consent agreements and administrative proceedings

• OFAC pre-penalty notices and enforcement matters

• DOJ criminal and civil enforcement, including parallel proceedings

• Court of International Trade and federal court litigation

We assess and build corporate compliance programs aligned with current DOJ guidance, including anti-bribery and anti-corruption policies under the Foreign Corrupt Practices Act (FCPA) and analogous international regimes.

Areas of work:

• Compliance program assessment and benchmarking against DOJ guidance

• Codes of conduct and anti-bribery / anti-corruption policies

• Gifts, hospitality, and political-activity policies

• Internal investigations and self-disclosure analysis

• Vendor and third-party due diligence

• M&A successor-liability assessments

• Compliance training