Development of Internal Trade Law Compliance Programs

It is a fundamental goal of our practice to help importers, exporters, freight forwarders, Customhouse Brokers, and others involved in international trade to prevent avoidable and unwanted entanglements with the federal agencies that regulate international trade.  Risk reduction in this area is possible through review or development of internal compliance programs designed to anticipate legal requirements, challenges, and risks.  This attention to risk management can also include a review of current practice to facilitate improvement and correction of deficit procedures.  When appropriate, we assist disclosure of past errors to minimize the impact of any discovery by agency or enforcement action.

Import Compliance Program Development

Compliance development in the context of import regulations typically requires advance attention to the classification of merchandise, the import valuation, and the determination and confirmation of the declared country of origin.  Where applicable, we review the application of any trade benefits programs such as free trade agreements, GSP, and Chapter 98 provisions.  Our assistance also extends to the use of bonded warehouses, foreign trade zones, and the refund of import duty. 

For clients committed to import compliance, we assist with internal audits, compliance development, and assistance through the Importer Self-Assessment and Trusted Trader certification.

Export Control Compliance Program Development

Compliance development in the context of export controls requires commodity review with attention to ECCN and ITAR classification, knowledge and documentation concerning the end use and end user, screening through various regulatory lists, and safeguards against illegal transshipment.  When appropriate, we help clients with Voluntary Self Disclosures or other actions designed to minimize penalties and other enforcement actions before or after they are initiated.