Dave's practice focuses on advising clients on international trade regulatory, including import and customs compliance, duty preference programs, in particular, the United States Mexico Canada Free Trade Agreement or USMCA. In addition, Dave provides legal and strategic advice regarding the implications of US economic sanctions and export controls.
Dave represents US and foreign companies, including manufacturers, importers, exporters, distributors, and trade associations on trade matters before the US Department of Treasury, US Customs and Border Protection (CBP), Alcohol and Tobacco Tariff and Trade Bureau (TTB). On customs issues, Dave specializes in duty preference programs, such as the USMCA; duty deferral programs, including drawback and FTZs; customs valuation and transfer pricing; country of origin marking; and intellectual property rights enforcement. Dave has represented importers in defending against customs civil and criminal penalties, including seizures and forfeitures, conducting and managing internal investigations, and preparing customs prior disclosures.
Dave’s portfolio also includes assisting companies with customs audits (known as focused assessments) and importer self-assessments. He has developed tailored customs risk management strategies, import compliance procedures, and special duty and free trade qualification programs for clients.
Dave also leads a dynamic and tailored service team at ArentFox Schiff that advises companies on the USMCA automotive rules, including critical rules of origin provisions and the new labor value content calculations. Dave has represented US and international companies as well as their diverse supply and customer partners when appropriate.
Dave’s practice also includes advising alcohol beverage companies on import and regulatory requirements administered and enforced by CBP and TTB.
Dave advises companies on export controls and economic sanctions issues. His work in this area has included performing internal investigations, drafting voluntary disclosures, responding to administrative subpoenas, developing and implementing export compliance programs, and providing ongoing export compliance advice.
Dave’s recent practice also includes representation of clients in other international trade areas, such as the imposition of steel and aluminum tariffs under section 232 of the Tract Act of 1962 and the proposed tariffs on Chinese imports under section 301 of the Trade Act of 1974.
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