Raymond Sullivan

With more than 30 years of practice in Customs law, international trade regulation and export control law, Mr. Sullivan has extensive experience in conducting compliance audits and investigations and has formulated compliance plans that incorporate Foreign Corrupt Practices Act compliance issues; and both import and export transactional issues for global and multinational clients.

Mr. Sullivan's practice encompasses customs penalties, seizures and other enforcement activities as well as classification and valuation of imported merchandise, including litigation of these issues in the U.S. Court of International Trade.  He represents clients in pre-audit reviews, audits and compliance assessments by the U.S. Customs Service. Mr. Sullivan regularly conducts evaluations of importer's entry systems and U.S. Customs clearance and duty payment processes with a focus on Customs duty assessment laws and effective duty savings within the Customs regulatory framework, and global, regional and bilateral trade preference agreements.

Mr. Sullivan has represented many clients engaged in global trade with multiple cross-border transactional issues; and, clients with multinational manufacturing facilities.  He has represented clients in the establishment of foreign trade zone assembly operations, including Foreign Trade Zone Board approvals establishing the zone operation, and subsequent modifications to the zone facility.  Additionally, he has represented clients establishing import operations in the U.S. and facilitated exporters to the U.S. in becoming U.S. importers of record while not being physically located in the U.S.

Mr. Sullivan has been actively engaged with importers and exporters in issues related to homeland security measures, both those measures required by regulatory authorities, as well as engaging in pro-active business practices to facilitate efficient and compliant logistical management designed to anticipate potential problems and to provide solutions combining legal compliance and sound business acumen.

His practice also includes export trade regulatory matters, including the export licensing process involving sensitive materials and destinations.  Mr. Sullivan has drafted and implemented comprehensive export compliance plans with an emphasis on compliance with U.S. government sanctions, as administered by the Office of Foreign Assets Control, against countries, and entities and individuals, as well as their integration and overlap with anti-money laundering measures required by the Patriot Act. He has also secured Commerce and State Department approvals and OFAC licenses on behalf of clients for various cutting edge technologies, specifically in the area of encryption.

Before entering private practice, Mr. Sullivan worked for the U.S. Customs Service as an Import Specialist and Special Agent engaged in criminal and civil customs fraud and revenue enforcement investigations.

Publications & Speaking Engagements

  • Author – "Myanmar: Land Of Opportunity?" International Law360, December 16, 2011
  • Author – "New Directions In Customs Valuation," Law360, November 16, 2011
  • Author – "Bringing Customs Back Into Revenue Enforcement," Law360, October 21, 2011
  • Author – "Blurring The Boundaries Of Border Search Authority," Law360, September 16, 2011
  • Author – "Were Smoot And Hawley Visionaries?" Law360, July 13, 2011
  • Author – "Ethics And Compliance — A Necessary Pair," Law360, April 12, 2011
  • Author – "How ICE Could Chill Export Enforcement," Law360, February 3, 2011
  • Author – "More Ammunition To Kill The 'First Sale Rule'?" Law360,  January 21, 2010
  • Author – "Customs Revenue Fraud Enforcement: Any Such Thing?" Law360, November 18, 2009
  • Author – "The Shift in FCPA Enforcement Targeting," Law360, September 28, 2009 
  • Speaker – "Foreign Corrupt Practices Act Enforcement: Solutions for Small Companies Targeted,"  Baltimore Customs Brokers and Forwarders Association, August 26, 2009
  • Speaker – "Export Controls Update," New Orleans World Trade Center, March 6, 2009
  • Author – "Year End Review of Export Control Regulatory Changes and Proposed Changes," Baker Donelson Alert, January 28, 2009; also published by Mondaq as "United States: Year End Review of Export Control Issues," February 20, 2009  

Professional Honors & Activities

  • AV® Preeminent™ Peer Review Rated by Martindale-Hubbell
  • Law360's International Trade Editorial Advisory Board, 2010
  • Member – American Bar Association (Section on International Law)
  • Member – Maryland State Bar (Past Chairman and Past President, Section on International Commercial Law)
  • Member – New York and Washington, D.C. Bar Associations


  • District of Columbia
  • New York
  • Maryland
  • U.S. Court of Appeals for the Federal Circuit
  • U.S. Court of International Trade


  • University of Maryland School of Law, J.D., 1976
  • University of Maryland, B.A., 1970, cum laude