Experience


Representation in all aspects of US Customs and Border Protection (CBP) law, and related international trade regulation, pertaining to importing and exporting, involving both goods and services.  Mr. Sullivan has been engaged by clients for a complete range of services and proceedings – from advisory consultation for clients just beginning to import or export to representation of the most sophisticated multinational clients in judicial proceedings in the U.S. Court of International Trade.

Areas of concentrated expertise include:

  • Representation in CBP penalty and liquidated damage proceedings, with the perspective and experience of a former Customs investigator; up to and including judicial proceedings. This has included matters with potential criminal implications.
  • Representation in Compliance Assessments and Audits covering the full range of CBP compliance issues, with the experience and expertise of a former Customs official
  • Representation at all stages of differences with CBP pertaining to issues of tariff classification and customs valuation and appraisement, particularly valuation issues involving related party transactions. This includes obtaining CBP Headquarters ruling, both prospective and internal advice requests, as well as representation in Court of International Trade.
  • Advice and counsel with respect to NAFTA, GSP, trade agreements and other trade preference provisions.
  • Advice and counsel regarding country of origin and marking requirements.
  • Full range of services pertaining to establishment of US based distribution facilities; and qualifications to become importers of record, including non-resident companies and individuals.
  • Establishment of Foreign Trade Zones, subzones and modifications and alterations to existing zone operations.
  • Counsel regarding duty savings and duty deferral programs involving the use of trade zones, bonded warehouses, temporary importations; and, advice on maintaining customs compliant inventory and record-keeping systems.
  • Defense of Foreign Corrupt Practices Act alleged violations; and, establishment and implementation of FCPA compliance programs
  • Advice on trade remedy proceeding, particularly antidumping and countervailing duty cases and issues.
  • Advice concerning the licensing of exports under Departments of Commerce, State and Defense statutes and regulations. Counsel and advocacy regarding the administration of sanctions regulations, including defense of OFAC penalties.
  • General advice and counsel pertaining to contractual aspects of international shipment of goods and distribution.