Dave represents U.S. and foreign companies, including manufacturers, importers, exporters, distributors, customs brokers, freight forwarders, and trade associations on customs/import and export matters. His client work covers the wide range of laws and policies administered and enforced by the Customs and Border Protection (CBP), Immigration and Customs Enforcement (ICE), and foreign customs authorities, which include the following: duty preference programs such as the North American Free Trade Agreement (NAFTA) and Generalized System of Preferences (GSP); tariff classification; customs valuation and transfer pricing; entry procedures; customs brokerage; country of origin marking; intellectual property rights enforcement, drawback; customs bonds, foreign trade zones, and border security (e.g., the Customs-Trade Partnership Against Terrorism (C-TPAT)). Dave also has represented importers in defending against customs civil and criminal penalties, including seizures and forfeitures, conducting and managed internal investigations, and preparing customs prior disclosures.
Dave’s specialties include 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 service team at Arent Fox that focuses on the NAFTA automotive rules. Dave has represented U.S., Canadian and Mexican importers, manufacturers and exporters during NAFTA verifications conducted by United States, Canadian and Mexican Customs officials, including companies in the automotive, food and beverage, agricultural, chemical, pharmaceutical, electronics, specialty metals, oilfield equipment, and petroleum sectors.
Dave also 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 practice also includes representation of clients in other international trade areas, such as market access, World Trade Organization-related matters, bilateral, multilateral and regional trade agreements, anti-corruption, foreign corrupt practices, anti-boycott, Section 201, Section 301, and other import relief actions.