Mr. Huffman has experience advising US and non-US clients before a variety of agencies with regulatory authority over exports, including the Bureau of Industry and Security (BIS) of the Department of Commerce, the Directorate of Defense Trade Controls (DDTC) of the Department of State, and the Office of Foreign Assets Control (OFAC) of the Department of Treasury. Mr. Huffman’s export controls includes work regarding the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR). Mr. Huffman has experience drafting and implementing tailored compliance programs, including leading related trainings, and assisting clients with internal audits and investigations related to sanctions and export control laws. His practice also includes drafting license applications, ruling requests, protests, commodity jurisdiction and classification requests, and advisory opinion requests.
Mr. Huffman also represents both US and non-US clients in import compliance and relief proceedings in the United States. His practice includes a range of customs issues, including classifications, country of origin marking, protests, customs audits and developing import compliance programs before the US Customs and Border Protection Agency (CBP). He has experience with antidumping and countervailing duty proceedings before the US Department of Commerce and the International Trade Commission (ITC), as well as appeals before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit.
Mr. Huffman represents an association on trade policy issues and has been active in free trade negotiations, including the TPP, as well as various trade preference initiatives, such as the Generalized System of Preferences (GSP) and Miscellaneous Tariff Bills (MTB).
Examples of recent engagements include:
- Counseling a variety of US and non-US companies regarding compliance with US sanctions laws, including OFAC’s General License H of US Iran Sanctions and Cuba sanctions regulations;
- Assisting a client with software export/re-export rules, including de minimis analysis of software with controlled encryption;
- Representing clients in antidumping duty cost and countervailing duty verifications by the US Department of Commerce;
- Auditing the export compliance of a security service defense contractor;
- Leading an internal investigation, including drafting and submitting a disclosure, regarding violations of the EAR and OFAC Regulations;
- Advising a client on the importation of antique firearms pursuant to regulations administered by the Bureau of Alcohol, Tobacco & Firearms (ATF);
- Creating a compliance program for a technology company for shipping products containing lithium ion batteries with the international shipment of dangerous goods pursuant to regulations administered by the Department of Transportation (DOT); and
- Counseling clients on the applicability of certain Trans-Pacific Partnership (TPP) provisions.