Representative Assignments:
International Trade and Customs Compliance
- Successful Challenge before the Department of Commerce related to Short Supply Certificate under CAFTA based on origin determination that no shortage existed.
- Voluntary disclosure in Korea, Japan, Peoples Republic of China and Taiwan relating to undervaluation of spare parts resulting from audit of internal records. At the time there were no procedures for voluntary disclosure. Successfully negotiated a non criminal outcome for the company. Subsequently implemented training and procedures including company code of conduct
- Created and implemented an determination of Origin policy and template to accurately determine origin on electronic parts.
- Harmonized Tariff Code determinations for both US and EU reconciling the appropriate HTS classifications.
- Created a policy and template to determine if goods met the requirements of the Buy American Act and the American Resource and Recovery Act
- Defended company against valuation matters related to intercompany pricing.
- Develop processes and procedures for importation into Russia and the middle east
- Applicability of CIFIUS and voluntary filing requirements in merger and acquisition
Anti-bribery and Anti-Boycott
- Develop and implement FCPA and UK Bribery Act policy, as well as local corruption implications in 10 countries. Conducted internal audit and investigation in EU, Asia Mexico and Middle East into alleged corruption allegations.
- Responsible for compliance with US Anti-boycott laws including issues related the Letter of Credit and the Arab boycott law.
- Compliance issues related with cross border transportation of goods on an undeclared basis in Asia
- Develop and implement a company code of conduct and online code of conduct training
ITAR and CIFIUS
- Commodity Jurisdiction analysis and filings
- Develop and implement and Export Control Plan
Risk Management
Develop an enterprise risk based compliance plan, including clear tangible set of policies, communication and training, and ongoing monitoring response program. Board Governance
- Work with board to asses board makeup and strategy
- Develop on boarding programs
- Develop board Education programs
- Develop board assessment and evaluation programs.
- Work with board to provide current assessments of best practice and evolution in board responsibilities