Dave Townsend

EXPORT CONTROLS AND SANCTIONS

• Regularly submits export licenses and classifications requests, including for encryption items.
• Advises clients on voluntary self-disclosures to and enforcement actions by the Commerce Department Bureau of Industry and Security (BIS), the Department of Treasury Office of Foreign Assets Control (OFAC), and the State Department Directorate of Defense Trade Controls (DDTC).
• Drafts and assists with implementation of compliance programs relating to U.S. export controls and sanctions.
• Assists with due diligence arising in mergers and acquisitions, including negotiation of post-closing measures relating to trade liability.

U.S. CUSTOMS

• Counsels clients on import entry, classification, valuation, marking and the rules of origin.
• Advises on prior self-disclosures to U.S. Customs and Border Protection (CBP).
• Analyzes eligibility of imports for lower tariff rates under U.S. free trade agreements and preferential tariff programs.

SECTION 232 AND 301 MATTERS

• Drafts comments to the Bureau of Industry and Security (BIS) and Office of the U.S. Trade Representative (USTR) on proposed tariffs under sections 232 and 301.
• Advises on exclusion requests to BIS and USTR.
• Reviews harmonized tariff schedule and country-of-origin for imports to determine applicability of tariffs under sections 232 and 301.

CFIUS REVIEWS

• Advises on necessity of making mandatory or voluntary disclosures to CFIUS, including identifying U.S. operations involving critical technologies, critical infrastructure, sensitive personal data, and sensitive real estate.
• Represents both sellers and buyers in cases before CFIUS, including those involving sensitive national security technology.

U.S. ANTI-DUMPING AND COUNTERVAILING DUTY PROCEEDINGS

• CERTAIN ALUMINUM ALLOY SHEET FROM CHINA
  Represented Chinese industry associations in Commerce antidumping proceeding and International Trade Commission injury investigation.
• CERTAIN STEEL NAILS FROM OMAN
  Lowered antidumping duty rate for foreign exporter and mandatory respondent in administrative review.
• CRYSTALLINE SILICON PHOTOVOLTAIC PRODUCTS FROM CHINA AND TAIWAN
  Represented mandatory respondent in Commerce antidumping duty investigation; represented U.S. importer in International Trade Commission injury determination.
• DIAMOND SAWBLADES FROM KOREA
  Successful representation of mandatory respondent in antidumping investigation and Court of International Trade and Federal Circuit appeals of the investigation.
• CERTAIN STEEL NAILS FROM THE UNITED ARAB EMIRATES
  Obtained court-ordered revocation of antidumping duty order with respect to foreign respondent.
• CRYSTALLINE SILICON PHOTOVOLTAIC CELLS, WHETHER OR NOT ASSEMBLED INTO MODULES, FROM CHINA
  Advised U.S. purchaser regarding Commerce and International Trade Commission proceedings.
• OIL COUNTRY TUBULAR GOODS FROM CHINA
  Represented respondent-government before Commerce.
• DIFFUSION-ANNEALED, NICKEL-PLATED FLAT-ROLLED STEEL PRODUCTS FROM JAPAN*
  Advised U.S. purchaser regarding ITC proceedings.
• GLYCINE FROM CHINA
  Represented U.S. petitioner in proceedings before Commerce and International Trade Commission.
• FROZEN WARMWATER SHRIMP FROM CHINA AND VIETNAM
  Represented exporters in proceedings before Commerce.