Laura Siegel Rabinowitz

• Represented one of the world’s largest investment banks and importer of commodities in a successful U.S. Customs and Border Protection audit. The audit covered classification, country of origin, and related party valuation of the imported commodities.°
• Represent a global manufacturer and world leader in the design and production of valves and steam traps and supplier to the U.S. federal government in an investigation by U.S. Customs since April 2018. The investigation covers the past five years and focusses on the verification of the company’s NAFTA entries, classification of its merchandise, including valves and valve parts, whether this is a bona fide sale between the Canadian parent and U.S. subsidiary, and whether the transfer price is acceptable to U.S. Customs. To date we have defended the company against the issuance of any penalty. The investigation is ongoing.
• Serves as outside trade counsel to a leading consumer products company in its ongoing audit with U.S. Customs.
• Serves as outside trade counsel for the global leader of consumer products. We have reviewed the company’s imported merchandise, including bicycles and accessories, for trade compliance covering classification, valuation, and country of origin. Adding to the complexity of this project, the company imports into a foreign trade zone before shipping out the products to its retailers.
• Following a determination of numerous errors from GT’s review, we filed several prior disclosures with US Customs and Border Protection (“CBP”) and are working with the company on corrective measures. CBP will eventually audit the company, reviewing all issues and samples of entries. The company has already paid $3.5m in back owing duty.
• We determined that the country of origin of the pressure washer was Vietnam rather than China and received a ruling from U.S. Customs on this issue. Accordingly, the company is avoiding the Section 301 duties on Chinese products.
• Represents multiple global and national apparel and footwear retailers in the set-up of the duty savings strategy “first sale” for numerous vendors saving the companies many millions per year.
• As the company’s longtime outside trade counsel and supply chain advisor to a national apparel retailer, we drafted the company’s master Purchase Agreement, Supplier Code of Conduct (including supplier’s responsibility regarding ESG, forced labor and potential detentions, the environment, worker rights, import regulations, Foreign Corrupt Practices Act, Confidential data, Insurance, arbitration, and termination of the agreement), Restricted Substances Policy (outlining the growing regulations covering restricted chemicals in apparel and accessories), Chargeback Policy (for late or poor quality goods), and edited Intertek’s Testing Compliance Manual. We have also been involved in the negotiations with the company’s numerous suppliers over the above-named documents. 
• Represented the leading global luxury conglomerate in importing a food product for the first time from France to the United States and advised the company on regulations surrounding the importation of food including the classification, valuation, and country of origin of the merchandise. The company has successfully imported the product.
• Represents an underwriter of photovoltaic solar electricity generation projects, on trade issues surrounding the importation of solar modules. For each new generation project we counsel the client on supply chain issues and edit its Master Supply Agreement. The issues we advise on are wide-ranging and include force majeure provisions, Section 301 duties, Section 201 duties on imports of solar products, and anti-dumping duties on solar products from China. We also counsel the client on the ongoing Department of Commerce circumvention investigation into solar products being imported from five countries including Vietnam, Thailand and Malaysia, and the enforcement of the Uyghur Forced Labor Prevention Act.
• Represents numerous companies in the ongoing Section 301 litigation which is currently under appeal at the Court of Appeals for the Federal Circuit. The companies are claiming that the Trump administration exceeded its executive authority in the promulgation of Lists 3 and 4A covering over $300 billion worth of merchandise. After a likely appeal to the U.S. Supreme Court, and should plaintiffs prevail, U.S. Customs would be ordered to refund the Section 301 duties.
• Represented a U.S. apparel retailer in the detention of several shipments on claims of forced labor. by U.S. Customs. We worked with the Vietnamese manufacturer to collect “traceability documents” into the shipments supply chain. 
• Represented a private stainless-steel company with an annual output of approximately 200,000 tons of specialty steels. We have submitted a number of petitions to mitigate liquidated damages/penalties and responses to Notices of Action by U.S. Customs and have been successful in the mitigation of all penalties.
• Represented a private equity fund which bought the assets of a well know flooring company. We put in place a drawback program so that the company can recover import duties paid for shipments subsequently exported to Canada.
• Serves as outside trade counsel for a leading provider of ergonomic products for corporate and hospitality industries. We routinely advise on navigating the Section 301 duties on products of China and the classification and country of origin determinations of imported merchandise (including the company’s sit-stand workstation). We also advise on supply chain strategies including navigating the US-China relationship, moving some production to Mexico, USMCA compliance, and the use of bonded warehouses, foreign trade zones, and duty drawback.
• Advised a globally recognized leading furniture brand in the classification of one of their products and succeeded in saving the company $4.5 million per year.
• For a $2.6 billion provider of juvenile, sports, and home products, we advise the company on duty mitigation strategies including the use of “first sale” to reduce the valuation of its imported products.
• Serves as outside trade counsel for a multibillion-dollar food company with over 50 brands. We advise on the import and export of food products, raw materials, and other ingredients including dealing with CBP and its partner government agencies, FDA, USDA, and APHIS and periodic “holds” on inbound shipments. As outside trade counsel for a multibillion- dollar food company, we successfully determining that the company was owed a duty refund on the basis that the imported products qualify as either “U.S. goods returned” or under NAFTA and navigated the duty refund process with U.S. Customs.
• Represented a multinational manufacturer of respiratory masks on the setup of its drawback program and continue to counsel on the implementation of the program. In this case, the company imported respiratory masks from China and is exporting a significant portion out of the United States. The Company has received over $200 million in refunds.
• Represented one of the largest grocery store retailers, on trade issues involving its importations into the United States. Issues include anti-dumping orders on food and other retail items and the implementation of the Uyghur Forced Labor Prevention Act (UFLPA).
• Represented the trade association representing catcher processor vessels in the federally managed fisheries off Alaska before the U.S. Trade Representative and to gain approval on Section 301 exclusion requests.
• Represented one of the largest suppliers of pools and pool parts in the United States and after successfully petitioning the U.S. Trade Representative for Section 301 exclusion approvals, we managed the refund process with U.S. Customs.
• In light of UFLPA which prevents the importation of solar cells from Xinjiang made with forced labor, we worked with the client to add language to its master service agreement to protect the company financially.
• Represented a major importer and exporter of hand sanitizer and masks and set up the company’s drawback program so that the company has recovered almost $200 million in paid duties.
• Represented a logistics and supply chain company in its audit by the FDA for importations of FDA regulated products.
• Advised a major importer of natural gas on the U.S.-Mexico-Canada Agreement.
• Advised numerous importers on Uyghur Forced Labor Prevention Act compliance, including mapping supply chains and editing purchase agreements, supplier codes of conduct, and other supplier agreements.
• Advised a leading importer on navigating the refund process on products subject to Section 301 exclusions, including counselling the company on the importation of several PPE products as U.S. Customs modified how those products were classified and whether they qualified for exclusions from the Section 301 tariffs.
• Represented a public company in several prior disclosures before the U.S. Department of Commerce and U.S. Customs and Border Protection on the parameters of scope rulings.°
• Represented a major health and beauty company on a detention of its merchandise in violation of FDA regulations.°
• Represented a large public company and importer of textbooks and other educational materials in a compliance review and the filing of prior disclosures with the U.S. Customs and Border Protection on the undervaluation of its merchandise.°

°The above representations were handled by Ms. Rabinowitz prior to her joining Greenberg Traurig, LLP.

• Attorney, U.S. Customs Service, Assistant Chief Counsel’s Office, 1992-1996

• Shortlisted, Euromoney, Americas Women in Business Law Awards, "Best in International Trade," 2023
• Listed, Chambers Global, “International Trade: Customs,” 2021-2025
• Listed, Chambers USA Guide, “International Trade: Customs,” 2017-2024
• Listed, Thomson Reuters, “Stand-Out Lawyers,” 2023-2024

• Member, American Association of Exporters and Importers
  • Chair, Textiles, Apparel, and Footwear Committee
• Advisory Board, Retailers United
• Member, Organization of Women in International Trade
  • Past President, New York Chapter
• Member, American Bar Association
  • Member, International Trade Section
• Member, Customs and International Trade Bar Association
• Member, U.S. Fashion Industry Association
• Member, Brazilian – American Chamber of Commerce, Trade & Business Investment Committee
• Member, European – American Chamber of Commerce, Trade Working Group