Miriam provides advice with respect to U.S. antiboycott laws and assistance in preparing antiboycott reports. She has been the principal antiboycott counsel for several clients with operations in the Middle East.
With respect to U.S. customs laws, Miriam represents clients in pre-audit reviews, internal audits, and Focused Assessments conducted by U.S. Customs and Border Protection. She also evaluates the dutiability of royalties and other payments to foreign suppliers; determines country-of-origin marking requirements and the tariff classification of imported merchandise; handles prior disclosures, duty tenders, and protests; and assists companies in developing compliance programs. Additionally, Miriam assists companies in qualifying their goods under free trade agreements and the Generalize System of Preferences (GSP) and dealing with issues related to GSP, Foreign Trade Zones, and duty drawback. Miriam also litigates contested customs issues at the U.S. Court of International Trade.
With respect to U.S. export controls, Miriam provides advice and assistance with respect to the Export Administration Regulations (EAR) administered by the Commerce Department, the International Traffic in Arms Regulations (ITAR) administered by the State Department, and Foreign Trade Regulations administered by Commerce and the Bureau of Census and handles questions that arise under the NISPOM involving the proper handling of classified information and the mitigation of foreign ownership, control, and influence (FOCI). She assists clients in determining the licensing requirements and controls applicable to products, technology, and software and assessing the availability of license exceptions. She also files classification requests and license applications. In addition, Miriam supervises internal investigations and prepares voluntary self-disclosures where appropriate and represents clients in investigations by agency enforcement personnel and the Department of Justice.
Miriam also has broad experience with U.S. trade sanctions issues and has worked with the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) on licensing issues. She advises major insurance and re-insurance companies, insurance brokers, investment funds, and multinational corporations with respect to potential U.S. trade sanctions issues raised by proposed transactions; routinely obtains licenses for the sale of agricultural goods and medical devices and other transactions; conducts due diligence for proposed transactions and assesses OFAC risk; and reviews and revises proposed OFAC representations, warranties, and other provisions in various types of agreements. In addition, Miriam assists clients in preparing voluntary disclosures, responding to subpoenas, and in OFAC investigations, audits, and compliance reviews.
Miriam has been involved in a number of trade remedy proceedings, including antidumping, countervailing duty, and Section 201 (Safeguard) investigations, as well as sunset reviews, scope inquiries, and anti-circumvention proceedings.
Miriam has experience with companies in a wide range of industries, including auto parts, chemicals, consumer electronics, hand tools, insurance and re-insurance, industrial equipment, motor vehicles, and steel.