Rimon

Sandra Lee Bell

Partner

International Trade and Customs Law, Litigation and Alternative Dispute Resolution, Arbitration and Mediation, White Collar and Government Investigations
Washington, D.C.
(202) 558-0407

EDUCATION

Harvard University

John F. Kennedy School of Government

Federal Executive Institute

George Washington National Law Center

J.D.

Howard University

B.A. summa cum laude

PREVIOUS EXPERIENCE

  • DLA Piper, Senior Counsel, Of Counsel
  • U.S. Customs and Border Protection, Deputy Assistant Commissioner, Trade; Executive Director, Regulations and Rulings

    ADMISSIONS

  • District of Columbia
  • State of South Carolina

Sandra Bell represents clients on regulatory procedures relating to customs tariff and import issues including securing and responding to decisions on prospective and current import transactions, international trade policy and regulatory programs, and border security and trade enforcement programs.

Ms. Bell has over three decades of customs, international trade and border security experience at U.S. Customs and Border Protection (CBP) where she held several positions most recently, as Deputy Assistant Commissioner, Office of International Trade (OT) and as Executive Director of Regulations and Rulings, OT. In the aftermath of 9/11, Ms. Bell also served as Acting Deputy Assistant Commissioner, Deputy Assistant Commissioner and Acting Assistant Commissioner for the Office of Regulations and Rulings, where she spearheaded development of programs to improve delivery of services in international trade regulatory programs that enhanced border security and trade enforcement, such as the Customs On line Rulings Search System (CROSS), the online IPR recordation system (IPRS) and the advance electronic transmission of cargo security (Trade Act) and passenger information (APIS). During this crucial time in US history, Ms. Bell led the development of watershed decisions, national policies, regulations, training and outreach programs that effected transition of the agency into a new legal and cultural environment.

Ms. Bell provides key customs law advice to a variety of clients, including major manufacturers and distributors of imported and exported finished goods and raw materials such as lumber, chemicals, textile and apparel/accessories; automotive vehicles and parts; food products and ingredients; software, industrial coating systems, medical supplies, energy products, luxury consumer goods and professional use products. She also assesses corporate customs compliance independently or as part of the firm’s due diligence reviews for mergers and acquisitions transactions. Specific customs areas in which Ms. Bell has provided advice have included: country of origin (determination and labeling); tariff classification; customs valuation; NAFTA/USMCA, other FTAs, and other US duty preference programs; customs drawback; bonds and bonded warehouses, foreign trade zones, customs enforcement and mitigation; import bans such as the US Forced Labor law; intellectual property rights import restrictions, restrictions by other US government agencies.

SELECTED EXPERIENCE

  • Led multi-practice team in providing customs law related advice and representation before Customs and Border Protection for a major Japanese American scientific and medical device company in four different client projects involving customs compliance and prior disclosures, transfer pricing for customs valuation, CTPAT Remediation, and country of origin determinations for customs admissibility and duty purposes.
  • Led International Trade team in representing three different components of a major airline and aircraft industry company in filings and communication involving prior disclosures of multimillion dollar loss of revenue amounts for past violations and appeals of the CBP legal theories for such calculations, successfully resolving all claims to client’s satisfaction.
  • Led International Trade team in representing a major floor covering importer and distributor of multi-layered wood floor covering products, before the US Customs and order Protection (CBP) in connection with possible violations of US customs laws involving tariff classification and allegations of antidumping/countervailing duty (AD/CVD) evasion. As a result of Ms. Bell’s representation and legal arguments, the company was allowed to file a prior disclosure and only pay the loss of revenue, plus interest to resolve the matter, even though the agency already had initiated a formal investigation of the company in connection with these imports.
  • Successfully represented before CBP, a major Chinese technology company importing electrical products into the U.S. in responding to CBP’s detention of client’s products under an ITC exclusion order, and as a result of client’s satisfaction with the service, continued representation of the client in connection with three additional CBP IP detentions and seizures, all of which were resolved favorably for the client.
  • Represented a Fortune 500 Engineering Company in connection with a variety of customs issues stemming from the company’s importation of steel products from China for FTZ manufacturing purposes, valued at over 200 million dollars. Developed and executed successful strategy for addressing numerous document requests (including a summons), from CBP and ICE (criminal investigators at DHS), consolidating all responses and transmitting to CBP and ICE, a comprehensive summary of facts and legal analysis, along with supporting commercial records responsive to each of the agencies’ requests over a period of three months, which addressed CBP’s major concerns with importer’s declared values, tariff classification and applicable duty rates. As a result of Ms. Bell’s representation, the client satisfied the criminal summons without further action by the government on the issues presented.
  • Led multi-practice team in advising a major international producer of networking products in its development of holistic legal and global strategies to address impending new duty liability under the newly announced Section 301 tariffs which covered nearly all of the client’s products manufactured in whole or in part in China. Client was successfully able to navigate its way around or though the tariffs with minimum duty exposures.

PUBLICATIONS

  • Extensions of Russian Sanctions to Certain Imports May Not Allow Importing as Usual, May 10, 2024
  • Senate Bill S. 3431, “Customs Modernization Act of 2023”, may be a vision, but if it becomes law: Importers, Are You Ready?, February 29, 2024
  • A “minor” amendment to the U.S. Customs Broker Regulations has a broad reach: Looking at revised 19 C.F.R. 111.32, 09, March 2023
  • CBP enforcement of the new UFLPA restrictions, 17 July 2022
  • US Department of Homeland Security seeks comments on implementation of Uyghur Forced Labor Prevention Act, 24 January 2022
  • “Meeting the Challenges of Customs Compliance in a post TFTEA and Reinvigorated Trade Enforcement Environment: Go Beyond by Returning to the Basics,” Global Trade and Customs Journal, Volume 7 Issue 3, March 2022
  • “Meeting the Challenges of Customs Compliance in a Post TFTEA and Reinvigorated Trade Enforcement Environment,” Global Trade and Customs Journal, Volume 12 Issue 5, May 2017
  • “The US Prohibition on Imports Made With Forced Labor: The New Law is a ‘Force’ to Be Reckoned With,” Global Trade & Customs Journal, Volume 11, Issue 11 & 12, 2016

SPEAKING ENGAGEMENTS

  • Women in International Trade and Business Empowerment Symposium, Speaker, U.S. Customs and Border Protection (CBP) and the Chicago Federal Executive Board (FEB), June 7, 2024
  • “AI & Emerging Technology in Trade”, Speaker, American Association of Exporters and Importers (AAEI) Webinar, January 18, 2024
  • Prior Disclosures: “Do Brokers Have a Role?”, Panelist, 9th Annual Global Trade Educational Conference, NCBFAA/NEI, July 31, August 2, 2023
  • Provided pro bono training on Special Economic Zones to LLM students in the International Trade and Investment law program at the University of Pretoria in South Africa —  May 2023
  • “Strategies to Minimize Duty Liability”, Panelist, 8th Annual Global Trade Educational Conference, NCBFAA/NEI, August 1-2, 2022
  • Managing the US Customs Process: Obligations and Opportunities,” Lorman, June 2020
  • Speaker, “Duty Drawback, Rules of Origin and Emerging Customs Law Issues,” Case Western Reserve University School of Law, October 2018

MEMBERSHIPS

  • District of Columbia Bar
  • South Carolina Bar
  • US Court of International Trade
  • US Court of Appeals for the Federal Circuit
  • US Supreme Court

AWARDS AND RECOGNITION

  • Recipient, Barbara Williams Lifetime Achievement Award by the Court of International Trade Bar Association
  • Recipient, Meritorious Executive Presidential Rank Award

EDUCATION

Harvard University

John F. Kennedy School of Government

Federal Executive Institute

George Washington National Law Center

J.D.

Howard University

B.A. summa cum laude

PREVIOUS EXPERIENCE

  • DLA Piper, Senior Counsel, Of Counsel
  • U.S. Customs and Border Protection, Deputy Assistant Commissioner, Trade; Executive Director, Regulations and Rulings

    ADMISSIONS

  • District of Columbia
  • State of South Carolina