Trade Remedy and Defence

When anti-dumping or countervailing duty petitions threaten market access, Sarah Mitchell represents respondents in proceedings before the US Department of Commerce and the International Trade Commission. Her experience includes preparing Section A and Section B questionnaires, responding to verification requests, and developing non-injury and public interest arguments. She also advises Chinese exporters on the separate-rate certification process required to obtain individually calculated duty rates in administrative reviews.

Beyond defensive work, Sarah helps clients structure their operations to minimise trade remedy exposure. This includes entity and product scope planning, jurisdiction selection for new manufacturing facilities, and supply chain documentation practices that withstand Commerce Department scrutiny.

• ⚖️ Section 301 and Section 232 exclusion request strategy and monitoring
• 📜 Anti-dumping and countervailing duty proceeding representation
• 🛡️ Customs valuation and transfer pricing alignment for related-party transactions
• 💼 Forced labour detention risk assessment and supply chain due diligence

Customs Compliance and Enforcement

US Customs and Border Protection has intensified enforcement across multiple fronts. Sarah Mitchell assists importers with prior disclosure filings when classification or valuation errors are discovered, manages penalty mitigation proceedings, and conducts internal compliance audits to identify and correct systemic issues before they escalate to formal investigations. She also represents clients in CBP Headquarters ruling requests and protests challenging adverse determinations.

For companies operating in the e-commerce and direct-to-consumer space, Sarah advises on de minimis entry strategies, Section 321 low-value shipment compliance, and the evolving duty treatment of goods shipped through cross-border e-commerce platforms. The rapid growth of small-package imports has created new compliance risks that her practice addresses through tailored training programs and documented standard operating procedures.

Export Controls and Sanctions

Sarah Mitchell counsels clients on compliance with the Export Administration Regulations, including entity list screening, licence review for dual-use items, and deemed export considerations for foreign national employees working with controlled technology. Her sanctions practice covers OFAC compliance, including SDN list screening, country-specific sanctions programmes, and voluntary self-disclosure strategy when potential violations are identified.

Export control due diligence is not a one-time assessment but a continuous compliance obligation that must be embedded in company-wide trade compliance programmes.

Washington DC Practice Context

Based in Washington DC, Sarah Mitchell maintains close working relationships with trade officials at USTR, Commerce, and CBP, enabling her to provide clients with real-time insight into policy developments and enforcement trends. The DC location also allows her to participate directly in the administrative rulemaking process, submitting comments on proposed regulations and advocating for client interests before federal agencies. Her practice includes monitoring legislative developments affecting trade policy, including renewal of trade promotion authority and proposed changes to de minimis treatment under Section 321.

Professional Standards

Sarah Mitchell structures engagements around clear written scopes that specify the regulatory framework, anticipated timeline, and deliverables for each matter. Fee arrangements and confidentiality boundaries are confirmed before substantive work begins. Clients receive periodic status updates with identified decision points and risk assessments. All customs and trade advice is documented with reference to the specific regulatory provisions, ruling letters, or judicial precedents on which it relies.

Supply Chain Documentation and Trade Compliance Programmes

Effective trade compliance requires documented procedures that govern how goods are classified, valued, and documented throughout the supply chain. Sarah Mitchell helps clients develop internal compliance manuals that address tariff classification decision trees, valuation methodology selection, country of origin determination, and record-keeping requirements. These programmes are tailored to each client's specific product portfolio, trade volumes, and risk profile, ensuring that the compliance burden is proportionate to the commercial activity.

She also conducts training sessions for client procurement, logistics, and finance teams on the practical application of customs rules, covering topics such as the correct completion of CBP Form 7501 entry summaries, the documentation needed to support preferential duty claims, and the identification of red flags that may trigger CBP enforcement action. Training is delivered in both English and Mandarin to ensure that teams in China and the US operate from the same compliance baseline.

Client Engagement Approach

Sarah Mitchell structures engagements to address the specific regulatory exposure of each client's supply chain. Initial assessments include a review of current classification and valuation practices, an analysis of recent CBP enforcement trends applicable to the client's industry sector, and a prioritised action plan for addressing identified compliance gaps. Fee arrangements are based on the scope of work agreed at the outset, with fixed fees for defined projects and ongoing retainer arrangements for continuing compliance support.