Sandra Lee BellSenior Counsel
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.
Sandra joined DLA Piper after 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.
Since joining the firm, Ms. Bell has provided 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. Some examples of Ms, Bell's representation of clients at DLA Piper include the following:
- Led DLA Piper multi-practice group 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 matter 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 DLA Piper International Trade practice group 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.
- Led DLA Piper's International Trade practice group in representing a major floor covering importer and distributor focused on floor covering products, before the US Customs and order Protection (CBP) in connection with possible violations of US customs laws involving the misclassification of imports and for antidumping/countervailing duty (AD/CVD) evasion for imports of multi-layered wood flooring products. As a result of this representation, notwithstanding that the CBP already had initiated a formal investigation of the company in connection with these imports, the company was allowed to file a prior disclosure and only pay the loss of revenue amount based upon the legal argument presented by DLA Piper, plus interest to resolve the matter with no additional penalty.
- Successfully represented a major Chinese technology company importing electrical products into the U.S. before U.S. Customs and Border Protection and advice to the company in responding to detention of client's review of facts, licenses, and consulting with licensor of products under the exclusion order in submission provided to agency and in conference call meeting. As a result of this representation, CBP released client's products and client expressed appreciation by its continuation to seek DLA Piper's guidance on three additional CBP 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 valued at over 200 million dollars for manufacturing purposes. Developed and executed successful strategy for addressing numerous document requests from CBP and ICE(including a summons), consolidating all responses and transmitting to CBP and ICE, a comprehensive summary of facts and legal analysis responsive to each of the agencies' request over the immediate past three months, along with supporting commercial records that addressed CBP's major concerns with importer's declared values, tariff classification and applicable duty rates, which resulted in the satisfaction of the criminal summonses without further action by the government on the issues raised in the document request.
- Led DLA Piper multi-practice group 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 recently announced Section 301 tariffs 0on pretty much all of the client's products manufactured in whole or in part in China, under its then business model. Client was successfully able to navigate its way around or though the tariffs with minimum duty exposures, as a result of our advice on the application on use of Customs laws and international trade tools in planning development and movement of the products internationally.
- John F. Kennedy School of Government, Harvard University
- Federal Executive Institute
- J.D., George Washington National Law Center
- Recipient, Barbara Williams Lifetime Achievement Award by the Court of International Trade Bar Association
- Recipient, Meritorious Executive Presidential Rank Award
- Recipient, numerous SES Bonuses and pay increases
- Sandra Bell and Amadi Anene, "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
- "Is it a new day for Jones Act enforcement? Maybe. A practical look at coastwise concerns," DLA Piper Energy Alert, August 9, 2016, selected as an Editor's Choice on DLA Piper's website
- "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
- "Managing the US Customs Process: Obligations and Opportunities," Lorman
- Speaker, "Duty Drawback, Rules of Origin and Emerging Customs Law Issues," Case Western Reserve University School of Law, October 2018
Memberships And Affiliations
- District of Columbia Bar
- South Carolina Bar
- US Court of International Trade
- US Court of Appeals for the Federal Circuit
- US Supreme Court
My latest insights
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9 March 2023 .20 minute read