Luis F. Arandia, Jr.

Specifically, Luis represents importers and exporters before federal agencies that administer international trade regulations, including U.S. Customs and Border Protection (CBP), the Bureau of Industry and Security (BIS), the Census Bureau, the U.S. Directorate of Defense Trade Controls (DDTC), and the Office of Foreign Assets Control (OFAC). He also advocates for clients under agency enforcement, whether in the context of investigations, penalties, or voluntary disclosures.

Imports

Luis has deep experience in a wide range of substantive customs issues, including tariff classification, country of origin marking, customs valuation, free trade agreements and tariff preference programs under the United States-Mexico-Canada Agreement (USMCA/NAFTA), counterfeits and border enforcement of IP rights, and trade remedy (antidumping and countervailing) duties. He also advises clients on special tariff actions, including Section 301 China tariffs, Section 232 steel and aluminum tariffs, and Section 201 safeguards. 

He has experience with prior disclosures, protests, penalty and seizure petitions, compliance audits, enforcement actions before CBP, as well as trade litigation before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit. He assists clients in developing and implementing effective compliance programs to help ensure that reasonable care is exercised over import matters.

In the course of his career, Luis has achieved over $1 million in Section 301 exclusion refunds for consumer products clients, and he is also well versed on the application Section 232 tariffs.

Exports and Economic Sanctions

Where export matters are concerned, Luis assists clients in navigating the U.S. export control laws, including the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), regulations administered by OFAC, the Foreign Trade Regulations, and the anti-boycott requirements administered by the U.S. Department of Commerce.

Luis advises clients on export control enforcement actions and sanctions risk assessments. Additionally, he conducts internal investigations, handles voluntary self-disclosures, and designs and implements trade controls compliance programs. With practicality and creativity, Luis is adept in Export Control Classification Number (ECCN) classification of products and technology in various industries, including aerospace, electronics, oil and gas, and medical devices.

He has managed and prepared multiple voluntary self-disclosures for aerospace and industrial clients before BIS and DDTC, resulting in no penalties. And he has advised and prepared license and classification requests concerning BIS encryption controls for software and mobile app products. 

In terms of economic sanctions, Luis analyzes and advises on OFAC regulations in connection to Iran, Russia, the Ukraine, and Venezuela, as well as to anti-boycott regulations for various industrial clients.

Further, Luis is a member of the team assisting the Special Compliance Coordinator appointed by the U.S. Department of Commerce to monitor, assess and report on the U.S. export control compliance of Zhongxing Telecommunications Equipment Corporation, of Shenzhen, China, and ZTE Kangxun Telecommunications Ltd. Of Hi-New Shenzhen, China (collectively, ZTE).