Michelle Rosario

With a varied background in international trade, Michelle is adept at navigating complex regulations impacting the execution of commercial transactions and global trade. Specifically, she has experience advising clients on trade matters relating to tariff classification, foreign acquisitions, antidumping and countervailing duties, as well as the export of controlled technologies. 

Export Controls

Michelle has experience assisting clients engaging in the export of items subject to regulation by the Bureau of Industry and Security (BIS) under the EAR, the Department of State under the ITAR, as well as regulations administered by the Office of Foreign Assets Control (OFAC).

To ensure businesses are compliant with export control regulations, Michelle is steadfast in drafting trade compliance programs and classifying items that may be subject to an export license under the U.S. Munitions List or the Commerce Control List, as well as determining the licensing requirements of specialized items with military or critical applications.

Import Regulations and Trade Remedies

Michelle is skilled in various matters related to the import of goods into the U.S. such as the tariff classification of items for duty calculation purposes, the drafting of short supply petitions under the Central America-Dominican Republic Free Trade Agreement (CAFTA-DR), as well as the import of items subject to regulations administered by the Bureau of Alcohol, Tobacco, Firearms, and Explosives. She also has experience representing clients in a variety of actions impacted by Section 232 and 301 tariffs.

Michelle also has experience in proceedings related to antidumping and countervailing duties (AD/CVD). From filing initial petitions before the International Trade Commission and the U.S. Department of Commerce to representing clients involved in sunset review proceedings, Michelle is determined to ensure her client’s interest is a priority.

Sanctions and Supply Chain Issues

As it relates to sanctions, Michelle has extensive experience screening for prohibited parties in a vast range of business transactions. She also provides pointed guidance regarding navigation of complicated sanctions programs such as those related to Russia. Within matters related to supply chain, Michelle advises business on compliance with the Uyghur Forced Labor Prevention Act (UFLPA) and addresses sourcing concerns as it relates to sanctioned entities or persons.

CFIUS

Where foreign acquisitions are concerned, Michelle has experience determining whether a particular agreement is subject to review by the Committee on Foreign Investment in the United States (CFIUS), as well working with domestic and international parties for submission of notices to CFIUS.

Prior to joining Barnes & Thornburg as a licensed attorney, Michelle served as a summer associate and law clerk to the firm’s International Trade Practice Group. During her time in law school, Michelle gained experience as an intern for the Honorable Rudolph Contreras in the U.S. District Court for the District of Columbia and the International Trade Administration of the Department of Commerce.