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Karla M. Cure

Karla Cure focuses her practice on customs laws, US trade remedies, the Committee on Foreign Investment in the United States (CFIUS), export controls, economic sanctions, and related areas of national security and international trade laws.

In the area of customs law and regulation, Karla regularly advises clients on a wide range of customs compliance issues, including tariff classification, country of origin marking, customs valuation, preferential duty treatment eligibility, and forced labor. Karla also advises clients in determining the application of Section 301 and Section 232 tariffs as well as eligibility for exclusions. She regularly assists clients on customs enforcement matters, including audits, investigations, detentions, and penalty cases. Her experience in this area also includes advising and representing clients in prior disclosure submissions before U.S. Customs and Border Protection (CBP).

In addition, Karla has represented clients in a wide variety of sectors in antidumping duty and countervailing duty cases before the US Department of Commerce and the US International Trade Commission. 

Karla also counsels both US businesses and foreign investors in matters before CFIUS and advises clients on determining whether filings are mandatory or appropriate and the CFIUS process. She also helps clients with compliance, and enforcement matters related to the Export Administration Regulations (EAR), the International Traffic in Arms Regulations (ITAR), and the embargoes and sanctions programs administered by the Office of Foreign Assets Control (OFAC) and the US State Department.   

Her experience in the above areas includes advising and representing clients in matters concerning:

  • Tariff classification, country of origin, customs valuation, and forced labor issues (including compliance with withhold release orders, findings, and the Uyghur Forced Labor Prevention Act). 
  • Acceptability of intercompany transfer prices for customs valuation purposes under the transaction method and the application of the “first sale” value rule. 
  • Duty preferential treatment qualification under several trade agreements, including the U.S.-Canada-Mexico Agreement (USMCA), the Dominican Republic-Central America-US Free Trade Agreement (DR-CAFTA), the U.S.-Colombia Trade Promotion Agreement and the Japan- U.S. trade agreement.
  • Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962, including advice on the tariffs’ application, the eligibility for exclusions, and assisting clients in identifying duty mitigation strategies and obtaining duty refunds. 
  • Responding to CBP Requests for Information (CBP Form 28), Notices of Action (CBP Form 29), and CBP Notices to Mark or Redeliver (CBP Form 4647) and forced labor detention notices. 
  • Assisting companies in customs enforcement proceedings, including civil penalty actions, import seizures, and audits and helping importers in preparing and submitting prior disclosures to CBP for violations of customs laws and regulations. 
  • Representing importers and foreign producers in antidumping duty (AD) and countervailing duty (CVD) investigations before the U.S. Department of Commerce and the U.S. International Trade Commission involving products such as wooden furniture, wooden cabinets and vanities, steel, mattresses, mobile access equipment, among others. 
  • Representing importers and foreign producers in scope ruling requests, AD/CVD administrative reviews, and circumvention inquiries before Commerce related to a wide variety of products such as solar products, wooden furniture, and agricultural products. 
  • Licensing, compliance assessments and monitoring, and voluntary disclosures under the EAR, ITAR, OFAC, and U.S. State Department sanctions, and Foreign Trade Regulations.
  • Declarations, voluntary notices, and responses to non-notified inquiries under the CFIUS regulations involving U.S. business and foreign investors in several industries such as aviation and aerospace, defense, construction, freight forwarding, and software development.

Before practicing law in the United States, Karla was an international trade and customs attorney in Colombia, where she helped importers comply with Colombian customs laws and regulations and represented the domestic industry in AD investigations before the Colombian Ministry of Commerce, Industry and Tourism. Karla is fluent in Spanish.

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