An update on Anti-Forced Labor guidance issued by US Customs in the context of Withhold Release Orders (WROs).

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Photo of David Stepp David Stepp

David Stepp is an experienced trade lawyer who provides multinational companies with strategic advice on global customs and international trade compliance matters. David is a partner in the Los Angeles office of Crowell & Moring.

His practice focuses on advising companies on their…

David Stepp is an experienced trade lawyer who provides multinational companies with strategic advice on global customs and international trade compliance matters. David is a partner in the Los Angeles office of Crowell & Moring.

His practice focuses on advising companies on their e-commerce strategies globally, conducting global customs and international trade audits, and assisting clients on improving, benchmarking, and coordinating compliance programs across borders.

David has over 30 years of experience handling international trade regulatory matters, including those related to tariff classification, valuation, country of origin marking, free trade agreements, and Customs-Trade Partnership Against Terrorism (CTPAT).

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Photo of Simeon Yerokun Simeon Yerokun

imeon Yerokun is a counsel in Crowell & Moring’s International Trade group and based in the firm’s Washington, D.C. office. He advises clients on all areas of import regulatory compliance, trade remedies, and international trade litigation.

Simeon has extensive experience counseling companies in

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imeon Yerokun is a counsel in Crowell & Moring’s International Trade group and based in the firm’s Washington, D.C. office. He advises clients on all areas of import regulatory compliance, trade remedies, and international trade litigation.

Simeon has extensive experience counseling companies in the areas of business and human rights law, including compliance with global anti-forced labor and human rights requirements. He regularly represents companies before U.S. government agencies on forced labor-related matters, including securing the release of goods detained and seized by U.S. Customs and Border Protection. He also offers deep experience assisting companies in mapping their supply chains, including linking imported products back to their raw materials using enterprise software and other inventory management audit tools. Simeon is highly accomplished in forced labor supply chain mapping and risk assessments, as well as verifying due diligence efforts with on-the-ground visits to client facilities, incorporating third-party intelligence and audit resources.

Simeon’s experience also covers a broad spectrum of trade and customs issues, including those related to import regulatory compliance matters such as valuation, classification, duty drawback, marking and labeling, entry procedures, and penalties; free trade agreements; antidumping and countervailing duty issues; trade litigation; intellectual property issues such as trademark and copyright infringement; the enforcement of exclusion orders issued by the International Trade Commission (ITC); steel and aluminum tariffs under the Section 232 National Security Investigation; and the additional tariffs on products from China under Section 301 of the Trade Act of 1974.

Additionally, Simeon handles antidumping (AD) and countervailing duty (CVD) investigations before the U.S. Department of Commerce’s International Trade Administration (ITA) and the U.S. International Trade Commission (ITC) under the Tariff Act of 1930, and litigation involving the U.S. Court of International Trade (CIT).

Prior to joining Crowell, Simeon was a trade and finance attorney in the Office of Chief Counsel—U.S. Customs and Border Protection (CBP), and before that, he served as counsel to Commissioner Irving A. Williamson at the U.S. International Trade Commission.

Simeon is a proud graduate of Howard University School of Law, where he served as technical editor of the school’s Human Rights and Globalization Law Review.

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Photo of Pierfilippo M. Natta Pierfilippo M. Natta

Pierfilippo M. Natta (“Pier”), is an associate in Crowell’s International Trade Law practice. He focuses on assisting clients with complex international trade matters, ranging from implementing sanctions and export controls programs to forced labor investigations and general trade disputes. Pier works on developing…

Pierfilippo M. Natta (“Pier”), is an associate in Crowell’s International Trade Law practice. He focuses on assisting clients with complex international trade matters, ranging from implementing sanctions and export controls programs to forced labor investigations and general trade disputes. Pier works on developing Business and Human Rights legal guidance for clients and his practice covers a global reach including US, EU and Asia. His investigatory work has primarily focused on South-East Asia.

Pier applies his international trade knowledge to help clients identify manage and remediate risks. He has advised U.S. and global companies on developing programs specific to UN, US, and EU sanctions. More recently, Pier and the Crowell team are working to develop Crowell’s Business and Human Rights sub-practice which includes Crowell’s anti-forced labor investigatory work.

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Photo of Sibilla Grenon Sibilla Grenon

Sibilla Grenon is an associate in Crowell & Moring’s International Trade Group.

Before joining Crowell, Sibilla clerked for the Honorable Timothy M. Reif of the Court of International Trade, where she assisted Judge Reif in cases related to antidumping and countervailing duties, customs,

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Sibilla Grenon is an associate in Crowell & Moring’s International Trade Group.

Before joining Crowell, Sibilla clerked for the Honorable Timothy M. Reif of the Court of International Trade, where she assisted Judge Reif in cases related to antidumping and countervailing duties, customs, and matters arising from the Court’s residual jurisdiction. Sibilla also assisted Judge Reif in the adjudication of cases before the Southern District of New York, notably in areas of trade secret and copyright law. Prior to her clerkship, Sibilla was an associate in the litigation group of a law firm where she represented clients on compliance issues concerning privacy and data security for large corporations in accordance with state, federal, and international privacy regulations (GDPR, CCPA, CPRA, TCPA, BIPA, and GLBA) and employment matters.

Sibilla is a Rising Leader with the Aspen Strategy Group, a program that cultivates the next generation of rising leaders in national security and foreign policy.

As a law student, Sibilla served as the articles editor for the Georgetown Journal of International Law, a fellow at the Institute of International Economic Law, and was a member of Georgetown’s francophone moot court team of the Concours d’Arbitrage International de Paris.

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Photo of Andrew J. Schlegel Andrew J. Schlegel

Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border

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Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. Andrew also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

Prior to joining Crowell & Moring, Andrew worked as an intern at SAP’s Government Affairs Business Development Team in Berlin, Germany. There, he analyzed the effects of regulatory changes on SAP business operations and expansion opportunities. Before this, he completed an internship at the International Trade Administration’s Office of Energy and Environmental Industries. While there, he developed the U.S. Energy Trade Dashboard, an interactive data visualization tool for use by professionals and researchers to analyze how energy supply chains have developed.

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