About The Webinar

U.S. Customs and Border Protection recently advised importers that they must submit post-summary corrections, with required antidumping and countervailing duty deposits, for entries missing third-country AD/CV cases where the CBP country of origin differs from the Commerce scope country. The concern is profound because for nearly a year CBP’s Automated Commercial Environment system did not allow importers to file AD/CV entries with any of the listed third-country case numbers. For liquidated entries, CBP encourages voluntary tenders but advises that failure to take immediate action could lead to enforcement.

Key Topics

  • confirming whether a third-country AD/CV case applies to your merchandise and how to report it at entry
  • finding your applicable third-country case or obtaining one if needed
  • understanding the differences and similarities between CBP origin and Commerce scope rules that create third-country scenarios
  • deciding how and when to file post-summary corrections, voluntary tenders, or prior disclosures to minimize exposure
  • avoiding Enforce and Protect Act transshipment issues
  • finding resources and implementing best practices to increase compliance


Lenny P. Feldman

Managing Partner, Operating Committee

LENNY FELDMAN is a Managing Partner, Operating Committee with Sandler, Travis & Rosenberg, P.A., resident in the Miami office. He previously co-chaired the twenty-member Customs and Border Protection’s Commercial Customs Operations Advisory Committee, providing strategic recommendations directly to CBP, Homeland Security and Treasury executives on issues such as forced labor, intellectual property rights, e-commerce policy, trade partnership programs, enforcement and facilitation mechanisms, and regulatory reform. He currently serves as General Counsel and Customs Counsel to the National Customs Brokers & Forwarders Association of America (NCBFAA).


Kristen S. Smith

Partner, Advisory Committee; Trade Remedies Practice Group Leader

KRISTEN SMITH is a Partner, Advisory Committee with Sandler, Travis & Rosenberg, P.A., resident in the Washington, D.C., office. She leads the firm’s Trade Remedies Practice. Ms. Smith has a broad-based international trade and customs practice. For more than 20 years she has represented clients in antidumping and countervailing duty cases and litigation both in the U.S. and abroad. Her experience includes a number of no-injury determinations before the International Trade Commission and obtaining zero percent AD rates on behalf of clients before the U.S. Department of Commerce.



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