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Angela M. Santos

Angela counsels clients on compliance with federal regulations involving the importation of merchandise.
Angela M. Santos, Partner at Arent Fox LLP

Angela helps companies identify business solutions and structure their transactions to facilitate the importation of merchandise, ensure regulatory compliance, minimize duties, and eliminate Customs penalty exposure.

Client Work

Angela advises clients on compliance issues involving rules governing the importation of merchandise issued by US Customs and Border Protection (Customs) and other government agencies (including the Fish and Wildlife Service, Consumer Product Safety Commission, Food and Drug Administration, Federal Trade Commission, the Department of Commerce, and the US Trade Representative). She represents importers, manufacturers, agents, Customs brokers, freight forwarders, bonded warehouses, and trading companies in various industries such as fashion, consumer products, electronics, food and drug, and cosmetics.

She helps clients manage Customs audits, respond to Customs inquiries and investigations, secure the release of detained or seized goods, mitigate or eliminate Customs penalties, and submit prior disclosures, where necessary. She has represented clients in False Claims Act investigations, FBI and ICE investigations, and in litigation in the Court of International Trade.

Angela advises clients on the development of internal import compliance programs and manuals to reduce the risk of Customs liability. She evaluates clients' supply chains and assists with the implementation of forced labor compliance programs. Angela responds to Customs questionnaires and prepares petitions for the release of merchandise detained in connection with forced labor Withhold Release Orders.

Angela routinely counsels clients regarding country of origin determinations, proper marking, correct tariff classification, valuation, duty recovery, bonded warehouse applications, and duty-free store requirements. She has extensive experience in duty savings programs including Free Trade Agreements, First Sale, and Buying Agency. In addition, she assists clients in mitigating the effects of the Section 301 tariffs by obtaining successful exclusion requests and identifying alternative manufacturing scenarios and duty savings avenues. She conducts Customs due diligence for mergers and acquisitions. Angela also guides clients through the US Customs-Trade Partnership Against Terrorism application and verification process.

Previous Work

Prior to joining Arent Fox, Angela was a partner at an international boutique law firm dedicated to the Customs and Trade practice. She also worked in Finance at an Energy Trading Software company prior to her legal career.

Professional Organizations

  • Customs and International Trade Bar Association
  • International Compliance Professionals Association