Ms. Nappi is recommended for her work in International Trade.The Legal 500 US 2015-2018

Sarah M. Nappi

Washington, D.C.
  • 555 Eleventh Street, NW
  • Suite 1000
  • Washington, D.C. 20004-1304
  • USA

Sarah Nappi, a counsel in the Washington, D.C. office of Latham & Watkins and a member of the Export Controls, Economic Sanctions & Customs Practice, focuses on US customs law and import regulation. She works with clients in a variety of industries, including aerospace and defense, aviation, oil and gas, chemicals, electronics, and consumer products. Her practice includes:

  • Conducting internal investigations of customs violations and preparing prior disclosures to US Customs and Border Protection (CBP) to mitigate penalty exposure 
  • Responding to government investigations and enforcement actions, including customs penalty cases, detentions, and seizures 
  • Representing clients in CBP Focused Assessments, origin verification proceedings, administrative protests, and ruling requests 
  • Counseling clients on tariff classification, customs valuation, origin determination, country of origin marking, duty reduction strategies, CBP protection of intellectual property rights, and the application of other government agency requirements to US imports 
  • Developing, implementing, and enhancing US import compliance programs, as well as preparing and delivering in-house training 
  • Performing internal controls assessments and compliance audits of US commercial import activity and developing strategies to mitigate risk 
  • Advising on customs compliance and liability considerations in corporate due diligence activities

Ms. Nappi holds a customs broker’s license from US Customs and Border Protection and is a former Co-Chair of both the Customs Section of Women in International Trade and the Women's Bar Association's International Forum. She is also a member of the ABA Customs Law Committee and the Customs Lawyers Association. Her publications on customs and international trade matters have included: 

  • “US Customs: A Practitioner’s Guide to Principles, Processes, and Procedures” (contributing author), American Bar Association, International Practitioner’s Deskbook Series, Second Edition (2016)
  • “FTA Duty Refund Claims: Requirements, Limitations, and Practice Tips” (co-author), Thomson Reuters World Trade Executive: Practical Trade & Customs Strategies (October 15, 2013)
  • “US Customs: A Practitioner’s Guide to Principles, Processes, and Procedures” (contributing author), American Bar Association, International Practitioner’s Deskbook Series (2009)
  • “Recent Legal Developments Highlight NAFTA Compliance,” BNA International Trade Reporter (March 2, 2006)

Ms. Nappi’s recent experience includes the representation of: 

  • Several companies in the aerospace and defense, energy and consumer products industries in investigations and disclosures of customs violations 
  • A multinational electronics manufacturer in a CBP Focused Assessment and prior disclosure verification proceedings 
  • A global manufacturing company in an internal investigation of customs fraud 
  • US and Canadian companies in successful claims for millions of dollars in retroactive duty refunds under the North American Free Trade Agreement 
  • US defense contractors and a US medical supply company in free trade agreement verification proceedings by Canadian, Israeli, and Korean customs authorities 
  • A company in the aviation industry in developing a comprehensive US import compliance program and conducting training for management and employees 
  • A multinational high-tech company in obtaining a formal determination of country of origin from CBP for compliance with government procurement requirements under the Trade Agreements Act 
  • Medical and laboratory equipment manufacturers in tariff classification and country of origin marking issues 
  • A US industrial supply company in origin verification proceedings by CBP under the Dominican Republic-Central America-United States Free Trade Agreement 
  • Multiple companies in various industry sectors in customs-related due diligence activities relating to merger, acquisition, and financing activities
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