Andrew Caridas
- Washington, D.C.
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Andrew combines two decades of international trade and litigation experience with a technical background to help clients navigate tariffs, export controls, and foreign investment.
Andrew Caridas assists U.S. and global clients of all sizes at every stage of the regulatory compliance journey—providing risk-based assessments, implementing tailored programs and procedures, and delivering custom training to key stakeholders.
Whether advising an importer facing rapidly changing tariffs, a tech company navigating export control risk, or a foreign fund investing in U.S. critical technologies, Andrew provides practical regulatory compliance advice. He meets clients where they are, from startups seeking pre-seed financing to Fortune 100 companies looking to harmonize compliance between their divisions.
Andrew’s comfort with technology and quantitative data makes him a true partner to companies confronting highly technical export control and customs determinations in industries ranging from semiconductors and quantum computing to automotive manufacturing. Andrew’s technical background means company executives and technical experts can spend less time on regulatory compliance and devote more time to profit drivers.
As a seasoned trial and appellate lawyer, Andrew serves his clients well in internal and external investigations, regulatory audits, negotiations around voluntary disclosures and penalty notices, and antidumping and countervailing duty investigations before the U.S. Department of Commerce and the International Trade Commission, as well as regulatory litigation at both the trial and appellate levels.
Andrew maintains a strong commitment to pro bono work, dedicating up to 100 hours per year to representing indigent persons in criminal, habeas corpus, and immigration cases before the U.S. appellate courts. His successes include overturning the wrongful murder conviction of an Indiana man serving a 110-year prison sentence and halting the deportation of a Russian political activist, securing his asylum.
Areas of focus
Industries
Services
Education & Credentials
Education
- American University Washington College of Law, LL.M., International Trade and Investment, Solf Award, 2018
- Northwestern University Pritzker School of Law, J.D., magna cum laude, Associate Editor, Northwestern University Law Review, 2008
Bar and Court Admissions
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District of Columbia
Related Employment
- Zuckerman Spaeder, LLP, Washington, D.C., Associate, 2011-2017
- Skadden, Arps, Slate, Meagher & Flom, LLP, Chicago, IL, Associate, 2008-2011
Additional Languages
- German
- Romanian
Impact
Professional Leadership
- Customs and International Trade Bar Association, Board Member; Co-Chair, Export Control Committee, 2020-present
Professional Experience
Export Controls & Sanctions
- Created comprehensive export controls compliance program for aviation company manufacturing ITAR and EAR NS1-controlled products
- Obtained favorable export classification and license exception treatment for three generations of UAVs from major supplier to domestic and foreign military and law enforcement customers
- Obtained favorable export classification and license exception treatment for 5G cellular device location tracking and network signal routing technology
- Advised developer of one of the leading AI models on compliance related to the new AI diffusion framework, and developments subsequent to the change in administration
- Obtained two export licenses permitting domestic imaging company to continue selling its products to its largest customer, which had been blacklisted by the Bureau of Industry and Security (BIS)
- Obtained 10 export licenses, permitting foreign sensor and lighting giant to continue selling its products to its largest Asian customer, which had been blacklisted by the Bureau of Industry and Security (BIS)
- Obtained export license permitting software company to avoid foreign breach of contract liability and realize additional sales totaling in six figures to entities blacklisted by BIS
- Successfully negotiated 90%+ reduction to proposed nine-figure OFAC penalty for digital currency exchange regarding hundreds of thousands of alleged violations of Cuba, Iran, Sudan, Syria, and Ukraine-related sanctions violations
- Advised multinational mining company on export control issues related to U.S. government contracts for extraction of critical minerals
- Negotiated release of large and business-critical shipment of UAVs destined for the Indian Ministry of Defense, which had been erroneously held by U.S. Customs and Border Protection (CBP) on ITAR and EAR export control grounds
- Advised electronic retail company on export control issues related to development of AI and communications software by Chinese subsidiary
- Designed comprehensive export-control compliance plan for computer-aided design software company, allowing the company to continue to work with mission-critical developers located in Russia
Committee on Foreign Investment in the United States (CFIUS)
- Represented quantum computing company in connection with seven separate CFIUS declaration submissions over the span of five years, resulting in clearance of foreign investments from Canada, Finland, Germany, Japan, Latvia, the Netherlands, South Korea, and Sweden
- Lead CFIUS counsel for major foreign investment company in connection with acquisition of multinational aerospace company with U.S. defense contracts
- Represented defense technology contractor in connection with CFIUS written notice submission resulting in approval of acquisition by foreign firm
- Represented aerospace services company in connection with CFIUS declaration submission resulting in approval of substantial investment by foreign firm
- Represented advanced computing company in connection with CFIUS declaration submission resulting in approval of seed investment by foreign firm
- Represented autonomous UAV company in connection with CFIUS declaration submission resulting in approval of substantial investment by foreign firm
- Represented advanced computing materials manufacturer in connection with CFIUS non-notified transaction review and submission of CFIUS notice
- Advised Japanese technology company on potential CFIUS implications of formation of innovative multi-party joint venture investment vehicle
- Guided foreign investment fund through CFIUS review of investment in domestic aerospace company, including submission of CFIUS declaration and successful negotiation with CFIUS for withdrawal of the declaration in light of changes to investment structure
Outbound Investment Security Program (OISP)
- Advised Fortune 100 domestic technology company about potential OISP implications of joint venture with major Taiwanese technology company with substantial connections to China
- Advised investment arm of Fortune 100 domestic technology company on creation of OISP compliance policy
Tariffs & Customs Compliance
- Guided domestic battery technology company through customs valuation of imports from manufacturing affiliate in China, establishment of a bonded warehouse, and development of a duty drawback program
- Negotiated downward departure from U.S. Customs & Border Protection (CBP) penalty guidelines on behalf of client consumer products importer, resulting in penalty of approximately 3% of statutory maximum
- Successfully challenged CBP determination that tool parts were subject to additional duty pursuant to antidumping order
- Represented multinational forestry products company in connection with CBP audit involving USMCA compliance and lumber AD/CVD for billions of dollars of customs entries
- Advised Fortune 100 technology company on country-of-origin issues related to dozens of consumer electronics products as part of effort to move supply chains out of China in response to Section 301 tariffs
- Advised Fortune 100 brick-and-mortar retailer on country of origin labeling requirement for food mixtures with complex multi-country supply chains and seasonal variance
- Developed UFLPA compliance program, and continue to serve as principal outside customs counsel, for largest automotive industry association in the world
- Assisted Italian sportswear and outdoor supply company with customs valuation issues regarding internal sales and application of the first sale doctrine to reduce duty liability
- Assisted medical device company with determinations of commercial and non-commercial use, classification of retail products and testing samples, and importation of human tissue from Canadian medical trials
- Advised musical instrument company on country of origin issues related to instruments and related electronic devices
- Lead counsel for foreign manufacturer and domestic importer in USCIT and Federal Circuit challenge to presidential proclamation imposing “national security” tariffs under Section 232 on steel and aluminum derivative products
- Lead counsel for major semiconductor manufacturer in USCIT challenge to presidential proclamation imposing Section 301 tariffs on imports from China
- Advising semiconductor manufacturing equipment importer on customs classification, valuation, and domestic material issues related to reciprocal tariffs and Section 232 aluminum and copper tariffs
- Providing ongoing advice to automotive part manufacturer on customs classification and tariff status of hundreds of separate products
Buy American Act (BAA) and Build America, Buy America (BABA) Act Compliance
- Ongoing advice to domestic industrial lighting company on compliance with BAA and BABA compliance for construction subcontracts for federal and state infrastructure projects
- Advised one of the largest foreign producers of electric vehicle charging networks on BAA and BABA compliance with respect to planned expansion into the U.S. market
- Advised U.S. subsidiary of foreign medical imaging device company on BAA compliance with respect to prospective Veterans Affairs hospital contracts
International Trade Remedies
- Represented largest foreign producer and importer subject to antidumping and countervailing duty (AD/CVD) investigations on steel nails before the U.S. Department of Commerce, International Trade Commission, U.S. Court of International Trade (USCIT) and U.S. Court of Appeals for the Federal Circuit, resulting in de minimis dumping margins in multiple consecutive administrative reviews, successful appeal of original less-than-fair-value determination, and negative ITC injury determination in countervailing duty case
- Represented foreign paper producer in antidumping investigation before the U.S. Department of Commerce and International Trade Commission
- Advised major energy company on antidumping and countervailing duty risk related to solar cells and panels manufactured in China and Southeast Asia in light of new anti-circumvention investigation, new AD/CVD investigations, and subsequent USCIT case
- Secured scope ruling exempting dozens of styles of accent furniture from antidumping and countervailing duties on bedroom furniture articles from China
Trade Policy
- Advised semiconductor industry interest group on current and forthcoming U.S. export control regulations and opportunities for advocacy
- Advised construction material interest group on current and forthcoming U.S. import restrictions and opportunities for advocacy
- Assisted nongovernmental organization in conforming proposed energy legislation to the United States’ obligations under the World Trade Organization agreements
