Michael D. Sherman, a member of Venable's International Trade and Customs Group, focuses his practice on administrative law, concentrating on matters relating to U.S. economic sanctions, customs, export controls, foreign investment in the United States (Exon-Florio), U.S. investment and business operations in foreign countries, Free Trade Agreements and unilateral trade preference programs, and international trade policy.

Mr. Sherman provides counsel regarding all aspects of regulatory compliance and enforcement in these areas, and he represents clients before the Office of Foreign Assets Control, U.S. Customs and Border Protection, Bureau of Industry and Security, Directorate of Defense Trade Controls in connection with rulemakings, tariff classifications, audits, licensing, ruling requests, protests, penalty proceedings, voluntary disclosures, Jones Act issues, and internal corporate compliance.  Also, he represents clients before the Committee on Foreign Investment in the United States (CFIUS) in CFIUS’ review of transactions that result in control of a U.S. business by a foreign person. In addition, he advocates on behalf of clients before the U.S. Congress on trade issues, including a variety of matters germane to U.S. investment in foreign countries. He has appeared before the United States Court of Appeals for the Fifth Circuit, U.S. Court of International Trade, and several U.S. District Courts in obtaining judicial review of agency action.

Mr. Sherman has represented clients in high-profile international trade, investment policy, and regulatory matters.  He was counsel for a South American country before the World Trade Organization in a challenge to U.S. regulations that discriminated against imported gasoline.  He also represented one of the major participants in the UN Iraqi Oil-for-Food Program in investigations arising from that program’s operation.  In addition, he represented an international oil trading company before the U.S. Court of Appeals in a case involving the blocking of millions of dollars of assets under the then-existing Libyan Sanctions Regulations.  Mr. Sherman was also instrumental in obtaining a change in the NAFTA Rules of Origin for petroleum products.

He served as an expert in U.S. economic sanctions and export control law in a British judicial proceeding related to the transfer of three Boeing 747s to Iran. In the past two years, he has obtained CFIUS approval of acquisitions of a variety of entities including a coal company, a provider of secure internet equipment and services to the U.S. military and other government agencies, and a liquified natural gas facility, involving particular issues such as the relationship of a foreign owner with questionable foreign individuals, the meaning of "control" under the CFIUS regulations, and Foreign Ownership, Control and Influence (FOCI) concerns regarding classified information.

His most recent significant work in the customs area involves addressing issues relating to the use by U.S. Customs and Border Protection (CBP) of 19 U.S.C. § 1509(a)(1)(A) to obtain records from importers, and CBP’s verification of duty-free claims by petroleum product importers under Free Trade Agreements and unilateral trade preference programs.