Navigating the New 232 Steel and Aluminum Tariff Requirements

Andy Siciliano is a Partner and leads the National U.S. Trade and Customs practice at KPMG. In his role, he leads a team of sixty people to assist multinational clients with international trade compliance and planning, the evaluation of cross-border transactions and compliance, and cost mitigation planning. Andrew specializes in assisting companies with reviewing, auditing, and assessing global import and export operations, and his experience includes collaborating with clients on customs audits and examining global supply chain structures for cost effectiveness. Andrew is a contributing author to The Import Handbook by Wiley and Sons, and has authored articles in the Customs and International Trade Bar Association Quarterly Newsletter, Journal of Accountancy, and BNA Tax Management publications, and a KPMG white paper, Managing Global Trade: A Rising Priority. Andrew is quoted regularly in CFO Magazine, the Journal of Commerce, and other business and trade publications, and is a frequent speaker at industry conferences, including American Association of Exporters and Importers’ annual conferences and Tax Executives Institute events. A licensed U.S. Customs Broker and certified public accountant, Andrew is a member of the New York Bar Association, the American Institute of Certified Public Accountants, and the American Association of Importers and Exporters. He holds a BA degree from Queens College and a JD degree from St. John’s University School of Law.

Gisele Belotto joined KPMG in 2005 and since then she has worked with several companies in a vast range of sectors. Gisele assisted her clients in the areas of global customs compliance, classification, customs value reconciliation, post entry reviews, transactional testing, special trade program procedures, importer self-assessment programs (ISA), NAFTA regulations, customs audits, and customs compliance trainings. Specifically, Gisele has assisted companies in the sporting goods, home furnishings, office supplies, automotive industry, and home appliance sectors to manage their customs planning and trade-related risks through mapping processes, identifying weaknesses, and enhancing procedures related to the company’s customs and trade compliance areas. Gisele has also assisted companies undergoing U.S. Customs and Border Protection (CBP) Focused Assessment Audits. Her role in these projects included advice regarding communication and interaction with CBP officials, detailed review and analysis of areas posing penalty risk, and drafting and quantification of prior disclosures.

Andrew Doornaert is a Managing Director in KPMG’s Trade and Customs practice. Andrew has more than 19 years of experience advising clients on a broad range of trade programs, import and export compliance and cost-savings opportunities related to global supply chain activities. Andrew uses his diverse consulting and customs brokerage background to assist clients with import and export planning and compliance. Andrew has advised multinational clients about compliance with various import and export regulations and assisted clients subject to enforcement procedures by Customs authorities-audits, verifications, and inquires. This included, working with several experienced companies to develop FTA eligibility determination processes with the goal of implementing the most cost-efficient, least time consuming method and considered various rules, such as, tariff shift, RVC, de minimis, roll-up, roll-down, averaging, accumulation, and preparing NAFTA Certificate Collection program for manufacturers in the United States. This also included NAFTA Certificates, instructions, training materials, and an audit tool for the client which included red-flags to identify when auditing NAFTA Certificates received from suppliers. He also managed NAFTA solicitation projects which involved preparing pre-populated NAFTA Certificates with HTS codes, collecting NAFTA Certificates from suppliers through various means to efficiently collect data for NAFTA eligibility determination process and applying applicable NAFTA rule of origin to determine tariff shift or RVC percentage. Andrew has worked with clients that represent a range of industries, including the automotive and heavy vehicle, consumer electronics, household products, retail, energy and defense. Andrew is a Licensed Customs Broker, he holds JD from the University of Detroit Mercy, and BA from Michigan State University.