Meet the Member: Matthew Bock, Partner, Middleton, Shrull & Bock LLC

Member news | November 22, 2019

In recent months, international trade has seen a resurgence in news coverage and visibility, keeping FACC Member Matthew Bock, Managing Partner at Middleton, Shrull & Bock very busy. In addition, Matthew just took up residency at the FACC office as a CoWorker, benefitting from the flexibility of daily, weekly and monthly desk rentals all in proximity to the French-American community and business services offered by the Chamber. 

Keep reading to learn more about Matthew's practice.

FACC: Middleton, Shrull & Bock is exclusively dedicated to the practice of Customs and International Trade Law, Import, Export and Economic Sanctions Regulatory Compliance. Recently, when in Beijing, Former Secretary of State Henry Kissinger spoke and cautioned against inciting a “conflict worse than WWII” (referring to the US-China tensions and retaliatory actions specifically). Has your practice observed an increase demand in advising, due to the volatility in current U.S. policies? Or to the contrary, do you perceive businesses to be increasingly pursuing development in other markets, or their home markets?

MB: We have absolutely seen an increase in demand. One of the defining features of the current conflict with China has been the imposition of tariffs (first by the United States, in response to an enumerated list of economic grievances, chief among them issues relating to technology transfer and intellectual property theft, and then, in retaliation, by China). There have been a series of tranches of tariffs, and each tranche has driven a new round of inquiries and calls to our firm by U.S. importers requesting guidance on how to avoid or mitigate these tariffs. There are a number of avoidance and mitigation options available, including the filing of a request for exclusion from the tariffs, which has been a very popular tool for our clients. The reviews that we have conducted on behalf of these clients have also inevitably led to the discovery of various, latent compliance gaps or deficiencies, and discovering and addressing (and, potentially disclosing) such gaps or deficiencies before the government does is critical. We do not foresee the conflict with China going away anytime soon, even if a “Phase 1” deal is accomplished, so we would strongly encourage companies with exposure to imports of Chinese-origin items to address that risk as early as possible.

FACC: Why are you personally passionate about this subject matter? What motivates you?

MB: I grew up in Francophone West Africa (Guinea and Togo), as an American, and this experience engendered a deep interest in global trade and geopolitics, which eventually drove me to pursue a career in international trade law and regulatory compliance right out of law school. This field has allowed me to stay perpetually engaged in those areas of interest, and to work with a broad segment of the global trade community (both here in the United States and around the world) on a very diverse and exciting range of projects. As far as law practices go, I can’t think of one that I find more interesting, exciting, and engaging.

FACC: Can you comment briefly on one of the most interesting cases you have represented to date? What distinguished it?

MB: I’m in the fortunate position of having had many, very interesting cases, particularly of late, as we’ve successfully obtained numerous exclusion requests for our clients from the China tariffs. One of the most interesting, recent projects has been assisting a major (traditionally EU-based) wind farm developer in understanding and addressing all of the Customs compliance risks associated with developing and building a groundbreaking utility-scale offshore wind farm in New England. This involved understanding the origin and classification of all of the underlying technology and negotiating and drafting Customs compliance clauses in dozens of engineering and supply contracts.

FACC: Regulations across sectors can vary greatly, for example, the importation of spirits and shoes do not follow the same script. Even within categories, we have observed that different products can be subject to preferential tariffs (i.e. men’s vs. women’s products). How do you help your clients to synthesize these complexities and integrate them into their business plans?

MB: You are right, the laws and regulations governing international trade can be extremely complex and can vary greatly across industries and product lines. A large portion of my practice involves assisting clients to address government inquiries, subpoenas, liquidated damages claims, penalties, audits, and other actions. These matters are inevitably costly and stressful for clients, and could have been avoided by the client expending a moderate level of time and resources on conducting a regulatory risk analysis and developing a compliance program to address those risks. This is the other large portion of my practice, and one that can be eminently more rewarding (both for the client and for me): interceding with clients before something has gone wrong to help them understand what risks their operations pose and develop and implement compliance policies, processes, and procedures that are tailored to their business and designed to effectively mitigate compliance risks.

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