Angela M. Santos

Angela advises companies on the importation of merchandise, customs compliance and the effect of trade measures on their supply chains. She helps structure transactions to manage duties and reduce customs penalty exposure, with particular experience advising fashion and retail companies, including prominent brands and fashion houses. Her work also spans consumer products, electronics, food and drug, and cosmetics. She represents importers, manufacturers, agents, customs brokers, freight forwarders, bonded warehouses and trading companies.

As leader of ArentFox Schiff’s task force on forced labor developments and import restrictions, Angela helps clients identify risks in their supply chains and establish policies and procedures to address them. She responds to customs questionnaires and prepares petitions seeking the release of merchandise detained under forced labor Withhold Release Orders. Her advice also addresses the Uyghur Forced Labor Prevention Act and related government enforcement measures.

Angela counsels clients on changing tariff and trade policies, including compliance, tariff mitigation and the recovery of tariff refunds. She engages with US government agencies and legislative stakeholders to pursue tariff relief through administrative proceedings, public comments and direct policymaker engagement. Her Section 232 work includes advising metal fabricators, equipment industry groups and industrial manufacturers on duties imposed on steel, copper and aluminum imports. She also helps manufacturers, importers and downstream users of metals plan for the effect of those duties on their supply chains. In matters involving Section 301 tariffs, she has obtained exclusions and advised on alternative manufacturing scenarios and duty-saving options.

Her customs practice covers rules administered by US Customs and Border Protection and other agencies, including the Fish and Wildlife Service, Consumer Product Safety Commission, Food and Drug Administration, Federal Trade Commission, Department of Commerce and US Trade Representative. Angela assists with customs audits, inquiries and investigations; detained or seized goods; penalties; and prior disclosures. She has represented clients in False Claims Act, FBI and ICE investigations, as well as litigation before the Court of International Trade.

Angela also develops internal import compliance programs and manuals and advises on country of origin, marking, tariff classification, valuation and duty recovery. Her work includes Free Trade Agreements, First Sale and Buying Agency programs, along with bonded warehouse applications and duty-free store requirements. She conducts customs due diligence for mergers and acquisitions and guides clients through the application and verification process for the US Customs-Trade Partnership Against Terrorism.

• Brooklyn Law School, JD, 2010
• Boston University, BS, Business Administration, International Management, Cum Laude, 2003

• New Jersey Bar
• New York Bar

• US Court of International Trade

• Co-chair of the New York State Bar Association (NYSBA) International Section – Trade Committee
• Customs and International Trade Bar Association
• International Compliance Professionals Association

Angela’s publications include:

• “Navigating the Complexities of Forced Labor Laws,” ArentFox Schiff’s 2026 Guide for Global Businesses, February 2026
• “Navigating the Complexities of Forced Labor Laws,” ArentFox Schiff’s 2025 Guide for Global Businesses, February 2025
• “Trump, Trade and Tariffs Tariffs Tariffs! How the Second Trump Administration’s Trade Policy Could Affect the Fashion and Retail Industry,” Retail Touchpoints, December 2024
• “Navigating the Complexities of Forced Labor Laws,” ArentFox Schiff’s 2024 Guide for Global Businesses, February 2024
• “Will AI save fashion supply chains?” Just Style, August 2023
• “Lessons to Be Learned In Canada: Biden Administration Enforcement of the Forced Labor Provisions In the USMCA,” Customs & International Trade Newsletter, Thomson Reuters, June 2021