Christine J. Sohar Henter

Christine started her legal career in public service. She was a senior attorney with the Office of the Chief Counsel for Import Administration (now the Office of Enforcement & Compliance) at the U.S. Department of Commerce (DOC). There, she advised U.S. government officials on compliance with U.S. trade laws and represented the U.S. in judicial appeals domestically before courts and internationally before the World Trade Organization (WTO) and North America Free Trade Agreement (NAFTA) panels. Christine was also the lead attorney for Commerce's Office of Textiles and Apparel, drafting implementation regulations, counseling on the application and negotiation of international textile and free trade agreements. Prior to DOC, Christine served as a legal adviser for a Commissioner and Chairperson at the U.S. International Trade Commission (ITC), assisting with trade remedy decisions, responding to inquiries from Congressional members, and overseeing 337 reviews. Before pursuing her government legal service in Washington, D.C., she assisted numerous companies with their export business through the Denver US Export Assistance Center.

Christine's import trade practice includes advising clients on customs compliance, trade remedy proceedings (antidumping duty, countervailing duty and safeguard cases), Foreign Trade Zones, Buy America requirements, and Section 337 intellectual property investigations. She also helps clients successfully navigate the complex rules of international trade agreements, trade legislation and regulations before the DOC, ITC, and the U.S. Bureau of Customs and Border Protection (CBP), as well as import requirements of the U.S. Food and Drug Administration (FDA), Fish and Wildlife Services, and Department of Agriculture.

Additionally, Christine has helped companies develop import or customs compliance programs and safeguard supplier relationships and supply chain management to mitigate risks, and has represented U.S. and non-U.S. companies before U.S. government agencies. She advises on trade restrictions, tariff classifications, valuation, marking, country of origin, ruling requests, internal advice requests, responses to information requests, and protests. She also assists company and trade association clients with tariff matters under Section 301 and Section 232, including exclusion requests and appeals related to these tariffs. Christine also assists companies with complying with the Uyghur Forced Labor Prevention Act (UFLPA), including supply chain tracing, compliance training, implementing compliance procedures and policies, and development of comprehensive business compliance programs.

Her experience in export controls issues ranges from assisting companies with a wide range of compliance matters, such as classification of encrypted technology, software, computer and aerospace products, to navigating ever-evolving export regulations and sanctions laws. Christine also represents clients for voluntary disclosures, developing compliance programs, and obtaining export licenses and other export authorizations under the Commerce Control List of the Export Administration Regulations (EAR) and the U.S. Munitions List of the International Traffic in Arms Regulations (ITAR). She also counsels clients on U.S. sanctions and embargoes enforced by the Office of Foreign Assets Control (OFAC) and foreign investment matters before the departments of State, Commerce, Defense and Treasury.

In addition, Christine advises U.S. and non-U.S. businesses regarding foreign direct investment in U.S.-based corporations, and represents clients before the Committee on Foreign Investment in the United States (CFIUS) by conducting due diligence, drafting notices and developing risk mitigation plans for sensitive infrastructure. She also counsels companies on the Foreign Corrupt Practices Act (FCPA) by developing compliance programs, analyzing transactions for potential liability, conducting internal reviews, and drafting contracts for agreements with non-US-based representatives.

She co-leads three subject matter expert teams assisting the Special Compliance Coordinator appointed by the U.S. Department of Commerce to monitor, assess and report on the U.S. export control compliance of Zhongxing Telecommunications Equipment Corporation, of Shenzhen, China, and ZTE Kangxun Telecommunications Ltd. of Hi-New Shenzhen, China (collectively, ZTE).

Prior to joining Barnes & Thornburg, Christine was in private practice, where she was involved in litigating the most recent trade remedies case before the U.S. Supreme Court, Eurodif S.A. v. United States.

Additionally, Christine teaches basic and advanced level courses across the country on compliance with U.S. export control laws and regulations, such as the ITAR, EAR and OFAC restrictions.