Michael A. Pass

Associate

• mpass@steptoe.com
• vCard
• Washington Office

Michael A. Pass is an associate in the Washington office of Steptoe & Johnson LLP, where he is a member of the International Department. Mr. Pass' practice focuses on international trade litigation and customs law, including antidumping and countervailing duty investigations under the Tariff Act of 1930, as well as anticorruption investigations pursuant to the Foreign Corrupt Practices Act (FCPA). 

Mr. Pass has represented clients before the Department of Commerce (DOC) and the International Trade Commission (ITC). He has been involved in a number of appeals of determinations by the DOC and ITC before the US Court of International Trade, US Court of Appeals for the Federal Circuit, and NAFTA Binational Panels. In the anticorruption area, Mr. Pass has experience in FCPA compliance work, including conducting internal investigations, audits, and risk assessments; and representing clients before enforcement agencies and bodies, such as the SEC and the US Department of Justice. Other aspects of Mr. Pass’ practice include counseling clients on the commercial impact of antidumping and countervailing duties and application of the rules and regulations of the US Customs and Border Protection Service. On behalf of these clients, he has prepared and filed protests and prior disclosures, as well as presented petitions for cancellation or mitigation of fines, penalties, seizures, and claims for liquidated damages.

Prior to joining Steptoe, Mr. Pass spent over 10 years in international business with industry experience in the furniture, auto parts, foundry, and metal stamping industries.  He has particular knowledge in the areas of manufacturing operations, supply chain management, and logistics. In addition, Mr. Pass has experience as an international trade analyst at the US Department of Commerce, where he was involved in antidumping investigations.

Publications & Speaking Engagements

• International Law Advisory - New Department of Justice FCPA Opinion Procedure Release Establishes a Limited Safe Harbor Against Successor Liability Based on Significant Undertakings by An Acquirer Regarding Its Post-Closing Conduct
  July 1, 2008
• International Law Advisory - Willbros Group Agrees to Pay $32.3 Million To Resolve DoJ and SEC FCPA Enforcement Actions
  May 21, 2008
• Customs Law Advisory - US Court Decision Provides Cautionary Tale for Importers Challenging a US Customs Decision
  February 22, 2007

Professional Affiliations

• State Bar of Texas
• Texas Young Lawyers Association