Sarah B. W Kirwin, Counsel, International Trade

Sarah B. W. Kirwin

Counsel

Areas of Focus

Sarah B. W Kirwin, Counsel, International Trade

Sarah B. W. Kirwin

Counsel

skirwin@akingump.com

Areas of Focus

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Biography
  • Counsels companies on matters at the intersection of trade policy and supply chain regulation, including tariff mitigation strategies, customs and forced labor compliance, supply chain due diligence, foreign entity restrictions, access to investment and production tax credits, trade negotiations and overcoming trade barriers.
  • Advises clients on complex trade matters through advocacy, compliance enhancements, enforcement defense and litigation.
  • Represents sovereign governments in trade disputes before the World Trade Organization (WTO), free trade agreement (FTA) panels and other international fora.

Sarah advises U.S. and foreign clients on complex strategy and compliance matters at the intersection of trade policy and supply chain regulation. She provides practical, business-friendly guidance on a range of trade and supply chain issues, including:

  • Tariff policy and tariff mitigation strategies.
  • FTA negotiations, disputes and eligibility analysis.
  • Forced labor law compliance, including Uyghur Forced Labor Prevention Act detentions, the revocation of Withhold Release Orders and rapid response labor mechanism cases under the United States-Mexico-Canada Agreement (USMCA)
  • Supply chain due diligence.
  • Eligibility for U.S. tax credits and other incentives, particularly with respect to compliance with foreign entity restrictions.
  • Goods and services market access and non-tariff trade barriers.
  • Electronic commerce and digital trade issues.

Sarah not only helps clients shape these policies—through advocacy, rulemaking and disputes—but she also helps them comply and respond to enforcement actions by U.S. Customs and Border Protection (CBP), the Office of the U.S. Trade Representative (USTR) and the U.S. Department of Commerce, among others. 

She also represents private sector clients in trade litigation matters before the U.S. Court of International Trade. Sarah represents sovereign governments in trade disputes before the WTO, FTA panels and other international fora.

Sarah’s practice focuses on industries facing increased risks due to U.S. trade policy and national security objectives. She is a go-to advisor for clients across the automotive, energy storage, solar, aerospace, electronics, building materials and retail sectors. 

Prior to her legal career, Sarah worked in management consulting for a global firm, focusing on the management of organizational reforms within U.S. government agencies.

Representative Work
  • Advises automotive manufacturers and suppliers on FTA rule of origin compliance and related legal and policy matters.
  • Developing an internal compliance program for a major battery manufacturer to support tax credit eligibility and foreign entity restriction compliance.
  • Counsels multinational solar, apparel and sporting goods companies on supply chain due diligence related to forced labor compliance, including in response to detentions and Withhold Release Orders.
  • Member of lead counsel team in litigation challenging the legality of the Section 301 tariffs on products of China.
  • Successfully advocated for Section 301 tariff exclusions for numerous clients in the automotive, electronics, medical device, home goods, building materials, apparel and other sectors.
  • Represents solar sector and battery supply chain manufacturers in joint venture negotiations to enable compliance with federal incentives and foreign entity restrictions.
  • Represented sovereign governments as complainants, respondents and third parties in over 25 trade disputes related to the General Agreement on Tariffs and Trade 1994 (GATT 1994), the General Agreement on Services (GATS), the Agreement on Trade-Related Aspects of Intellectual Property (TRIPS Agreement), the Agreement on the Application of Sanitary and Phytosanitary Measures (SPS Agreement) and the Agreement on Technical Barriers to Trade (TBT Agreement) and the USMCA, among others.

Education
  • J.D., Duke University School of Law, 2017

  • M.P.P., University of Virginia, 2012

  • B.A., University of Virginia, 2011

Bar Admissions
  • District of Columbia

  • Virginia

Recognitions
  • The Legal 500 US, International Trade, 2022, 2024–2025, Leading Associate, 2025.
  • Akin, Pro Bono Scholar, 2015.
Affiliations and Public Service
  • Women in International Trade.
  • Washington International Trade Association.
Speeches and Publications

Insights and Achievements

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