19CFR Trade Consulting
Executive Director, Don Luther
Managing Director, Michelle Salem
International Trade Specialist, Nancy Roe
International Trade Specialist, Cara Zamboni
Senior International Trade Specialist, Leo Wells

Don Luther
Executive Director

Cumberland, MD

Don Luther co-founded 19CFR Trade Consulting after eight years with the U.S. Customs Service and three years with a national law firm.

Don brings a wealth of expertise in all areas of international trade compliance. He served with U.S. Customs from 1992 to 2000 as an import specialist in his home town of Seattle, and then as a program officer at Customs headquarters in Washington, DC. He is renowned for his work in customs modernization efforts, including the ACS Reconciliation Prototype.

From 2000 to 2003, Don practiced as an attorney and trade specialist in the Customs and Trade division of a national law firm.

He is a licensed customs broker and an attorney* admitted to the State Bar of California.


Juris Doctor, George Washington University, 2001
B.A. Linguistics, University of Washington, 1991
A.A.S. Digital Electronics, N. Seattle Comm. College, 1987

Professional and Community Involvement

Member, Trade Support Network (Transition Committee, Legal & Policy Committee)

*Don Luther is Of Counsel with an international trade law firm in Washington, DC. 19CFR Trade Consulting partners with this and other firms on specific matters. However, 19CFR Trade Consulting is not a law firm, and its independent services do not constitute the practice of law.

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Michelle Salem
Managing Director

Miami Beach, FL

Michelle Salem cofounded 19CFR Trade Consulting after working with an international law firm for several years. During that time Michelle was the controller for the law firm and later served as a consultant specializing in valuation (with special emphasis on related party transactions) and free trade programs.

She covers the full range of international trade issues, with particular expertise in audits, accounting and finance, reconciliation, preferential trade programs, rules of origin, middleman sales valuation and internal training.

Michelle has more than 20 years' experience in compliance assessment with customs regulations and laws, customs-related issues involving transfer pricing, the use of preferential programs such as GSP, CBI, NAFTA and DR-CAFTA, and minimizing duty in multi-tiered sales transactions.

Michelle often deals with complex import regulatory issues, especially those involving the determination of accurate customs values. In addition, she analyzes whether companies can restructure their transactions to lower their customs value, thereby achieving duty savings. She assists companies in conducting internal audits, primarily focused on their customs compliance programs, and in developing and implementing such a program when needed. She also prepares companies for customs regulatory audits and compliance reviews. Further, Michelle conducts employee compliance training and assists in establishing offshore service companies, preparing annual cost submissions, and other customs matters.


B.A., Florida International University, 1990


Spanish (Conversational)

Professional and community involvement

Founding Member, Miami Chapter, Women in International Trade (Treasurer, 1993-1996)

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Nancy Roe
International Trade Specialist

Manhattan Beach, CA

Nancy Roe has been with 19CFR Trade Consulting since 2005, as an international trade specialist.

Nancy began her international trade career in 1984 at a customs brokerage and freight-forwarding firm in Los Angeles, where she performed inbound traffic and import brokerage functions. Within a few years she rose to the position of import manager for the customs brokerage team. She obtained her customs broker's license in 1988.

In 2000, Nancy started working as a writer for an e-learning website specializing in training for the international trade community. She has been a consultant advising brokers and importers on customs compliance and import/export issues since 2002.


B.A. Tulane University, 1984

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Cara Zamboni
International Trade Specialist

Chapel Hill, NC

Cara Zamboni has been with 19CFR Trade Consulting since 2008, as an International Trade Specialist.

Cara began her 12 year career with U.S. Customs and Border Protection in 1995 as an Import Specialist in the Port of Baltimore, specializing in steel and base metals. She also worked in Customs headquarters in the Office of International Affairs and as a program officer in the Office of International Trade. The last several years of her career with CBP were spent as a National Account Manager. In this position Cara worked with importer accounts in the pharmaceutical, textile, steel, chemical and mass merchandising industries as well as broker accounts to ensure compliance and national uniformity. Cara also assisted with developing and implementing national policies for the Account Management Program and the Importer Self Assessment Program.


BA Clemson University 1995
MBA University of Pittsburgh Katz Graduate School of Business 2004

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Leo Wells
Senior International Trade Specialist

Providence Forge, VA

Leo Wells is 19CFR Trade Consulting's senior international trade specialist, a position he has held since joining the company in 2004.

Leo retired from U.S. Customs and Border Protection in 2004 after more than 40 years of government service. He served in various capacities with Customs field offices in New York, Cleveland and Miami, as well as at Customs headquarters in Washington, DC.

During most of his distinguished Customs career, Leo served as a program manager at Customs headquarters. He is best known as the chief operational liaison between Customs and other government agencies, including FDA, EPA, and the U.S. Department of Commerce. He was responsible for analysis and operational implementation of antidumping and countervailing duty cases for the agency, and played a significant role in the negotiation of free trade agreements and special trade issues with several foreign countries.


Legal Studies, Case Western Reserve University, 1963-1964
B.A., Political Science, John Carroll University, 1961

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19CFR Trade Consulting, LLC

P.O. Box 3093, Cumberland, MD 21502 (301) 722-3449
1920 Bay Drive, Miami Beach, FL, 33141 (305) 867-0800

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