Jane Dempsey has extensive experience in international trade law. Before joining Polsinelli, she worked for ten years at the International Trade Commission in the Office of the General Counsel and, before then, eight years at the U.S. Department of Justice in the National Courts Section of the Commercial Litigation Branch. During her nearly two decades of government service, she provided legal advice on complex trade remedies issues and drafted injury opinions in numerous antidumping and countervailing duty investigations, safeguard investigations and five-year reviews spanning a wide range of industries. She also served as lead counsel for the International Trade Commission and the Department of Justice, successfully litigating trade cases before the U.S. Court of International Trade, U.S. Court of Appeals for the Federal Circuit, the World Trade Organization and the North American Free Trade Agreement (the predecessor to the United States-Mexico-Canada Agreement) binational panel. 

With her deep understanding of the trade statute and administrative proceedings before the government agencies, Jane provides strategic counsel to clients in diverse industries to ensure they stay in compliance with U.S. laws and regulations while mitigating potential risks. She also handles trade disputes before the government agencies and related appeals to the U.S. courts.

Education

  • The George Washington University Law School (J.D., with honors)
    • Notes Editor, The George Washington University International Law Review
  • Yale University (B.A., with distinction)

    Bar Admission

    • District of Columbia
    • Virginia

    Court Admissions

    • U.S. Supreme Court
    • U.S. Court of Appeals, Federal Circuit
    • U.S. Court of Federal Claims
    • U.S. Court of International Trade

    Professional Affiliations

    • Customs and International Trade Bar Association (CITBA)
      • Board of Directors, 2020-2022
      • Vice-Chair of Trade Remedies Committee, 2019-2020
    Publications
    IEEPA Refund Portal Opens on April 20: What Importers Should Know About Filing, Timing and Liquidity Options
    Key Takeaways U.S. Customs and Border Protection (CBP) will launch Phase 1 of CAPE on April 20, giving many importers their first access to the ACE-based path to request IEEPA duty refunds. More complicated entries – including those involving certain AD/CVD orders, protests, drawback, reconciliation and liquidated entries that are more than 80 days past liquidation – remain outside Phase 1 or will follow a different timeline. Importers and brokers should act now to confirm ACE portal access, ACH/electronic refund enrollment, U.S. bank account information and entry eligibility before submitting CAPE declarations. CBP also has made clear that filers may not initiate an IEEPA refund request through a Post Summary Correction (PSC). Timing of refund declaration processing will vary. For many standard accepted entries, CBP
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    CBP to Launch Phase One of CAPE for IEEPA Refunds on April 20
    Key Takeaways U.S. Customs and Border Protection (CBP) will launch the first phase of its Consolidated Administration and Processing of Entries (CAPE) tool to process International Emergency Economic Powers Act (IEEPA) duty refunds on April 20. Phase one is limited to most unliquidated entries and entries within 80 days of liquidation, while more complex scenarios will be addressed in later phases as more functionality is added to the CAPE system. Importers and brokers should prepare now by confirming ACE Portal access, ensuring that their U.S. bank account information is accurate and up to date, and identifying entries eligible for phase one processing.  On April 10, 2026, CBP issued Cargo Systems Messaging Service Number 68315804, announcing that the first phase of CAPE will go live
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