Comments/Notes on Adjudication Structure:
This scheme allows for hearings for review of sanctions issued when a party violates an Administrative Protective Order issued in an Anti-Dumping Proceeding. A party may request a hearing before a presiding official, who could be an administrative law judge, a hearing commissioner, or other person who is not under the supervision or control of the Assistant Secretary for Import Administration, the Deputy Secretary for International Trade, the Chief Counsel for Import Administration, or a member of the APO Sanctions Board. See 19 CFR 354.2. If a party is dissatisfied with a decision, he or she may appeal to the APO Sanctions Board, which consists of the Under Secretary for International Trade (who also serves as the chair), the Under Secretary for Economic Affairs, and the General Counsel. See 19 CFR 354.15(a).