Last month, the Department of Justice put trade, customs, and tariff fraud squarely in the spotlight. This isn’t just another line item on the compliance checklist, it’s a loud-and-clear signal that import-related enforcement...more
6/10/2025
/ Corporate Counsel ,
Customs ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Fraud ,
Imports ,
Manufacturers ,
Risk Management ,
Supply Chain ,
Tariffs ,
White Collar Crimes
In less than 100 days, the Trump administration has implemented a dizzying array of new tariffs, significantly increasing costs and complexity for U.S. importers. The administration is keenly aware that companies operating in...more
3/26/2025
/ China ,
Criminal Prosecution ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Statements ,
Foreign Trade Regulations ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Regulatory Requirements ,
Risk Management ,
Risk Mitigation ,
Smuggling ,
Tariffs ,
Trump Administration ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes ,
Wire Fraud
We have received several requests for a list of the compliance policies that make sense for every multinational company. So, as a follow-up to our earlier two posts providing “twelve steps to international compliance” (see...more
1/4/2024
/ Anti-Corruption ,
Anti-Discrimination Policies ,
Anti-Harassment Policies ,
Anti-Retaliation Provisions ,
Antitrust Provisions ,
Books & Records ,
Code of Conduct ,
Compliance ,
Conflicts of Interest ,
Copyright ,
Customs ,
Cybersecurity ,
Data Protection ,
Document Retention Policies ,
Economic Sanctions ,
Ethics ,
Export Controls ,
Family and Medical Leave Act (FMLA) ,
Forced Labor ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Imports ,
Insider Trading ,
Internal Controls ,
Litigation Hold ,
Multinationals ,
Popular ,
Privacy Laws ,
Risk Mitigation ,
Social Media ,
Supply Chain ,
Trademarks ,
Uyghur Forced Labor Prevention Act (UFLPA)
Many have viewed corporate commitments to ESG as largely performative measures amidst toothless compliance frameworks. But this has been changing and we expect that change to continue. One example arises out of the “S” in...more
12/20/2022
/ Child Labor ,
Compliance ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
EU ,
Forced Labor ,
Imports ,
Proposed Regulation ,
Supply Chain ,
Trade Facilitation and Trade Enforcement Act ,
United States-Mexico-Canada Agreement (USMCA) ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Withhold Release Orders (WROs)
On December 8, the U.S. House of Representatives passed the Uyghur Forced Labor Prevention Act nearly unanimously. The House bill would create a “rebuttable presumption” that all goods from the Xinjiang Uyghur Autonomous...more
12/10/2021
/ China ,
Customs and Border Protection ,
Economic Sanctions ,
Enforcement Actions ,
Forced Labor ,
Human Rights ,
Imports ,
Securities and Exchange Commission (SEC) ,
Supply Chain ,
Supply Contracts ,
Withhold Release Orders (WROs)
Yesterday, the U.S. Customs and Border Protection (“CBP”) issued a Withhold Release Order (“WRO”) against Hoshine Silicon Industry Co. Ltd. , a company located in China’s Xinjiang Uyghur Autonomous Region (“XUAR”). The WRO...more
6/28/2021
/ Biden Administration ,
China ,
Customs and Border Protection ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Exports ,
Forced Labor ,
Human Rights ,
Imports ,
Solar Energy ,
Supply Chain ,
US State Departments ,
Withhold Release Orders (WROs)
...Think your company and its employees are beyond the reach of U.S. authorities? Maybe you don’t have U.S. operations there, or your company isn’t publicly traded on a U.S. stock exchange. Perhaps you don’t directly sell or...more
6/2/2020
/ Anti-Bribery ,
Anti-Competitive ,
Antitrust Violations ,
Business Operations ,
Conspiracies ,
Copyright ,
Department of Justice (DOJ) ,
Enforcement ,
Exports ,
Federal Trade Commission (FTC) ,
Foreign Corrupt Practices Act (FCPA) ,
Imports ,
International Trade Commission (ITC) ,
Jurisdiction ,
Office of Foreign Assets Control (OFAC) ,
Patents ,
Sherman Act ,
Trademarks