As detailed in Part I of our three-part series on Minimizing Customs Enforcement and False Claims Act Risks, the combination of the new high-tariff environment, the heightened ability of Customs (and the general public) to...more
4/25/2025
/ Anti-Dumping Duty ,
Classification ,
Compliance ,
Countervailing Duties ,
Country of Origin ,
Customs and Border Protection ,
Duty Free ,
Enforcement Actions ,
False Claims Act (FCA) ,
Free Trade Agreements ,
Imports ,
International Trade ,
Misclassification ,
Misrepresentation ,
Penalties ,
Risk Management ,
Tariffs ,
Valuation
Assessing Tariff Impacts in Commercial Contracts -
With the size and scope of President Trump’s tariffs continuing to shift, this is a critical time for businesses to assess their contracts and determine how increased...more
Share on Twitter Print Share by Email Share Back to top The recent announcement of a pause in the rollout of reciprocal tariffs has created some confusion — and some hope — for multinationals and importers around the world....more
4/14/2025
/ Automotive Industry ,
China ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
Multinationals ,
Retaliatory Tariffs ,
Risk Management ,
Supply Chain ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
On April 3, 2025, President Trump issued the full details of the automotive tariffs, including the exact Harmonized Tariff Schedule (HTS) subheadings to which the automotive tariffs apply. This completed the implementation of...more
4/14/2025
/ Automotive Industry ,
China ,
Customs and Border Protection ,
Foreign Trade Zones ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Supply Chain ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
As detailed in our prior article on “What Every Multinational Company Should Know About … The Rising Risk of Customs False Claims Act Actions in the Trump Administration,” the Department of Justice (DOJ) is encouraging the...more
4/10/2025
/ Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement ,
False Claims Act (FCA) ,
Imports ,
International Trade ,
Multinationals ,
Penalties ,
Risk Management ,
Settlement ,
Tariffs
On April 2, 2025, President Trump implemented the steepest American tariffs in over a century. The implications for numerous multinational companies — including importers, manufacturers, distributors, and retailers — will be...more
4/4/2025
/ Anti-Dumping Duty ,
Automotive Industry ,
China ,
Compliance ,
Corporate Counsel ,
Countervailing Duties ,
Country of Origin ,
Customs and Border Protection ,
Distributors ,
Imports ,
International Trade ,
Manufacturers ,
Multinationals ,
Retailers ,
Supply Chain ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
Although we are only two months into the new administration, we have seen a dizzying array of new tariffs that have been proposed, imposed, revoked, suspended, and sometimes reimposed. It can be difficult for importers to...more
3/20/2025
/ Canada ,
China ,
International Trade ,
Mexico ,
Popular ,
Risk Management ,
Section 232 ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trump Administration
On February 20, 2025, the Deputy Assistant Attorney General for the Commercial Litigation Branch at the U.S. Department of Justice (DOJ), Michael Granston, emphasized using the False Claims Act (FCA) to address U.S. Customs &...more
3/7/2025
/ Compliance ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Globally Harmonized System ,
Imports ,
International Trade ,
Misclassification ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trump Administration ,
US Enforce and Protect Act (EAPA) ,
Whistleblowers
As reported in our prior article, “What Every Multinational Company Should Know About … The New Steel and Aluminum Tariffs (Part I),” President Trump signed two proclamations on February 10, 2025, imposing 25-percent tariffs...more
2/26/2025
/ Compliance ,
Customs and Border Protection ,
Imports ,
International Trade ,
Risk Management ,
Section 232 ,
Steel Industry ,
Supply Chain ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department
What Has President Trump Announced?
On February 10, 2025, President Trump signed proclamations titled Adjusting Imports of Steel Into the United States and Adjusting Imports of Aluminum into the United States. The...more
As an accompaniment to our “What Every Multinational Should Know” biweekly series, below find an update to our “Five Compliance Best Practices” series, which provides quick-hit advice for multinational companies to implement...more
Our previous article on What Every Multinational Company Should Know About … Managing Import Risks Under the New Trump Administration (Part I) identified the 12 main import-related risks (and opportunities) likely to arise in...more
1/29/2025
/ Corporate Counsel ,
Customs and Border Protection ,
International Trade ,
Risk Management ,
Supply Chain ,
Tariffs ,
Trade Agreements ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
Uyghur Forced Labor Prevention Act (UFLPA)
As an accompaniment to our biweekly series on “What Every Multinational Company Should Know About” various international trade, enforcement, and compliance topics, below find an update to our series on compliance checks that...more
1/24/2025
/ Compliance ,
Customs ,
Customs and Border Protection ,
Cybersecurity ,
Forced Labor ,
Human Rights ,
International Trade ,
Labor Regulations ,
National Security ,
Risk Management ,
Supply Chain
Share on Twitter Print Share by Email Share Back to top On September 26, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) published a Notice of Proposed Rulemaking that, if finalized, would prohibit...more
10/11/2024
/ Automotive Industry ,
Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Data Collection ,
Driverless Cars ,
Due Diligence ,
Export Controls ,
Foreign Adversaries ,
Hardware ,
International Trade ,
Proposed Rules ,
Recordkeeping Requirements ,
Russia ,
Software ,
Supply Chain ,
Vulnerability Assessments
The United States-Mexico-Canada Agreement (USMCA) automotive sector must be prepared to navigate a new set of requirements that will likely reshape supply chains, impact costs, and alter the competitive dynamics within the...more
We have received a number of inquiries regarding the implications of the new solar panels antidumping (AD) and countervailing duty (CVD) investigations. With the ITC just issuing its affirmative preliminary determination, we...more
7/5/2024
/ Anti-Discrimination Policies ,
Countervailing Duties ,
Importers ,
Imports ,
International Trade ,
International Trade Commission (ITC) ,
Manufacturers ,
Multinationals ,
Solar Panels ,
Supply Chain ,
Tariffs
Share on Twitter Print Share by Email Share Back to top In Part I and Part II of “What Every Multinational Company Needs to Know About … The Uyghur Forced Labor Prevention Act” (UFLPA), we summarized the UFLPA requirements...more
2/23/2024
/ Compliance ,
Corporate Counsel ,
Customs and Border Protection ,
Forced Labor ,
Human Trafficking ,
Internal Controls ,
International Trade ,
Multinationals ,
New Guidance ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA)
In our previous biweekly update, What Every Multinational Needs to Know About … The Uyghur Forced Labor Prevention Act, Part I, we summarized the UFLPA requirements and the basic expectations that U.S. Customs and Border...more
2/1/2024
/ Compliance ,
Corporate Counsel ,
Customs and Border Protection ,
Due Diligence ,
Forced Labor ,
Human Trafficking ,
Imports ,
International Trade ,
Multinationals ,
Risk Management ,
Supply Chain ,
Transparency ,
Uyghur Forced Labor Prevention Act (UFLPA)
Happy Thanksgiving! As anyone who saw our Halloween International Trade Update is aware, we are all in favor of alternative ways to get out our international regulatory compliance message. So, who better to aid in our...more
Did you know that whistleblowers can use the False Claims Act to get the U.S. Government to investigate allegations of lost revenue to the U.S. Treasury, including underpaid Customs tariffs? A large importer recently found...more
11/17/2023
/ Anti-Discrimination Policies ,
CAATSA ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Export Controls ,
False Claims Act (FCA) ,
Forced Labor ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Importers ,
International Trade ,
Revenue ,
Russia ,
Whistleblowers
A veritable grab bag of international trade developments to parse this week. Recent developments include increasing FCPA enforcement, a record OFAC economic sanctions penalty, and a large customs penalty for willful failure...more
10/26/2023
/ Anti-Money Laundering ,
Audits ,
Compliance ,
Customs ,
Duties ,
Economic Sanctions ,
Enforcement ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Misclassification ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Valuation
The U.S. Government continues to send compliance messages in a variety of international trade areas. Recent developments include clarifications from the Court of International Trade regarding how country of origin is to be...more
10/16/2023
/ Anti-Dumping Duty ,
Compliance ,
Countervailing Duties ,
Court of International Trade ,
Customs ,
Enforcement ,
Export Controls ,
Forced Labor ,
Human Trafficking ,
International Trade ,
Supply Chain ,
U.S. Commerce Department ,
US Enforce and Protect Act (EAPA)
Recent developments include fair warning from the Department of Justice that national security concerns can invade even ordinary business activities, a reminder that the False Claims Act increasingly is being used as a weapon...more
6/22/2023
/ Antitrust Division ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement ,
Export Administration Regulations (EAR) ,
Export Controls ,
False Claims Act (FCA) ,
International Trade ,
National Security ,
U.S. Commerce Department ,
Voluntary Disclosure
Did you read this week’s article on supply chain integrity? If so, you won’t be surprised to see this week’s International Trade update includes a timely reminder regarding avoiding the use of forced labor in its supply...more
6/8/2023
/ Anti-Money Laundering ,
Compliance ,
Customs and Border Protection ,
Enforcement ,
Federal Trade Commission (FTC) ,
Forced Labor ,
International Trade ,
Jurisdiction ,
Made in the USA ,
Supply Chain ,
Tariffs
Recent developments include significant antitrust penalties, the issuance of CBP compliance guidance regarding the Uyghur Forced Labor Prevention Act, increasing emphasis on economic sanctions, “the new FCPA,” and the...more
5/25/2023
/ Anti-Corruption ,
Anti-Dumping Duty ,
Compliance ,
Cross Border Privacy Rules (CBPR) ,
Economic Sanctions ,
Enforcement ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Non-Compete Agreements ,
Uyghur Forced Labor Prevention Act (UFLPA)