This Memorial Day marks 35 years since Jim Henson, creator of the Muppets, passed away. Among his many accomplishments, the Muppets were essential to the creation of the longest-running children’s television show, “Sesame...more
Our previous article on What Every Multinational Company Should Know About … Customs Enforcement and False Claims Act Risks (Part I) outlined how import-related risks have substantially increased given the combination of the...more
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
So, just before Easter, in 1957, a little book you may have heard of, called The Cat in the Hat, made its first appearance. Theodore Geisel — writing under the name “Dr. Suess” — later said that of all his children’s books,...more
4/18/2025
/ Anti-Corruption ,
Bribery ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Corporate Governance ,
Ethics ,
Export Controls ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Sanctions
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
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
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
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
Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more
3/7/2025
/ Anti-Money Laundering ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Management ,
Supply Chain
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 Trump seeks to raise U.S. tariffs (which currently tend to be among the lowest worldwide), manufacturers, distributors, retailers, and other companies that frequently import (“importers”) must determine the best strategy...more
2/18/2025
/ China ,
Compliance ,
Customs and Border Protection ,
Forced Labor ,
Human Trafficking ,
Imports ,
Risk Management ,
Supply Chain ,
Tariffs ,
Trade Wars ,
Trump Administration ,
US Trade Policies ,
Uyghur Forced Labor Prevention Act (UFLPA)
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
So, for those of you who missed last year’s “The Grinch Who Stole Compliance,” never fear: We have an endless supply of compliance-related holiday mirth. After all, who doesn’t like a bit of eggnog and the traditional singing...more
Regulators around the world are sending a consistent message to companies that operate or source internationally, which is that they must take ownership of their supply chains. In addition, multinational companies face...more
11/21/2024
/ Compliance ,
Due Diligence ,
Environmental Social & Governance (ESG) ,
Ethics ,
Forced Labor ,
Human Trafficking ,
Investors ,
Multinationals ,
Penalties ,
Reputational Injury ,
Risk Management ,
Slavery ,
Supply Chain
Ah, Halloween. The one day of the year where we celebrate non-compliance by masked, under-age workers. And as our long-time readers know — and if you are not, you know who you are and need to hang your head in shame — it...more
We have received requests to publish a comprehensive set of Customs and import compliance best practices that covers all aspects of importation and supply chain management. As part of this series, the topic this week is best...more
10/24/2024
/ Brokers ,
Compliance ,
Customs ,
Documentation ,
Duties ,
Fraud ,
Freight Forwarding ,
Importers ,
Multinationals ,
Recordkeeping Requirements ,
Regulatory Requirements ,
Risk Management ,
Supply Chain
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
Regulators have sent numerous messages that companies who source from abroad need to subject their entire supply chain to extensive due diligence, based on state-of-the-art compliance measures to minimize supply chain risks....more
We have received several requests to publish a list of red flags pertinent to multinational organizations. To accommodate these requests, we are publishing a three-part series on anticorruption, export controls and economic...more
3/21/2024
/ Anti-Corruption ,
Buyers ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Multinationals ,
Regulatory Agenda ,
Risk Management ,
Sellers ,
Supply Chain ,
U.S. Commerce Department
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)
Both enforcement agencies and consumers increasingly are focused on manufacturers’ supply chains. Human rights enforcement frameworks increasingly have real teeth. Both the United States and the European Union either have, or...more
6/8/2023
/ Compliance ,
Consumers ,
Country of Origin ,
Due Diligence ,
Enforcement ,
EU ,
Human Rights ,
Manufacturers ,
Modern Slavery Act ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Slavery ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA)
As the global economy faces the third year of the pandemic, manufacturers are no longer focused on figuring out when things will return to “normal.” Instead, they are applying lessons learned from the past few years to become...more
7/7/2022
/ Artificial Intelligence ,
Audits ,
BPA ,
China ,
Climate Change ,
Compliance ,
Consumer Product Safety Commission (CPSC) ,
Copyright ,
Coronavirus/COVID-19 ,
Customs and Border Protection ,
Disclosure Requirements ,
Due Diligence ,
Environmental Social & Governance (ESG) ,
Ethics ,
False Advertising ,
Food and Drug Administration (FDA) ,
Greenhouse Gas Emissions ,
Greenwashing ,
Human Rights ,
ICFR ,
Internet of Things ,
Investment ,
Liability ,
Machine Learning ,
Manufacturers ,
Mexico ,
Model Contract Clauses ,
NLRA ,
NLRB ,
Office of Foreign Assets Control (OFAC) ,
Patents ,
PFAS ,
Popular ,
Proposed Rules ,
Remote Working ,
Risk Management ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Supply Chain ,
Supply Shortages ,
Sustainability ,
Task Force on Climate-related Financial Disclosures (TCFD) ,
Trade Secrets ,
Unions ,
United States-Mexico-Canada Agreement (USMCA) ,
Uyghur Forced Labor Prevention Act (UFLPA)