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Customs and Border Protection Department of Justice (DOJ) International Trade

The Volkov Law Group

False Claims and Trade Compliance: Enforcement Examples (Part III of III)

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In the prior post, I cited three significant risk areas for False Claims Act (“FCA”) risks and trade compliance: (1) Valuation; (2) Misclassification and (3) Country of Origin. On April 18, 2025, the United States filed a...more

The Volkov Law Group

A Dangerous Combination: False Claims Act and Trade Violations (Part II of III)

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As in every Administration, the Trump Department of Justice has made clear its enforcement priorities — government fraud, immigration and national security to include tariff and trade violations.  DOJ fully recognizes the...more

Kelley Drye & Warren LLP

DOJ Intervenes in Customs False Claims Act Case, Consistent with Administration’s Focus on Foreign Trade

The United States has intervened and filed a superseding complaint in a False Claims Act case originally filed by a whistleblower in the Eastern District of California. The Government’s complaint alleges that an importer and...more

Vinson & Elkins LLP

Heightened False Claims Act Enforcement Risks Highlight the Importance of Compliance

Vinson & Elkins LLP on

Despite signs of a retrenchment in some of the traditional areas of white collar enforcement under the Trump administration, the U.S. Department of Justice’s (“DOJ”) enforcement of the civil False Claims Act (“FCA”) appears...more

Cranfill Sumner LLP

DOJ Invites Whistleblowers to Report Tariff Fraud

Cranfill Sumner LLP on

On May 12, 2025, head of the Department of Justice Criminal Division Matthew Galeotti delivered a speech in which he stated that the Department augmented its corporate whistleblower program to prioritize the following subject...more

Husch Blackwell LLP

Week Seventeen in Trade

Husch Blackwell LLP on

CBP Issues Facility Requirements for Bonded Warehouses In a Cargo Systems Messaging Service (“CSMS”) message, U.S. Customs and Border Protection (“CBP”) clarified that bonded warehouses, as defined in 19 C.F.R. § 19.1, do...more

Foley Hoag LLP - White Collar Law &...

Are There Legitimate Ways to Achieve More Advantageous Tariff Classifications?

With recent increases in U.S. tariffs and the increasing complexity of determining applicable duties for different products, importers are looking for ways to reduce their tariff exposure. Since a product’s tariff treatment...more

Seward & Kissel LLP

Undervalue at Your Own Risk: The False Claims Act Comes for Imports

Seward & Kissel LLP on

While some enforcement areas have taken a pause this year, False Claims Act enforcement—especially around customs duties—is moving and likely to get busier. Just last week the U.S. Department of Justice filed a complaint...more

Dorsey & Whitney LLP

The Trump Administration’s Sweeping New Tariffs Heighten False Claims Act Risks for U.S. Importers

Dorsey & Whitney LLP on

As the business community adjusts to the reality of the Trump Administration’s sweeping new tariff regime, importers and other organizations that rely on imports should be mindful that with the expansion and sharp increases...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … Customs Enforcement and False Claims Act Risks (Part I)

Foley & Lardner LLP on

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

BakerHostetler

Should You Consider a Voluntary Self-Disclosure for a Tariff Violation?

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Tariff evasion techniques such as transshipping goods through third countries, underreporting the value of goods, and mislabeling goods as other items subject to lower tariff rates have resulted in hundreds of billions of...more

WilmerHale

As Tariffs Increase, So Too May the Use of False Claims Actions to Pursue Customs Fraud

WilmerHale on

New trade policies—and particularly tariffs—are at the top of the agenda for President Donald Trump and his new Administration. Indeed, in his first weeks in office, President Trump has already imposed tariffs on major...more

Husch Blackwell LLP

FCA Enforcement May Increase In a Tariff Focused Trade Policy Regime

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The first seven weeks of the second Trump Administration has revealed that tariffs are going to be a primary tool in the administration’s trade arsenal to address both domestic and foreign trade policy goals. What is...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … The Rising Risk of Customs False Claims Act Actions in the Trump...

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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

ArentFox Schiff

Trump Tariffs: What Importers Need to Know About Customs Fraud and the Increased Use of the False Claims Act

ArentFox Schiff on

In addition to navigating the Trump Administration’s ever-changing international trade policy through the use of existing (e.g., Section 301, Section 232, etc.) and novel (e.g., International Emergency Economic Powers Act,...more

Quarles & Brady LLP

New Tariffs Mean New Targets of the False Claims Act

Quarles & Brady LLP on

The value of goods imported to the United States in Fiscal Year 2024 was $893.15 billion, and as a result, U.S. Customs and Border Protection (“CBP”) collected $24.37 billion in duties, taxes and fees for those imports. Given...more

BakerHostetler

Criminal Enforcement of the Trump Tariffs Is Likely - Here’s What It Will Look Like

BakerHostetler on

On Saturday, President Trump signed executive orders imposing stiff tariffs on three of the United States’ biggest trading partners. The orders impose a 25 percent tax on most imports from Canada and Mexico, while goods from...more

Torres Trade Law, PLLC

DOJ’s Increasing Role in the Enforcement of U.S. Trade Laws

Multiple federal agencies are charged with enforcing U.S. international trade and national security laws. These agencies include the Department of Commerce Bureau of Industry and Security (BIS) and the Department of State...more

Latham & Watkins LLP

The Guide to Anti-Money Laundering: Trade-Based Money Laundering and Terrorist Financing

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Trade-based money laundering (TBML) describes a set of techniques through which drug traffickers, terrorists and other criminals use the veneer of trade to move illicit funds across borders while disguising the origin and...more

Foley & Lardner LLP

International Trade, Enforcement & Compliance Recent Developments Update

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Recent developments include the U.S. government using novel legal theories to expand jurisdiction over banking activities outside the United States, the imposition of hundreds of millions of dollars of penalties on companies...more

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