News & Analysis as of

Customs and Border Protection Enforcement Actions

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

Foley Hoag LLP - White Collar Law &...

Are there ways to reduce the customs value of goods and thereby reduce tariffs?

In this article, the third in our blog series on U.S. tariffs (check out the other two pieces on origination and classification), we continue to spotlight high-risk tariff practices and potential enforcement consequences. ...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

Foley Hoag LLP

DOJ Announces New Priorities in White-Collar Criminal Enforcement: Targeting Waste, Fraud, and Abuse and Protecting American...

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The U.S. Department of Justice’s ("DOJ") Criminal Division recently issued a memorandum outlining a shift in the DOJ’s priorities and policies for prosecuting white-collar crime (the “Memorandum”). Issued by the Head of the...more

Vinson & Elkins LLP

Heightened False Claims Act Enforcement Risks Highlight the Importance of Compliance

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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

Sheppard Mullin Richter & Hampton LLP

Department of Justice Tariff Enforcement Likely to Surge After Tariff Increases and the Administration’s Increased Focus on...

A serious step up in civil and criminal enforcement of customs laws, including tariff evasion, is imminent. In a May 12 memorandum, the Department of Justice’s new Chief of the Criminal Division, Matthew Galeotti, counted as...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

The Volkov Law Group

Episode 369 -- Stepping Into the Enforcement Spotlight -- Customs and Border Patrol and Import Enforcement

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What if your next import shipment becomes the centre of a federal enforcement action — not because of criminal intent, but because of a mistake? In today’s episode, Michael Volkov breaks down the expanding power and reach of...more

Cooley LLP

Complaint Against Uniform Company for Customs Duties Underpayment Highlights False Claims Act Risks for Tariff Compliance

Cooley LLP on

As we discussed in this April 7 blog post, the US Department of Justice (DOJ) can pursue civil penalties for tariff evasion under the False Claims Act (FCA), including against companies that are aware of tariff evasion by...more

Vinson & Elkins LLP

The Trump Tariff Regime Brings Risks of Criminal and Civil False Claims Act Enforcement

Vinson & Elkins LLP on

On April 2, 2025, President Donald Trump announced a new tariff regime under the International Emergency Economic Powers Act of 1977 (“IEEPA”), citing national security concerns. This regime includes a 10 percent baseline...more

Foley Hoag LLP - White Collar Law &...

Can I Avoid New U.S. Tariffs by Routing Goods Through Different Countries? (Spoiler Alert: No)

With the recent surge in tariffs and imposition of differentiated tariffs for different countries of origin (i.e., higher tariffs for goods originating from China than from neighboring countries and potentially other...more

Husch Blackwell LLP

April 2025 Trade Law Update

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In Husch Blackwell’s April 2025 Trade Law Update you’ll learn about the following updates in international trade and supply chain law: • An update on U.S. Department of Commerce decisions • U.S. International Trade...more

The Volkov Law Group

Reviewing the CPB Enforcement Process Under 19 U.S.C. § 1592 (Part II of II)

The Volkov Law Group on

CPB’s administrative enforcement program is robust and increasing, especially with the importance of trade and tariff enforcement.  There are a lot of “ins and outs” (Big Lewbowski Here) to the administrative process which...more

The Volkov Law Group

Stepping Into the Enforcement Spotlight — Customs and Border Patrol and Import Enforcement (Part I of II)

The Volkov Law Group on

The Trump Administration is committed to a re-defined objective of fair trade. This will have a significant impact on all businesses, across all operational functions. This is not surprising — for years, the United States...more

Foley & Lardner LLP

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

Foley & Lardner LLP on

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

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

Troutman Pepper Locke

Recent DOJ Intervention Highlights FCA Use Against Customs Fraud

Troutman Pepper Locke on

With the Trump administration’s new tariffs, some companies may be looking for ways to compensate for increased costs of imports. Companies operating in the international supply chain must be aware that any attempts to...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

Mintz - Intellectual Property Viewpoints

Regulation, Enforcement, and Associated Challenges: Part II

Given the continued challenges in policing the burgeoning ENDS marketplace, as previously discussed in Part I of this article, in mid-2024 FDA and DOJ announced the establishment of a federal multi-agency task force to combat...more

Skadden, Arps, Slate, Meagher & Flom LLP

Regulatory Strategies To Combat Counterfeit Beauty Products

Increases in Counterfeit Beauty and Personal Care Products - The rise of e-commerce has led to increasing sales of counterfeit or noncompliant beauty and personal care products, including many that are knockoffs of...more

ArentFox Schiff

As the (Customs and Trade) World Turns: April 2025

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Welcome to the April 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

Mayer Brown

Heightened Enforcement Risks and Opportunities in International Trade

Mayer Brown on

On April 2, 2025, the Trump Administration imposed a sweeping new set of tariffs against imported goods as part of its efforts to remake the framework for international trade. ...more

Cooley LLP

Tariffs Are Here – Be Aware of Criminal and Civil Enforcement Risks

Cooley LLP on

On April 2, 2025, President Donald Trump, citing national security concerns, used authority granted under the International Emergency Economic Powers Act of 1977 (IEEPA) to announce a sweeping new tariff regime, with a 10%...more

Faegre Drinker Biddle & Reath LLP

Heightened False Claims Act Enforcement of Customs and Trade Violations

As the Trump administration forges ahead with its trade agenda, including almost weekly new tariffs, and antidumping and countervailing duties orders, heightened False Claims Act (FCA) enforcement is sure to follow. Below, we...more

Bass, Berry & Sims PLC

DOJ Settlement Highlights Customs, FCA Risks for Importers

On March 25, 2025, the U.S. Department of Justice (DOJ) announced an $8.1 million settlement in a civil case under the False Claims Act (FCA) related to alleged customs evasion by a California importer of wood flooring. The...more

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