News & Analysis as of

Enforcement Actions Tariffs

Dickinson Wright

Recent U.S. – China Tariff Tensions Spark Investigations by Chinese Authorities

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This spring, representatives from China’s Ministry of Commerce (“MOFCOM”) met with Walmart executives in China (“PRC”) to discuss allegations that Walmart had asked its Chinese suppliers to reduce prices or offer some sort of...more

Torres Trade Law, PLLC

White House Announces Steel and Aluminum Tariff Increase to 50%

On June 3, 2025, President Trump signed a Proclamation increasing Section 232 tariffs on steel and aluminum imports, including derivative articles, from 25% to 50% ad valorem. The increase follows the reinstatement and...more

Clark Hill PLC

New presidential proclamation doubles tariffs on steel and aluminum imports

Clark Hill PLC on

On June 3, President Trump issued a proclamation doubling tariffs on imports of steel and aluminum articles and derivative steel and aluminum articles from 25% to 50%, effective at 12:01 a.m. EDT on June 4. This action, taken...more

The Volkov Law Group

Criminal Liability and Tariff and Trade Enforcement

The Volkov Law Group on

Tariff and trade violations are on DOJ’s radar screen.  No question but starting with Customs and Border Patrol we can expect that regulatory investigations and enforcement actions will increase.  Along with that — you can...more

The Volkov Law Group

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

The Volkov Law Group on

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

Cozen O'Connor

The State AG Report – 05.29.2025

Cozen O'Connor on

Here are curated AG and federal regulatory news stories highlighting key areas in which state and federal regulators’ decisions are having an impact across the US: • NY Fights FAIR to Expand State Consumer Protection Law - ...more

The Volkov Law Group

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

The Volkov Law Group on

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 & Lardner LLP

U.S. and International Antitrust Agencies Signal Aggressive Antitrust Enforcement in Procurement, Consumer Products, and Labor...

Foley & Lardner LLP on

As we previously reported on April 15 and April 28, the Department of Justice (DOJ) and Federal Trade Commission (FTC) are increasingly monitoring companies for anticompetitive conduct in response to rising costs following...more

The Volkov Law Group

DOJ Applies False Claims Act to Tariff and Trade Violations (Part I of III)

The Volkov Law Group on

Never underestimate the creativity and ability of federal prosecutors to apply federal criminal laws to address “new” crimes or new enforcement programs. Corporate leaders and compliance officials are making a serious...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...

Foley Hoag LLP on

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

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

DOJ Expands Whistleblower Program to Include Tariffs, Sanctions and Export Controls (Part III of III)

The Volkov Law Group on

DOJ’s new Corporate Enforcement Program is designed to bring certainty to the voluntary disclosure and cooperation process.  DOJ’s intent is clear — voluntary disclosure is likely to lead to a declination, reduced penalties...more

Morgan Lewis

New Tariffs, Old Risks: Antitrust Considerations

Morgan Lewis on

With regulatory scrutiny by governments on the rise, this LawFlash summarizes key antitrust issues for companies in all industries affected by tariffs. History shows that cartels tend to form in times of rapid economic...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

Troutman Pepper Locke

FERC Enforces “Rule of Reason,” Requiring CAISO to Embed Business Practice Manual Provision in Tariff

Troutman Pepper Locke on

On April 29, 2025, FERC partially granted rehearing in the case of Cometa Energia, S.A. de C.V. (“Saavi”) against the California Independent System Operator Corporation (“CAISO”), finding a provision of CAISO’s Business...more

DLA Piper

The Second Trump Administration’s First 100 days

DLA Piper on

The first 100 days of the second Trump Administration have been marked by a flurry of Executive Orders (EOs) and policy memoranda intended to advance President Donald Trump’s “America First” agenda. In the process, these...more

Skadden, Arps, Slate, Meagher & Flom LLP

President Trump’s First 100 Days: Impacts and Projections

The first 100 days of a new administration sets the tone for policy direction and regulatory priorities. The following key takeaways from the Trump administration’s first three months highlight significant trends, shifts and...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

DLA Piper

Key Considerations for Compliance Officers Under President Trump

DLA Piper on

The Trump Administration has ushered in massive shifts in enforcement and policy priorities. From crypto to anti-corruption measures and tariffs to technology, the new Administration has changed the compliance landscape...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

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

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