News & Analysis as of

Tariffs Customs and Border Protection Department of Justice (DOJ)

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

Foley & Lardner LLP

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

Foley & Lardner LLP on

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

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

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

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

American Conference Institute (ACI)

[Event] Trade & Sanctions Compliance for the Oil and Gas Industry - May 21st - 22nd, Houston, TX

Between tariffs, tightening export controls, evolving sanctions, and ramped up enforcement, the cost and complexity of compliance is rising for oil and gas supply chains. ACI’s Trade & Sanctions Compliance for the Oil and...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

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

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

Foley & Lardner LLP

What Every Multinational Company Needs to Know About … Criminal Enforcement of Trade, Import, and Tariff Rules: A Growing Risk for...

Foley & Lardner LLP on

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

BakerHostetler

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

BakerHostetler on

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

Secretariat

Trump Tariffs Raise False Claims Act Risks as Customs Enforcement Increases

Secretariat on

During his 2024 presidential campaign, Donald Trump made tariffs a cornerstone of his foreign and domestic policy. With new 25% tariffs now imposed on Mexico and Canada, along with an additional 10% tariff on imports from...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

Husch Blackwell LLP on

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...

Foley & Lardner LLP on

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

Morgan Lewis

US Administration Tariff Expansion, Potential False Claims Act Actions, and Other Enforcement Implications

Morgan Lewis on

With the second Trump administration holding the reins of the executive branch, companies should brace for a renewed focus on trade enforcement. The administration has already begun to expand tariffs on a variety of items...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

Braumiller Law Group, PLLC

Jurisdiction and History of Tariff Classification Litigation in the U.S

[Written by: Mike Smiszek, Senior Trade Advisor, Braumiller Consulting Group] Several tribunals and courts were established at various periods of America’s history to resolve trade-related litigation, both at the trial and...more

Adams & Reese

International Compliance Digest – November 2024

Adams & Reese on

While the incoming administration has blanketed the news cycle with newly threatened tariffs against typical targets like China, and against neighboring allies like Canada and Mexico, the current administration has quietly...more

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