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Matthew Galeotti, head of the Department of Justice’s (DOJ) Criminal Division announced in May that DOJ “is turning a new page on white-collar and corporate enforcement.” The same day, the Criminal Division circulated four...more
Last month, the Department of Justice put trade, customs, and tariff fraud squarely in the spotlight. This isn’t just another line item on the compliance checklist, it’s a loud-and-clear signal that import-related enforcement...more
Join us for an exclusive CLE-eligible live masterclass with cybersecurity, data privacy, and international trade professionals from Baker McKenzie and Ankura, where they will share how to implement a successful Data Security...more
What if your trade compliance misstep became tomorrow’s federal prosecution headline? In this episode, Michael Volkov issues a powerful warning to corporate leaders and compliance professionals: the DOJ is no longer treating...more
Here are a few recent legal updates from US and UK of relevance to Indian clients...more
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
In the current economic environment, where tariffs are being discussed, proposed, or implemented, with potential impact on many industries, companies are feeling pressure to rethink or adjust their pricing strategies....more
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
On May 28, 2025, a three-judge panel of the U.S. Court of International Trade (CIT) unanimously struck down the extensive tariffs imposed by President Trump under the International Emergency Economic Powers Act (IEEPA). The...more
On Wednesday, May 28, 2025, and Thursday, May 29, 2025, three significant court actions impacted the tariff and trade landscape....more
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
A three-judge panel of the United States Court of International Trade late Wednesday afternoon struck down the reciprocal tariffs imposed last month by the Trump administration....more
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
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
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
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
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
Welcome to this edition of the award-winning Everything Compliance. In this episode, the quartet of Matt Kelly, Jonathan Marks, Karen Moore, and Karen Woody is hosted by Tom Fox, the Compliance Evangelist. • Karen Moore...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
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
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
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
ACI's Global Anti-Corruption, Ethics & Compliance – New York is your best opportunity to hear how companies are addressing the status of DOJ and SEC priorities, effective compliance and risk strategies, strengthening...more
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
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