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Tariffs False Claims Act (FCA)

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

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

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

White & Case LLP

Life Science Private Equity Risk

White & Case LLP on

Private Equity focused on investment and operations within the Life Science industry faces significant compliance, operational and business risk due to the heavily regulated nature of the investment targets and portfolio...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

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

WilmerHale

Enforcement Round Up: What Trump Administration Priorities Mean for Enforcement Against European Companies

WilmerHale on

Since the beginning of his second term, President Donald Trump has implemented policy changes in accordance with top administration priorities that are likely to significantly alter the enforcement landscape for non-U.S....more

ArentFox Schiff

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

ArentFox Schiff on

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

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

Paul Hastings LLP

New Trump Administration Tariffs Fundamentally Change Global Trading System, Raise Commercial and Compliance Risks

Paul Hastings LLP on

On April 2, 2025, the Trump administration announced the rollout of its “Reciprocal Tariff Policy,” which on April 5 will effect a blanket 10% ad valorem duty on all articles imported into the U.S. from approximately 185...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

DLA Piper

Settlement Further Signals New Surge of Reverse False Claims Act Cases Related to Customs Fraud

DLA Piper on

The United States Department of Justice (DOJ) recently announced a significant settlement that underscores the federal government’s increasing appetite to rely on the False Claims Act to address alleged customs fraud....more

Zuckerman Spaeder LLP

What to Expect in Consumer Protection in the New Administration

Zuckerman Spaeder LLP on

At the 2025 American Bar Association (“ABA”) White Collar Crime Institute in Miami, industry veterans forecasted the new Trump Administration’s white collar objectives by examining trends during the first Trump presidency. In...more

Hinckley Allen

Enforcement Outlook Under the Second Trump Administration: How Trump’s Priorities Will Impact White-Collar Enforcement Actions

Hinckley Allen on

With every change in administration, organizations and individuals face changes in the types of conduct the federal government focuses on in its investigations, enforcement, and criminal prosecutions. ...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

Morrison & Foerster LLP

DOJ Signals Continued Robust Enforcement of the False Claims Act In the New Administration

This year, at the Federal Bar Association’s (FBA) annual Qui Tam Conference, United States Department of Justice (DOJ) leadership confirmed that DOJ will remain committed to aggressive enforcement of the False Claims Act...more

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