News & Analysis as of

Tariffs False Claims Act (FCA) Supply Chain

Blank Rome LLP

Tariffs, Treble Damages, and Trade Enforcement: Surviving the New Era of Customs Crackdown

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The American trade landscape has transformed rapidly as the United States’ “America First” national-security platform reshapes international relations. New executive orders, proclamations, and memoranda issued under the...more

Morris, Manning & Martin, LLP

The Department of Justice's Criminal Division is Now Prioritizing Enforcement Related to Trade, Tariff, and Customs Fraud:...

On May 12, 2025, the U.S. Department of Justice’s (DOJ) Criminal Division released a memorandum containing the Trump Administration’s new white collar enforcement priorities. Consistent with the Administration’s heightened...more

Cooley LLP

DOJ Announces Priorities and Policy Updates – Including Tariff Compliance Enforcement, Expansion of Whistleblower Program

Cooley LLP on

Over the last year, we have paid close attention to the increasingly complicated and evolving landscape companies are facing in light of changing government enforcement priorities, including the Department of Justice’s...more

Foley & Lardner LLP

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

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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

Cooley LLP

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

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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

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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

White & Case LLP

Life Science Private Equity Risk

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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

Troutman Pepper Locke

Recent DOJ Intervention Highlights FCA Use Against Customs Fraud

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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

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

Cooley LLP

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

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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

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

Foley & Lardner LLP

What Every Multinational Company Should Know About … The Rising Risk of Customs False Claims Act Actions in the Trump...

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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

Dorsey & Whitney LLP

DOJ Intends to “Aggressively” Enforce the False Claims Act During Second Trump Administration

Dorsey & Whitney LLP on

Deputy Assistant Attorney General Michael Granston laid out the Department of Justice’s (“DOJ”) priorities over the next four years at the Federal Bar Association’s annual qui tam conference in Washington, D.C. last week....more

Ropes & Gray LLP

Customs Fraud May Bring a New Wave of False Claims Act Cases

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On February 1, 2025, President Trump imposed 25% tariffs on most imports from Canada and Mexico, as well as 10% tariffs on Canadian energy products and imports from China. The primary immediate impact of the new tariffs will...more

Ballard Spahr LLP

Tariff Compliance Under the New Trump Administration

Ballard Spahr LLP on

In his first two weeks back in office, President Donald Trump signaled his administration will impose new tariffs as part of his economic agenda, urging businesses to comply with U.S. trade policies to avoid severe penalties...more

American Conference Institute (ACI)

[Event] 12th Advanced Forum on Import Compliance & Enforcement - November 7th - 8th, Washington, DC

Back by popular demand! Join U.S. imports/customs controls experts and supply chain professionals at ACI’s Advanced Forum on Import Compliance and Enforcement, taking place November 7–8, 2023, in Washington, D.C....more

Husch Blackwell LLP

International Trade Law: 2021 Year in Review & Outlook for 2022

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Husch Blackwell’s third-annual international trade law year-in-review report provides a detailed look at how 2021 played out and takes a peek at how 2022 might develop. As companies begin to strategize on what a second year...more

Hogan Lovells

ADG Insights: Managing the ADG supply chain in the age of protectionism

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Through ADG Insights, we share with you the top legal and political issues affecting the aerospace, defense, and government services (ADG) industry. Our ADG industry team monitors the latest developments to help our clients...more

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