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Tariffs International Trade 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

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

Foley & Lardner LLP

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

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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

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

Paul Hastings LLP

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

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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

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

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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

Wiley Rein LLP

DOJ Affirms Aggressive False Claims Act Enforcement, Highlights Use Against Illegal Trade Practices

Wiley Rein LLP on

The head of the U.S. Department of Justice (DOJ) branch that oversees False Claims Act (FCA) investigations affirmed the Trump Administration’s commitment to pursue civil fraud cases as part of its focus on achieving...more

Bass, Berry & Sims PLC

Update on Tariffs: Vigorous Enforcement Likely Amidst Uncertainty

Bass, Berry & Sims PLC on

In the roughly four weeks since his inauguration, President Trump has announced then paused tariffs on Canada and Mexico, expanded tariffs on steel and aluminum, and suggested introducing reciprocal tariffs on the rest of the...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

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

Foley & Lardner LLP

What Every Multinational Organization Should Know About ... Customs

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The international trade and regulatory environment never has been more difficult for multinational corporations to navigate. For companies that operate, source from, or sell goods, software, or services across borders, legal...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

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