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
6/10/2025
/ Corporate Counsel ,
Customs ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Fraud ,
Imports ,
Manufacturers ,
Risk Management ,
Supply Chain ,
Tariffs ,
White Collar Crimes
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
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
4/25/2025
/ Anti-Dumping Duty ,
Classification ,
Compliance ,
Countervailing Duties ,
Country of Origin ,
Customs and Border Protection ,
Duty Free ,
Enforcement Actions ,
False Claims Act (FCA) ,
Free Trade Agreements ,
Imports ,
International Trade ,
Misclassification ,
Misrepresentation ,
Penalties ,
Risk Management ,
Tariffs ,
Valuation
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
4/10/2025
/ Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement ,
False Claims Act (FCA) ,
Imports ,
International Trade ,
Multinationals ,
Penalties ,
Risk Management ,
Settlement ,
Tariffs
A recent United States Department of Justice (DOJ) announcement reinforces that enforcement of cybersecurity requirements under the False Claims Act (FCA) remains an ongoing risk. According to the press release, defense...more
4/4/2025
/ Compliance ,
Corporate Counsel ,
Cybersecurity ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Contractors ,
NIST ,
Qui Tam ,
Risk Management ,
Settlement ,
Subcontractors
Although the change in administrations has heralded shifting enforcement priorities at the U.S. Department of Justice (DOJ), cybersecurity enforcement under the False Claims Act (FCA) appears to be alive and well. That is the...more
3/4/2025
/ Compliance ,
Corporate Counsel ,
Cybersecurity ,
Data Security ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Enforcement ,
False Claims Act (FCA) ,
Federal Contractors ,
Health Care Providers ,
Risk Management ,
TRICARE
On Monday, September 23, DOJ’s Criminal Division announced updates to its guidance for evaluating corporate compliance programs (“ECCP”). Principal Deputy Assistant Attorney General Nicole Argentieri also delivered remarks...more
9/27/2024
/ Anti-Retaliation Provisions ,
Artificial Intelligence ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Emerging Technologies ,
Incentives ,
Penalties ,
Risk Assessment ,
Risk Management ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Protection Policies ,
Whistleblowers