News & Analysis as of

Criminal Prosecution Tariffs False Claims Act (FCA)

Morrison & Foerster LLP

DOJ Deploys Specialized Criminal Unit to Target Tariff Evaders

The United States Department of Justice (DOJ) has deployed its Market Integrity and Major Frauds Unit to target tariff evasion, a clear sign of the escalation of trade enforcement. The Criminal Division’s specialized unit,...more

Morgan Lewis

DOJ Shifts Focus of Enforcement Efforts to Tariff Evasion

Morgan Lewis on

As the US administration has imposed and modified tariffs on key trading partners, the US Department of Justice has turned its focus to criminally prosecuting companies and individuals for tariff evasion....more

Womble Bond Dickinson

[Webinar] Compliance Priorities for In-House Counsel: Responding to Latest DOJ Priorities & Guidance - August 5th, 3:00 pm - 4:00...

Womble Bond Dickinson on

Join us for an informative webinar providing the latest updates on key compliance issues under the current administration. Our panel will address recent developments in tariffs, the FCPA, False Claims Act, and sanctions....more

Hogan Lovells

Imports and the False Claims Act: Recent Ninth Circuit decision reflects trends in increased import fraud enforcement and...

Hogan Lovells on

The Ninth Circuit’s recent decision in Island Industries Inc. v. Sigma Corporation, coupled with recent government pronouncements concerning trade enforcement, are likely to drive an increase in customs fraud FCA...more

ArentFox Schiff

Investigations Newsletter: Co-Founder and Accountant of Leading Special Needs Trusts Charged in $100 Million Alleged Fraud Scheme

ArentFox Schiff on

Earlier this week, the government unsealed an indictment against Leo Joseph Govoni, the co-founder of the nonprofit Center for Special Needs Trust Administration (CSNT), and John Leo Witeck, an accountant for CSNT, charging...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

The Volkov Law Group

DOJ Applies False Claims Act to Tariff and Trade Violations (Part I of III)

The Volkov Law Group on

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

Sheppard Mullin Richter & Hampton LLP

Department of Justice Tariff Enforcement Likely to Surge After Tariff Increases and the Administration’s Increased Focus on...

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

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

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

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

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

Dorsey & Whitney LLP

Importer and Its Executives Pay $5.2 Million Under FCA for Evading U.S. Tariffs

Dorsey & Whitney LLP on

An importer recently agreed to pay $5.2 million to settle a False Claims Act (“FCA”) case alleging evasion of antidumping duties (“AD”) on wooden bedroom furniture from China. The importer, Blue Furniture Solutions, LLC (now...more

King & Spalding

Trade & Manufacturing - News of Note - January 2016

King & Spalding on

United States Repeals Country of Origin Labeling Legislation, Avoiding Retaliation - On December 18, President Obama signed a bill that repealed legislation requiring country of origin labeling (COOL) on beef and pork...more

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