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Customs and Border Protection Corporate Counsel

Davis Wright Tremaine LLP

Federal Appeals Court Rules Set of Trump Tariffs Unlawful: What Importers Need to Know

On Friday evening, August 29, 2025, as Americans settled into the beginning of a long holiday weekend, the U.S. Court of Appeals for the Federal Circuit released its highly anticipated opinion in V.O.S. Selections, Inc. v....more

Troutman Pepper Locke

DOJ and DHS Launch Cross-Agency Trade Fraud Task Force

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On August 29, 2025, the U.S. Department of Justice (DOJ) announced the formation of a cross-agency Trade Fraud Task Force in partnership with the Department of Homeland Security (DHS). This initiative is designed to...more

DLA Piper

False Claims Act Usage Continues to Rise in US Tariff Enforcement Context

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In the first eight months of 2025, the US Department of Justice (DOJ) announced four significant settlements involving allegations of knowingly and improperly evading customs duties on imports under the False Claims Act...more

Ropes & Gray LLP

US and EU Agree on Trade Framework Agreement – Implications for ESG/CSR Compliance

Ropes & Gray LLP on

On August 21, the US and EU announced that they have agreed on a Framework on an Agreement on Reciprocal, Fair, and Balanced Trade. The Framework Agreement expands upon earlier official statements on the US-EU trade deal and...more

Foley & Lardner LLP

Tariffs and Your Contracts: Why does the "importer of record" provision matter?

Foley & Lardner LLP on

To ascertain which party in a commercial contract is responsible for tariffs, it is important to check whether the contract specifies the importer of record....more

Foley & Lardner LLP

What Every Multinational Should Know About … the Use of Reshoring to Navigate Tariff Uncertainty

Foley & Lardner LLP on

The global manufacturing landscape is undergoing a fundamental shift. In recent years, reshoring — at times discussed more conceptually than executed in practice — has evolved into a strategic response to a range of complex...more

Husch Blackwell LLP

The Risks of Trade-Related FCA Enforcement

Husch Blackwell LLP on

In March 2025, in a similar blog post to this one, Nithya Nagarajan and Robert Romashko forecasted that False Claims Act (“FCA”) enforcement would increase under the current tariff-focused trade policy regime. Sure enough,...more

Troutman Pepper Locke

With New Tariffs, Recent Settlements May Foreshadow Future DOJ Enforcement

Troutman Pepper Locke on

The Trump administration’s implementation of tariffs on August 7, 2025, will have profound implications for companies engaged in international supply chains. These tariffs are poised to increase business costs, affecting a...more

Blank Rome LLP

The Frontline is Everywhere: What General Counsel Need to Know About the Department of Justice’s Strategic Pivot Toward Customs...

Blank Rome LLP on

Introduction - The U.S. Department of Justice (“DOJ”) has announced a significant realignment of resources that will fundamentally reshape criminal enforcement of international trade rules. By combining senior prosecutors...more

McDermott Will & Schulte

DOJ complaint underscores Trump administration’s use of the FCA to enforce US trade laws

A recent complaint – U.S. ex rel. Joyce v. Global Office Furniture, LLC, et al. – marks one of the Trump administration’s first publicly filed False Claims Act (FCA) enforcement actions focused on tariff evasion. In its July...more

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

Fisher Phillips

How Will Employers Be Impacted by the Big Beautiful Bill? A Recap of Key Workplace Provisions in The New Federal Budget

Fisher Phillips on

Don’t have the energy to slog through the 1,127 (or so) pages of the legislative text, amendments, and explanatory materials that comprise the final version of the “Big Beautiful Bill” to see how it impacts labor and...more

Mintz

Dodging Duties: The Ninth Circuit Affirms an Expansive Application of the False Claims Act Consistent with Trump Administration...

Mintz on

On June 23, 2025, the United States Court of Appeals for the Ninth Circuit affirmed a district court judgment in a case in which the jury found the defendant knowingly made false statements on customs forms to avoid paying...more

DLA Piper

Ninth Circuit Holds Private Parties Can Bring Claims Against Importers Under the False Claims Act for Antidumping Duty Evasion

DLA Piper on

The United States Court of Appeals for the Ninth Circuit has issued a significant ruling with potentially far-reaching consequences for companies that import merchandise, including but not limited to those subject to...more

Constangy, Brooks, Smith & Prophete, LLP

New USCIS Guidance overhauls TN visa requirements

The USCIS has issued new guidance in its Policy Manual, which updates the eligibility criteria for TN professionals under the United States-Mexico-Canada Agreement, also known as the “USMCA.” This guidance outlines...more

BCLP

Importers Who Paid IEEPA Tariffs That Were Later Ruled Unlawful Seek Refunds

BCLP on

Markets plunged earlier this year upon President Trump’s announcement of steep tariffs on imports to the U.S. from its trading partners, at rates varying from 10% to 125% depending on the country of the imported goods’...more

Husch Blackwell LLP

CBP Issues Guidance on Prioritization of Articles “Subject to” More Than One Tariff Under EO 14289

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On May 15, 2025, U.S. Customs and Border Protection (“CBP”) issued further guidance via the Cargo Systems Messaging Service (“CSMS”) for determining the order in which the various tariffs will apply to an article when that...more

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

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

Sheppard Mullin Richter & Hampton LLP

Not What You Think: Some Trump Tariffs Exempt Your Goods from Other Trump Tariffs

Some importers are finding, to their surprise, that the Trump Administration’s 25% tariffs on aluminum and steel create an exemption from the 125% tariffs on Chinese goods. The Trump tariff agenda has been complex, to say...more

Pillsbury Winthrop Shaw Pittman LLP

Comparing Developments in U.S. and EU Strategies to Combat Forced Labor

In recent years, a multinational focus on preventing forced labor within supply chains has shaped due diligence requirements for companies worldwide. Recent changes to global policies and potential shifts in enforcement...more

Torres Trade Law, PLLC

Trump Tariff Survival Guide

With U.S. trade policy constantly evolving and Customs enforcement increasing, importers face more pressure than ever to ensure customs compliance from the beginning. One misstep – whether it is a misclassified product, an...more

Husch Blackwell LLP

Customs Issues Guidance on Reporting Requirements for Reciprocal Tariffs and New Section 232 FAQs

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On April 8, 2025 U.S. Customs and Border Protection (“CBP”) issued a Cargo Systems Messaging Service (“CSMS”) Message # 64680374which sets forthadditional guidance on the reporting of reciprocal tariffs set to take effect on...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … The Global and Reciprocal Tariffs Announcement

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On April 2, 2025, President Trump implemented the steepest American tariffs in over a century. The implications for numerous multinational companies — including importers, manufacturers, distributors, and retailers — will be...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

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