News & Analysis as of

Customs and Border Protection Department of Justice (DOJ) Enforcement Actions

Oberheiden P.C.

10 Key Facts About the DOJ’s Crackdown on Tariff Evasion

Oberheiden P.C. on

The U.S. Department of Justice (DOJ) and U.S. Customs and Border Protection (CBP) are cracking down on tariff evasion. The DOJ has expressly stated that exposing and prosecuting tariff evasion schemes is among its top...more

K&L Gates LLP

Trump DOJ Elevating Criminal Prosecution of Tariff Evasion

K&L Gates LLP on

As part of the Trump administration’s broad repositioning of US international trade policy toward higher tariffs and enhanced customs enforcement, on 12 May 2025, the head of the Criminal Division of the Department of Justice...more

ArentFox Schiff

Investigations Newsletter: Patio Furniture Firm Pays Millions for Dodging Import Duties

ArentFox Schiff on

Patio Furniture Firm Pays Millions for Dodging Import Duties - Grosfillex Inc., a Pennsylvania-based patio furniture company, has agreed to pay $4.9 million to resolve allegations that it violated the False Claims Act...more

Shook, Hardy & Bacon L.L.P.

DOJ Announces Unit to Prosecute Criminal Customs and Trade Fraud

Escalating what has already been a strong focus on combating customs and trade fraud in President Donald Trump’s second administration, on July 10, 2025, the Department of Justice announced it would be devoting significant...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

Holland & Knight LLP

Importers Beware: Signals Point to Significant Enforcement Risks for Tariff Evasion

Holland & Knight LLP on

As importers await outcomes from the Trump Administration's trade negotiations, a series of newly imposed tariffs continues to impact a broad spectrum of imported products and related supply chains. Businesses are currently...more

The Volkov Law Group

Landmark Ninth Circuit Ruling Expands Application of False Claims Act to Trade Enforcement (Part II of II)

The Volkov Law Group on

DOJ’s ability to bring False Claims Act actions against companies for customs fraud was affirmed in a significant Ninth Circuit decision, United States ex rel. Island Industries Inc. v. Sigma Corp., No. 22‑55063, __ F.4th __...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

The Volkov Law Group

Episode 376 -- DOJ's Unicat Settlement and the Future Look of Trade Enforcement Actions

The Volkov Law Group on

What happens when a company inherits a sanctions violation through acquisition, and acts fast to fix it? Can a robust post-acquisition response really save a parent company from prosecution? In this episode, Michael...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

Stinson LLP

Possible Relief from New Tariffs — and Risks to Avoid

Stinson LLP on

Tariffs have been in the news almost daily. Not only have tariff rates changed repeatedly, but the deadlines around implementation are subject to change. Meanwhile, the list of new commodities that are subject to additional...more

The Volkov Law Group

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A...

The Volkov Law Group on

In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies...more

Blank Rome LLP

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

Blank Rome LLP on

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

Warner Norcross + Judd

DOJ Announces “New Page” in White Collar and Corporate Enforcement

Warner Norcross + Judd on

Matthew Galeotti, head of the Department of Justice’s (DOJ) Criminal Division announced in May that DOJ “is turning a new page on white-collar and corporate enforcement.” The same day, the Criminal Division circulated four...more

The Volkov Law Group

Criminal Liability and Tariff and Trade Enforcement

The Volkov Law Group on

Tariff and trade violations are on DOJ’s radar screen.  No question but starting with Customs and Border Patrol we can expect that regulatory investigations and enforcement actions will increase.  Along with that — you can...more

The Volkov Law Group

False Claims and Trade Compliance: Enforcement Examples (Part III of III)

The Volkov Law Group on

In the prior post, I cited three significant risk areas for False Claims Act (“FCA”) risks and trade compliance: (1) Valuation; (2) Misclassification and (3) Country of Origin. On April 18, 2025, the United States filed a...more

The Volkov Law Group

A Dangerous Combination: False Claims Act and Trade Violations (Part II of III)

The Volkov Law Group on

As in every Administration, the Trump Department of Justice has made clear its enforcement priorities — government fraud, immigration and national security to include tariff and trade violations.  DOJ fully recognizes the...more

Kelley Drye & Warren LLP

DOJ Intervenes in Customs False Claims Act Case, Consistent with Administration’s Focus on Foreign Trade

The United States has intervened and filed a superseding complaint in a False Claims Act case originally filed by a whistleblower in the Eastern District of California. The Government’s complaint alleges that an importer and...more

Foley Hoag LLP

DOJ Announces New Priorities in White-Collar Criminal Enforcement: Targeting Waste, Fraud, and Abuse and Protecting American...

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The U.S. Department of Justice’s ("DOJ") Criminal Division recently issued a memorandum outlining a shift in the DOJ’s priorities and policies for prosecuting white-collar crime (the “Memorandum”). Issued by the Head of the...more

Vinson & Elkins LLP

Heightened False Claims Act Enforcement Risks Highlight the Importance of Compliance

Vinson & Elkins LLP on

Despite signs of a retrenchment in some of the traditional areas of white collar enforcement under the Trump administration, the U.S. Department of Justice’s (“DOJ”) enforcement of the civil False Claims Act (“FCA”) appears...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

Cranfill Sumner LLP

DOJ Invites Whistleblowers to Report Tariff Fraud

Cranfill Sumner LLP on

On May 12, 2025, head of the Department of Justice Criminal Division Matthew Galeotti delivered a speech in which he stated that the Department augmented its corporate whistleblower program to prioritize the following subject...more

Cooley LLP

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

Cooley LLP on

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

Seward & Kissel LLP

Undervalue at Your Own Risk: The False Claims Act Comes for Imports

Seward & Kissel LLP on

While some enforcement areas have taken a pause this year, False Claims Act enforcement—especially around customs duties—is moving and likely to get busier. Just last week the U.S. Department of Justice filed a complaint...more

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