News & Analysis as of

Enforcement Actions Goods or Services

Hughes Hubbard & Reed LLP

$140M US Export Controls Enforcement Action for ‘Reason to Know, Including Awareness of a High Probability’ Violations

On July 28, the U.S. Department of Justice’s National Security Division and the Department of Commerce’s Bureau of Industry and Security (BIS) jointly announced resolutions of parallel criminal and administrative...more

Troutman Pepper Locke

DOJ Ramps Up Enforcement Efforts Targeting Tariff Evasion and Trade Fraud

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The U.S. Department of Justice (DOJ) has announced that it is expanding its enforcement priorities to include a focus on import-related fraud — particularly schemes aimed at evading U.S. tariffs and duties. This marks a...more

Jones Day

Landmark Enforcement Under U.S. CPSA Leads to Sentencing of Corporate Executives for Failure to Report Product Hazards

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In June 2025, two former executives were each sentenced to more than three years in prison for conspiracy and failure to report hazardous products to the U.S. Consumer Product Safety Commission ("CPSC"), marking the first...more

Fish & Richardson

Lack of Bona Fide Intent to Use Sends Alcohol Trademark Application Down the Drain

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In a recent precedential decision, the U.S. Trademark Trial and Appeal Board (TTAB) upheld an opposition by Tequila Cuadra S. de RL de CV (“Tequila Cuadra”) and denied an application filed by Manufacturera de Botas Cuadra,...more

Loeb & Loeb LLP

60 More Days for Click to Cancel

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Take a quick breath—but just a short one—because late Friday, the Federal Trade Commission (FTC) decided (3-0) to push the compliance date of its Negative Option (or "Click to Cancel") Rule, a regulation designed to make...more

Troutman Pepper Locke

Recent DOJ Intervention Highlights FCA Use Against Customs Fraud

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With the Trump administration’s new tariffs, some companies may be looking for ways to compensate for increased costs of imports. Companies operating in the international supply chain must be aware that any attempts to...more

Jones Day

ACCC Conducts Sweep of Online Statements for Compliance with Australian Consumer Law

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The Australian Competition and Consumer Commission ("ACCC") recently announced that it had conducted a sweep of more than 2,000 Australian retail websites that found some businesses' return policies and website terms and...more

Troutman Pepper Locke

Alaska Obtains Six-Figure Civil Penalty in Product Labeling Case

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Alaska’s Department of Law’s Consumer Protection Unit recently announced it obtained a Superior Court order issuing a $250,000 civil penalty against B. Merry Studio, which the state alleged to have marketed products as being...more

Secretariat

Trump Tariffs Raise False Claims Act Risks as Customs Enforcement Increases

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During his 2024 presidential campaign, Donald Trump made tariffs a cornerstone of his foreign and domestic policy. With new 25% tariffs now imposed on Mexico and Canada, along with an additional 10% tariff on imports from...more

Eversheds Sutherland (US) LLP

FTC says (uninformed) silence is not assent: “Click to cancel” final rule is here

On October 16, 2024, and by a 3-2 vote of its commissioners, the Federal Trade Commission (FTC) issued a broad-reaching final “click to cancel” rule (Rule), updating its Negative Option Rule, that could subject companies to...more

Perkins Coie

With Operation AI Comply, the FTC Steps Up AI Enforcement

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The Federal Trade Commission (FTC) recently announced several enforcement actions and proposed settlements as part of a new sweep it calls “Operation AI Comply.” These cases appear focused on companies that the FTC alleges...more

Troutman Pepper Locke

$11M Cigarette Drawback Dispute Could Have Significant Consequences for FTZ Importers

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In August, North Carolina-based cigarette importer, King Maker Marketing Inc., challenged a decision by U.S. Customs and Border Protection (Customs) that rejected its claims for more than $11 million in drawback duties as...more

Troutman Pepper Locke

Pennsylvania AG Sues Robotics Toy Company for Alleged Failure to Fulfill Prepaid Orders

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In September, Pennsylvania Attorney General (AG) Michelle Henry filed a lawsuit against Pittsburgh-based Digital Dream Labs, Inc., and its CEO, Harold Jacob Hanchar, individually and in his capacity as CEO. In the lawsuit,...more

The Volkov Law Group

Supply Chain Sanctions Liability — The Importance of Supply Chain Audits (Part III of IV)

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Global companies face significant risks in their supply chains of compliance with OFAC’s economic sanctions regime.  OFAC has emphasized the importance of conducting supply chain risk assessments and audits....more

Cohen & Gresser LLP

The Return of Price Discrimination Enforcement: What Every Business Needs to Know

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The rumors of the death of price discrimination enforcement may have been greatly exaggerated. The Robinson-Patman Act (“RPA”) (15 U.S.C. §13), enacted in 1936, prohibits price discrimination by producers and resellers of...more

Knobbe Martens

FTC Cracks Down on Deceptive Marketing: Old Southern Brass Faces Consequences for False Claims on “Made in USA” and Military...

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The Federal Trade Commission is cracking down on Florida-based EXOTOUSA LLC d/b/a Old Southern Brass and its owner (collectively, “OSB”) for deceptive claims regarding the origin of its products and its alleged financial...more

The Volkov Law Group

DOJ Resolves First Corporate Sanctions Case Involving Iran Sanctions Program

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The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message – companies are going to...more

Troutman Pepper Locke

Seven State AGs Announce Settlement With Robocallers

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On August 16, a coalition of seven state attorneys general (AG) announced a settlement with participants alleged to be involved in a “massive” robocall operation. The stipulated order, which names Scott Shapiro, Michael T....more

The Volkov Law Group

Murad Pays OFAC $3.3 Million for Iran Sanctions Violations; Former Senior Executive Pays $175k

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Over an eight-year period ending in 2018, Murad, a U.S. cosmetics company, illegally exported goods and services to Iran in 62 separate transactions worth approximately $11 million.  Murad was acquired by Unilever United...more

Orrick, Herrington & Sutcliffe LLP

FTC takes action against investment advisor, cites violations of Notice of Penalty Offenses

On January 13, the FTC announced an action against an investment advisor and its owners concerning allegations that the defendants made deceptive claims when selling their services to consumers. ...more

Venable LLP

The Pandemic May Be Over, but Price-Gouging Laws Live On

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​​​​​​​When the COVID-19 pandemic began, and consumers swarmed the stores for disinfectant sprays, masks, and household items, state price-gouging laws grew increasingly relevant as sellers sought to cash in on the heightened...more

Stinson LLP

Check Your LED Lighting Supplies and Construction Materials or It Could Cost You

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Recently the Federal Trade Commission entered into a settlement under which Patriot LED must pay civil damages of nearly $158,000, plus a penalty of $2.96 million, for its alleged false marketing of lighting products as...more

The Volkov Law Group

Global Logistics Company Settles OFAC Violations for $6.1 Million

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You have to wonder how OFAC has the time to investigate and settle cases given its significant work implementing the Russia Sanctions Program.  But OFAC continues to demonstrate its commitment to aggressive enforcement. ...more

Cadwalader, Wickersham & Taft LLP

FTC Sues to Block Lockheed’s Proposed Acquisition of Aerojet Rocketdyne in Milestone Defense Industry Vertical Challenge

The Federal Trade Commission (“FTC”) filed suit yesterday to block Lockheed Martin Corporation’s proposed $4.4 billion acquisition of Aerojet Rocketdyne Holdings Inc., announced back in December 2020. Aerojet, the last...more

Alston & Bird

Update Regarding the BrightSpeed Payment Processor Case

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On January 18, after approximately fourteen months of settlement negotiations, the CFPB announced that it secured a settlement agreement with BrightSpeed Solutions, Inc., a third-party payment processor that had ceased...more

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