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Enforcement Actions International Trade Penalties

Snell & Wilmer

New Reciprocal Tariff Rates Announced, but the Real Risk Is Hidden: Transshipment Enforcement Now Comes With an Additional 40%...

Snell & Wilmer on

On July 31, 2025, President Trump issued a new Executive Order modifying the reciprocal 10% global tariff introduced earlier this year. The revised rates impose differentiated tariffs by country, ranging from 10% to over 40%....more

Paul Hastings LLP

Addressing Gaps and Inconsistencies in the EU Sanctions’ Enforcement: The Commission Urges Member States to Transpose Directive...

Paul Hastings LLP on

Since Russia’s invasion of Ukraine in February 2022, the European Union has adopted 18 packages of sanctions targeting Russia and Belarus, with the latest on July 19, 2025. In total, the EU has about 40 different sanctions...more

Stankie Law

OFAC Fines Harman International $1.4 Million for Iran Sanctions Violations

Stankie Law on

On July 8, 2025, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Harman International Industries, Inc. (“Harman”) for $1,454,145 to settle potential civil...more

The Volkov Law Group

Episode 379 -- Update on False Claims Act and Customs Evasion Liability

The Volkov Law Group on

A competitor could trigger a federal investigation against your company, just by filing a whistleblower complaint about your imports. In this episode, Michael Volkov explores how the Trump Administration is reshaping the...more

The Volkov Law Group

Interactive Brokers Settles with OFAC for $11.8 Million for Violations of Multiple Sanctions Programs

The Volkov Law Group on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced on July 15, 2025, that Interactive Brokers LLC (“IB”)—a globally active electronic brokerage firm headquartered in Greenwich,...more

The Volkov Law Group

Episode 378 -- Update on Export Controls and Sanctions Enforcement

The Volkov Law Group on

What happens when companies ignore red flags, bypass legal advice, and underestimate the reach of U.S. export laws? In this episode, Michael Volkov unpacks two major enforcement actions from the Department of Commerce’s...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

The Volkov Law Group

The False Claims Act and Trade Enforcement (Part I of II)

The Volkov Law Group on

The Trump Administration intends to leave a strong enforcement mark on fraud and trade enforcement. DOJ is linking together trade enforcement and False Claims Act cases in an unprecedented manner that will open up new...more

The Volkov Law Group

BIS Levies $4.25 Million Penalty Against Alpha and Omega Semiconductor for Unauthorized Exports to Huawei

The Volkov Law Group on

On June 27, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order resolving administrative enforcement proceedings against Alpha and Omega Semiconductor Incorporated (“AOS”), a...more

Foley & Lardner LLP

Ninth Circuit Slams Importer in a False Claims Act Case Involving the Knowing Avoidance of Antidumping Duties

Foley & Lardner LLP on

A recent Ninth Circuit decision underscores why importers should be worried that they will be hit with a large government bill under the False Claims Act (FCA) to pay for newly raised duties imposed on imported products. The...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

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

Foley Hoag LLP - White Collar Law &...

Are there ways to reduce the customs value of goods and thereby reduce tariffs?

In this article, the third in our blog series on U.S. tariffs (check out the other two pieces on origination and classification), we continue to spotlight high-risk tariff practices and potential enforcement consequences. ...more

The Volkov Law Group

Episode 369 -- Stepping Into the Enforcement Spotlight -- Customs and Border Patrol and Import Enforcement

The Volkov Law Group on

What if your next import shipment becomes the centre of a federal enforcement action — not because of criminal intent, but because of a mistake? In today’s episode, Michael Volkov breaks down the expanding power and reach of...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

The Volkov Law Group

Stepping Into the Enforcement Spotlight — Customs and Border Patrol and Import Enforcement (Part I of II)

The Volkov Law Group on

The Trump Administration is committed to a re-defined objective of fair trade. This will have a significant impact on all businesses, across all operational functions. This is not surprising — for years, the United States...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … Customs Enforcement and False Claims Act Risks (Part II)

Foley & Lardner LLP on

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

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

Dorsey & Whitney LLP

The Trump Administration’s Sweeping New Tariffs Heighten False Claims Act Risks for U.S. Importers

Dorsey & Whitney LLP on

As the business community adjusts to the reality of the Trump Administration’s sweeping new tariff regime, importers and other organizations that rely on imports should be mindful that with the expansion and sharp increases...more

WilmerHale

UK, French, and Swiss Enforcement Authorities Announce New Alliance

WilmerHale on

Anti-bribery and corruption agencies in the UK, France and Switzerland today announced a shared commitment to tackling international bribery and corruption, by way of a new taskforce intended to strengthen collaboration....more

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more

Foley Hoag LLP

CFIUS Year in Review

Foley Hoag LLP on

CFIUS reviewed a record number of transactions in 2021 according to its most recent annual report – and shows no signs of slowing down. High technology (including quantum computing), life sciences, and green energy...more

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