False Claims Act Insights - Beyond Adversarialism: How to Steer FCA Investigations
Work This Way: A Labor & Employment Law Podcast | Compliance Clarity for Federal Contractors with Joan Moore and Mim Munzel of Arbor Consulting Group
Great Women in Compliance: LATAM Compliance Update with Alejandra Montenegro Almonte
AI and the False Claims Act
False Claims Act Insights - The Mathematics of Nuclear FCA Verdicts
Episode 379 -- Update on False Claims Act and Customs Evasion Liability
Everything Compliance: Episode 157, The Q2 2025 Great Women in Compliance Edition
Great Women in Compliance: The Compliance Influencer with Bettina Palazzo
Blowing the Whistle: What Employers Should Know About DEI & the False Claims Act
When DEI Meets the FCA: What Employers Need to Know About the DOJ’s Civil Rights Fraud Initiative
False Claims Act Insights - Bitter Pills: DOJ Targets Pharmacies for FCA Enforcement
False Claims Act Insights - Will Recent Leadership Changes Lead to FCA Enforcement Policy Changes?
Enforcement Priorities of the Second Trump Administration: The False Claims Act
Episode 372 -- DOJ Applies False Claims Act to Tariff and Trade Violations
False Claims Act Insights - How Payment Suspensions Can Impact FCA Litigation
False Claims Act Insights - Trump DOJ Sharpens Its Focus on Healthcare Fraud
False Claims Act Insights - DOJ’s Reliance on FCA to Pursue Covid-Related Fraud
UPIC Audits
Criminal Health Care Fraud Enforcement: Projections for 2025 and Beyond – Diagnosing Health Care Video Podcast
False Claims Act Insights - Stranger Than Fiction? An FCA April Fools’ Day Episode
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
In a recent post, we briefly explored potential insurance coverage for tariff- and trade-related losses, particularly in the context of escalating global trade tensions and U.S. enforcement trends. Since then, enforcement...more
As of midnight, a sweeping set of new tariffs is in effect. Many are country-specific or based on foreign policies targeting specific products from specific countries. Some of the tariffs going into effect are based on...more
The Department of Justice (DOJ) has recently begun an aggressive enforcement campaign targeting companies and individuals that attempt to circumvent U.S. tariffs, particularly those imposed under President Trump’s ongoing...more
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
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
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
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
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
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
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
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
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
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
Welcome to the July 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
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
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
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 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 Ninth Circuit Court of Appeals in Island Industries v. Sigma Corp., upheld a lower court jury determination that an importer of welded pipe fittings is liable for $8 million in unpaid antidumping duties under the False...more
What if your trade compliance misstep became tomorrow’s federal prosecution headline? In this episode, Michael Volkov issues a powerful warning to corporate leaders and compliance professionals: the DOJ is no longer treating...more
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
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
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