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Ice Miller

A New Era of Trade Enforcement: DOJ Expands Criminal and Civil Focus on Tariff Fraud

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The shifting tariff landscape in 2025 has incentivized businesses to reexamine their import practices and identify any available options to reduce their tariff exposure and liability....more

Akin Gump Strauss Hauer & Feld LLP

Tariff Evasion and Customs Fraud Under the Microscope: DOJ Signals Aggressive Criminal Enforcement Ahead

Given the Trump Administration’s unprecedented reliance on tariffs as a foreign policy tool and a means to protect and foster U.S. industry, the U.S. Department of Justice (DOJ) is rapidly shifting resources and enforcement...more

Lathrop GPM

DOJ Ramps Up Tariff Evasion Enforcement

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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

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

Blank Rome LLP

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

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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

Katten Muchin Rosenman LLP

DOJ Identifies Tariff Fraud as Enforcement Priority

The Trump administration’s announcement of a panoply of steep tariffs on April 2, 2025, and the associated tariff negotiations that followed, has been met with extensive media coverage and analysis. To emphasize the...more

K&L Gates LLP

Trump DOJ Elevating Criminal Prosecution of Tariff Evasion

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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

Adams & Reese

United States: How a multi-pronged legislative approach is curbing the online trade in fakes

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Anti-counterfeiting enforcement in the United States stems largely from two federal statutes: the Lanham Act (codified at 15 USC Section 1051) and the Trademark Counterfeiting Act 1984 (codified at 18 USC Section 2320). The...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

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

DLA Piper

DOJ Expands Enforcement of Trade Fraud and Tariff Evasion

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On July 10, 2025, officials from the US Department of Justice (DOJ) announced a significant shift in DOJ’s strategy for fraud enforcement, consolidating resources from the Criminal Division and the Civil Division to create a...more

Morgan Lewis

DOJ Shifts Focus of Enforcement Efforts to Tariff Evasion

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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

Hogan Lovells

Imports and the False Claims Act: Recent Ninth Circuit decision reflects trends in increased import fraud enforcement and...

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The Ninth Circuit’s recent decision in Island Industries Inc. v. Sigma Corporation, coupled with recent government pronouncements concerning trade enforcement, are likely to drive an increase in customs fraud FCA...more

Williams Mullen

Bracing for Impact: Tariff Compliance Risks due to Trump-Era Trade Policy Shifts

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Businesses engaged in international trade are struggling with a wave of uncertainty arising from recent shifts in U.S. tariff policy. Each day’s news cycle is peppered with stories about the Trump administration’s aggressive...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

The Volkov Law Group

Criminal Liability and Tariff and Trade Enforcement

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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

Bradley Arant Boult Cummings LLP

Customs Fraud Investigations Will Be a DOJ Area of Focus

On May 12, 2025, Department of Justice (DOJ) Criminal Chief Matthew Galeotti issued a memorandum addressing the “Fight Against White-Collar Crime.” The memorandum lists several priorities for white-collar criminal...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

Vinson & Elkins LLP

The Trump Tariff Regime Brings Risks of Criminal and Civil False Claims Act Enforcement

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On April 2, 2025, President Donald Trump announced a new tariff regime under the International Emergency Economic Powers Act of 1977 (“IEEPA”), citing national security concerns. This regime includes a 10 percent baseline...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

Cooley LLP

Tariffs Are Here – Be Aware of Criminal and Civil Enforcement Risks

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On April 2, 2025, President Donald Trump, citing national security concerns, used authority granted under the International Emergency Economic Powers Act of 1977 (IEEPA) to announce a sweeping new tariff regime, with a 10%...more

Foley & Lardner LLP

What Every Multinational Company Needs to Know About … Criminal Enforcement of Trade, Import, and Tariff Rules: A Growing Risk for...

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In less than 100 days, the Trump administration has implemented a dizzying array of new tariffs, significantly increasing costs and complexity for U.S. importers. The administration is keenly aware that companies operating in...more

BakerHostetler

Should You Consider a Voluntary Self-Disclosure for a Tariff Violation?

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Tariff evasion techniques such as transshipping goods through third countries, underreporting the value of goods, and mislabeling goods as other items subject to lower tariff rates have resulted in hundreds of billions of...more

WilmerHale

Clearing the Air on Criminal Enforcement of Hydrofluorocarbon Importation Laws

WilmerHale on

The Biden Administration’s focus on climate change mitigation is showcased in a prosecution recently announced by the U.S. Attorney’s Office, Southern District of Cali- fornia against Michael Hart, who is accused of smuggling...more

Akin Gump Strauss Hauer & Feld LLP

New Executive Order Authorizes the Imposition of Secondary Sanctions on Foreign Financial Institutions Facilitating Russia’s...

Key Points - On December 22, 2023, President Biden issued E.O. 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.” Specifically, E.O. 14114, which amends E.O. 14024 and E.O. 14068,...more

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