News & Analysis as of

Imports Fraud

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

The Volkov Law Group

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

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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)

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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

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

Mintz

Dodging Duties: The Ninth Circuit Affirms an Expansive Application of the False Claims Act Consistent with Trump Administration...

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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

Foley & Lardner LLP

Customs Fraud Makes the Big Leagues: DOJ’s New White-Collar Priorities Confirm Heightened Risk

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Last month, the Department of Justice put trade, customs, and tariff fraud squarely in the spotlight. This isn’t just another line item on the compliance checklist, it’s a loud-and-clear signal that import-related enforcement...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

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

Cranfill Sumner LLP

DOJ Invites Whistleblowers to Report Tariff Fraud

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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

Foley Hoag LLP - White Collar Law &...

Are There Legitimate Ways to Achieve More Advantageous Tariff Classifications?

With recent increases in U.S. tariffs and the increasing complexity of determining applicable duties for different products, importers are looking for ways to reduce their tariff exposure. Since a product’s tariff treatment...more

The Volkov Law Group

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

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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

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

DLA Piper

Settlement Further Signals New Surge of Reverse False Claims Act Cases Related to Customs Fraud

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The United States Department of Justice (DOJ) recently announced a significant settlement that underscores the federal government’s increasing appetite to rely on the False Claims Act to address alleged customs fraud....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

ArentFox Schiff

Trump Tariffs: What Importers Need to Know About Customs Fraud and the Increased Use of the False Claims Act

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In addition to navigating the Trump Administration’s ever-changing international trade policy through the use of existing (e.g., Section 301, Section 232, etc.) and novel (e.g., International Emergency Economic Powers Act,...more

Wiley Rein LLP

DOJ Affirms Aggressive False Claims Act Enforcement, Highlights Use Against Illegal Trade Practices

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The head of the U.S. Department of Justice (DOJ) branch that oversees False Claims Act (FCA) investigations affirmed the Trump Administration’s commitment to pursue civil fraud cases as part of its focus on achieving...more

Ropes & Gray LLP

Customs Fraud May Bring a New Wave of False Claims Act Cases

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On February 1, 2025, President Trump imposed 25% tariffs on most imports from Canada and Mexico, as well as 10% tariffs on Canadian energy products and imports from China. The primary immediate impact of the new tariffs will...more

King & Spalding

The Trifecta: What to Expect from a Second Trump Administration and a Republican Congress

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Republicans have swept the 2024 elections, returning Donald Trump to the White House as the 47th President and flipping the Senate to a Republican majority. Having narrowly maintained control of the House of Representatives,...more

ArentFox Schiff

As the (Customs and Trade) World Turns: September 2024

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Welcome to the September 2024 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

Torres Trade Law, PLLC

Trade Violations Under the False Claims Act

On February 7, the U.S. Department of Justice (DOJ) announced that settlements and judgements under the False Claims Act (FCA) exceeded $2 billion for the 2022 fiscal year. The 2022 fiscal year also had the second-highest...more

Torres Trade Law, PLLC

What You Need to Know about 19 USC 1592

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In 2022, Customs and Border Protection (“CBP” or “Customs”) processed $3.35 trillion in imports, issued 2,121 penalties, and collected $19.3 million from penalties and liquidated damages. Section 1592 of the Tariff Act of...more

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