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Imports International Trade Corporate Counsel

Foley & Lardner LLP

Tariffs and Your Contracts: Why does the "importer of record" provision matter?

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To ascertain which party in a commercial contract is responsible for tariffs, it is important to check whether the contract specifies the importer of record....more

Foley & Lardner LLP

Tariffs and Your Contracts: Why do delivery terms matter?

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In light of a trade landscape rife with tariffs, companies are examining their commercial contracts to judge the exposure to increased costs of production. One area of a supply contract that cannot be overlooked when...more

Husch Blackwell LLP

The Risks of Trade-Related FCA Enforcement

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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

Sterne, Kessler, Goldstein & Fox P.L.L.C.

Minimizing Your Risk of Being Sued Before the U.S. International Trade Commission

The International Trade Commission (ITC) is an independent U.S. federal agency that oversees issues including IP enforcement, anti-dumping, and tariffs. A finding of infringement at the ITC can result in exclusion orders and...more

McDermott Will & Schulte

DOJ complaint underscores Trump administration’s use of the FCA to enforce US trade laws

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

Mintz

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

Mintz on

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

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

Williams Mullen

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

Williams Mullen on

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

Husch Blackwell LLP

CBP Issues Guidance on Prioritization of Articles “Subject to” More Than One Tariff Under EO 14289

Husch Blackwell LLP on

On May 15, 2025, U.S. Customs and Border Protection (“CBP”) issued further guidance via the Cargo Systems Messaging Service (“CSMS”) for determining the order in which the various tariffs will apply to an article when that...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

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

Sheppard Mullin Richter & Hampton LLP

Not What You Think: Some Trump Tariffs Exempt Your Goods from Other Trump Tariffs

Some importers are finding, to their surprise, that the Trump Administration’s 25% tariffs on aluminum and steel create an exemption from the 125% tariffs on Chinese goods. The Trump tariff agenda has been complex, to say...more

Pillsbury Winthrop Shaw Pittman LLP

Comparing Developments in U.S. and EU Strategies to Combat Forced Labor

In recent years, a multinational focus on preventing forced labor within supply chains has shaped due diligence requirements for companies worldwide. Recent changes to global policies and potential shifts in enforcement...more

Baker Botts L.L.P.

Trump Tariff Tracker -- April 30

Baker Botts L.L.P. on

We have passed the 100-day mark in the second Trump Administration and tariffs remain the talk of the town, with President Trump taking more trade-related actions in this time than any other president in modern history. As...more

Husch Blackwell LLP

Customs Issues Guidance on Reporting Requirements for Reciprocal Tariffs and New Section 232 FAQs

Husch Blackwell LLP on

On April 8, 2025 U.S. Customs and Border Protection (“CBP”) issued a Cargo Systems Messaging Service (“CSMS”) Message # 64680374which sets forthadditional guidance on the reporting of reciprocal tariffs set to take effect on...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … The Global and Reciprocal Tariffs Announcement

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On April 2, 2025, President Trump implemented the steepest American tariffs in over a century. The implications for numerous multinational companies — including importers, manufacturers, distributors, and retailers — will be...more

DLA Piper

Navigating the Trump Administration’s Latest Tariffs on Canada, Mexico, and China

DLA Piper on

We have reported extensively on President Trump's "America First Trade Policy", the new tariffs imposed on Canada, Mexico and China, and provided commentary on how President Trump's return to office might affect the UK and...more

Wolf, Greenfield & Sacks, P.C.

Federal Circuit Removes Limits on “Qualifying” Domestic Industry Activities at the ITC

On March 5, 2025, the Federal Circuit rejected the ITC’s longstanding practice of excluding certain types of activities from qualifying as “domestic industry” activities under Section 337(a)(3)(B), finding the ITC’s approach...more

WilmerHale

Fact Sheet: Trump March 4 Trade Actions on Canada, Mexico, China

WilmerHale on

On February 1, President Trump issued two Executive Orders (EOs) announcing the imposition of a 25% tariff on products of Canada (10% on energy products) and Mexico, effective February 4. On February 3, the President...more

Skadden, Arps, Slate, Meagher & Flom LLP

Significant UK Court of Appeal Decision Confirms the Applicability of the UK’s Proceeds of Crime Legislation to Illegality in...

The UK Court of Appeal recently held that the National Crime Agency’s decision not to investigate whether cotton goods manufactured in China and imported to the UK were the product of forced labour was unlawful — a decision...more

Foley & Lardner LLP

What Every Multinational Company Needs to Know About … The Uyghur Forced Labor Prevention Act Due Diligence and Compliance (Part...

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In our previous biweekly update, What Every Multinational Needs to Know About … The Uyghur Forced Labor Prevention Act, Part I, we summarized the UFLPA requirements and the basic expectations that U.S. Customs and Border...more

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