News & Analysis as of

International Trade Whistleblowers False Claims Act (FCA)

Akin Gump Strauss Hauer & Feld LLP

DOJ and DHS Launch Cross-Agency Task Force to Combat Trade Fraud

On August 29, 2025, the U.S. Departments of Justice (DOJ) and Homeland Security (DHS) announced the creation of a new cross-agency Trade Fraud Task Force “to bring robust enforcement against importers and other parties who...more

Cozen O'Connor

New DOJ-DHS Trade Fraud Task Force Signals Increased Tariff and False Claims Act Enforcement

Cozen O'Connor on

On August 29, the Department of Justice (DOJ) announced the new Trade Fraud Task Force focused on robust enforcement of import laws and regulations. A partnership between the DOJ Civil and Criminal Divisions and the...more

DLA Piper

DOJ Officially Launches the Trade Fraud Task Force

DLA Piper on

The US Department of Justice (DOJ), in coordination with the Department of Homeland Security (DHS), on August 29, 2025, launched a cross-agency Trade Fraud Task Force to bolster enforcement against tariff evasion, customs...more

Baker Donelson

Shifting Priorities: DOJ's Formation of the Market, Government, and Consumer Fraud Unit

Baker Donelson on

The U.S. Department of Justice (DOJ) unveiled a revised strategy for white collar enforcement on May 12, 2025. Included in this policy realignment was the identification of trade and customs fraud as a "high impact area" that...more

DLA Piper

False Claims Act Usage Continues to Rise in US Tariff Enforcement Context

DLA Piper on

In the first eight months of 2025, the US Department of Justice (DOJ) announced four significant settlements involving allegations of knowingly and improperly evading customs duties on imports under the False Claims Act...more

Foley Hoag LLP - White Collar Law &...

DOJ Ramps Up Use of False Claims Act to Advance Tariff Agenda

The second Trump administration’s aggressive tariff policy is playing out in more than just the Commerce Department. Framed under the administration’s commitment to fight “waste, fraud, and abuse,” the U.S. Department of...more

WilmerHale

Tariffs Take Hold Raising the Specter of Criminal and Civil Tariff Enforcement

WilmerHale on

Seven months into President Donald Trump’s second administration, a new trade paradigm is emerging that presents challenges for everyone involved in bringing products into the United States. ...more

Husch Blackwell LLP

The Risks of Trade-Related FCA Enforcement

Husch Blackwell LLP on

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

Lathrop GPM

DOJ Ramps Up Tariff Evasion Enforcement

Lathrop GPM on

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

ArentFox Schiff

Investigations Newsletter: Patio Furniture Firm Pays Millions for Dodging Import Duties

ArentFox Schiff on

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

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

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

Holland & Knight LLP

Importers Beware: Signals Point to Significant Enforcement Risks for Tariff Evasion

Holland & Knight LLP on

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

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

Morgan Lewis

DOJ Shifts Focus of Enforcement Efforts to Tariff Evasion

Morgan Lewis on

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

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

Husch Blackwell LLP

Ninth Circuit Finds Importer Liable Under False Claims Act for Failure to Pay Antidumping Duties

Husch Blackwell LLP on

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

The Volkov Law Group

Episode 372 -- DOJ Applies False Claims Act to Tariff and Trade Violations

The Volkov Law Group on

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

The Volkov Law Group

A Dangerous Combination: False Claims Act and Trade Violations (Part II of III)

The Volkov Law Group on

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

The Volkov Law Group

DOJ Applies False Claims Act to Tariff and Trade Violations (Part I of III)

The Volkov Law Group on

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

Kelley Drye & Warren LLP

DOJ Intervenes in Customs False Claims Act Case, Consistent with Administration’s Focus on Foreign Trade

The United States has intervened and filed a superseding complaint in a False Claims Act case originally filed by a whistleblower in the Eastern District of California. The Government’s complaint alleges that an importer and...more

Vinson & Elkins LLP

Heightened False Claims Act Enforcement Risks Highlight the Importance of Compliance

Vinson & Elkins LLP on

Despite signs of a retrenchment in some of the traditional areas of white collar enforcement under the Trump administration, the U.S. Department of Justice’s (“DOJ”) enforcement of the civil False Claims Act (“FCA”) appears...more

Cranfill Sumner LLP

DOJ Invites Whistleblowers to Report Tariff Fraud

Cranfill Sumner LLP on

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

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