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Penalties International Trade

The Volkov Law Group

Interactive Brokers Settles with OFAC for $11.8 Million for Violations of Multiple Sanctions Programs

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced on July 15, 2025, that Interactive Brokers LLC (“IB”)—a globally active electronic brokerage firm headquartered in Greenwich,...more

The Volkov Law Group

Episode 378 -- Update on Export Controls and Sanctions Enforcement

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What happens when companies ignore red flags, bypass legal advice, and underestimate the reach of U.S. export laws? In this episode, Michael Volkov unpacks two major enforcement actions from the Department of Commerce’s...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

The Volkov Law Group

BIS Levies $4.25 Million Penalty Against Alpha and Omega Semiconductor for Unauthorized Exports to Huawei

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On June 27, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order resolving administrative enforcement proceedings against Alpha and Omega Semiconductor Incorporated (“AOS”), a...more

Foley & Lardner LLP

Ninth Circuit Slams Importer in a False Claims Act Case Involving the Knowing Avoidance of Antidumping Duties

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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

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

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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

False Claims and Trade Compliance: Enforcement Examples (Part III of III)

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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

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

King & Spalding

Transatlantic AI Governance – Strategic Implications for U.S. — EU Compliance

King & Spalding on

Introduction: The Global Race Towards AI Governance Takes Different Paths- As artificial intelligence (AI) continues to transform global markets, the European Union and the United States are advancing regulatory...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

Episode 369 -- Stepping Into the Enforcement Spotlight -- Customs and Border Patrol and Import Enforcement

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What if your next import shipment becomes the centre of a federal enforcement action — not because of criminal intent, but because of a mistake? In today’s episode, Michael Volkov breaks down the expanding power and reach of...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

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

Foley & Lardner LLP

What Every Multinational Company Should Know About … Customs Enforcement and False Claims Act Risks (Part II)

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As detailed in Part I of our three-part series on Minimizing Customs Enforcement and False Claims Act Risks, the combination of the new high-tariff environment, the heightened ability of Customs (and the general public) to...more

Seward & Kissel LLP

Undervalue at Your Own Risk: The False Claims Act Comes for Imports

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While some enforcement areas have taken a pause this year, False Claims Act enforcement—especially around customs duties—is moving and likely to get busier. Just last week the U.S. Department of Justice filed a complaint...more

Dorsey & Whitney LLP

The Trump Administration’s Sweeping New Tariffs Heighten False Claims Act Risks for U.S. Importers

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As the business community adjusts to the reality of the Trump Administration’s sweeping new tariff regime, importers and other organizations that rely on imports should be mindful that with the expansion and sharp increases...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - April 2025 - USMCA – We Have Some Good News and Some Terrible News

As is well known the US has imposed duties of 25% on imports from Canada and Mexico. This means that those imports will take the regular duty plus 25%. For example, a switchgear assembly classified under 8537.10.91 made in...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … Customs Enforcement and False Claims Act Risks (Part I)

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As detailed in our prior article on “What Every Multinational Company Should Know About … The Rising Risk of Customs False Claims Act Actions in the Trump Administration,” the Department of Justice (DOJ) is encouraging the...more

WilmerHale

UK, French, and Swiss Enforcement Authorities Announce New Alliance

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Anti-bribery and corruption agencies in the UK, France and Switzerland today announced a shared commitment to tackling international bribery and corruption, by way of a new taskforce intended to strengthen collaboration....more

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more

Adams & Reese

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

Bass, Berry & Sims PLC

CFIUS Update: Larger Penalties, Sharper Monitoring

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On April 11, the U.S. Treasury Department promulgated a Notice of Proposed Rulemaking (NPRM) amending the regulations that govern the operations of the Committee on Foreign Investment in the United States (CFIUS) to increase...more

Snell & Wilmer

The Uncertain World: Nearshoring, Economic Development, and the Next Frontier

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Historically, international trade regulation has swung between economic protectionism and national security concerns. Between World War II and the 2018 presidential election, the primary international trade regulatory issue...more

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