News & Analysis as of

Tariffs Enforcement Actions

Holland & Knight LLP

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

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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

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

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

Husch Blackwell LLP

June 2025 Trade Law Update

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In Husch Blackwell’s June 2025 Trade Law Update you’ll learn about the following updates in international trade and supply chain law: • An update on U.S. Department of Commerce decisions - • U.S. International Trade...more

Kelley Drye & Warren LLP

Trump Issues Reciprocal Tariff Letters to 8 Additional Trade Partners

On Wednesday, July 9, President Trump issued letters to eight additional trade partners notifying them of their country-specific reciprocal tariff rates that will go into effect on August 1. An updated reciprocal tariff chart...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

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

Blank Rome LLP

[Webinar] 180 Days of the Trump Administration—Quick Hits on Executive Orders, Actions, and Policies - July 17th - August 13th,...

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Blank Rome presents a new summer webinar series where our interdisciplinary team will unpack the most pressing legal, regulatory, and policy developments from the Trump Administration’s first 180 days. Each session offers...more

Stinson LLP

Possible Relief from New Tariffs — and Risks to Avoid

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Tariffs have been in the news almost daily. Not only have tariff rates changed repeatedly, but the deadlines around implementation are subject to change. Meanwhile, the list of new commodities that are subject to additional...more

DLA Piper

Ninth Circuit Holds Private Parties Can Bring Claims Against Importers Under the False Claims Act for Antidumping Duty Evasion

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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

White & Case LLP

Navigating Antitrust Risks When Responding to Tariffs

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As companies consider their responses to tariffs, including potential price and supply chain adjustments, antitrust enforcers are scrutinizing competitor conduct. Recent enforcement warnings from both FTC and DOJ officials...more

Blank Rome LLP

Tariffs, Treble Damages, and Trade Enforcement: Surviving the New Era of Customs Crackdown

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The American trade landscape has transformed rapidly as the United States’ “America First” national-security platform reshapes international relations. New executive orders, proclamations, and memoranda issued under the...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

Baker Donelson

Trade Enforcement Risks Escalate with Increasing Tariffs: What Companies Should Do to Mitigate Risk

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The increase in tariffs and export control actions by the Trump Administration has led to additional reporting and compliance obligations for companies that import and export goods. To ensure these new tariffs and rules are...more

Morgan Lewis

Staying Resilient Amid Global Tariff Uncertainty

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From reciprocal tariffs and retaliatory investigations to paused agreements and looming re-escalations, the global tariff landscape remains as turbulent as ever. Morgan Lewis recently hosted a three-part webinar series...more

Cooley LLP

DOJ Announces Priorities and Policy Updates – Including Tariff Compliance Enforcement, Expansion of Whistleblower Program

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Over the last year, we have paid close attention to the increasingly complicated and evolving landscape companies are facing in light of changing government enforcement priorities, including the Department of Justice’s...more

Benesch

Regulatory Policy Showdown - Domestic vs. International Differences for the Trump 47 Administration

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The White House’s approach to regulatory policy emerged swiftly after Inauguration Day. In many parts of the industry the new Administration started with a “buzz” of excitement. ...more

Warner Norcross + Judd

DOJ Announces “New Page” in White Collar and Corporate Enforcement

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Matthew Galeotti, head of the Department of Justice’s (DOJ) Criminal Division announced in May that DOJ “is turning a new page on white-collar and corporate enforcement.” The same day, the Criminal Division circulated four...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

Husch Blackwell LLP

May 2025 Trade Law Update

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In Husch Blackwell’s May 2025 Trade Law Update you’ll learn about the following updates in international trade and supply chain law: • An update on U.S. Department of Commerce decisions - • U.S. International Trade...more

The Volkov Law Group

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

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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

Dickinson Wright

Recent U.S. – China Tariff Tensions Spark Investigations by Chinese Authorities

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This spring, representatives from China’s Ministry of Commerce (“MOFCOM”) met with Walmart executives in China (“PRC”) to discuss allegations that Walmart had asked its Chinese suppliers to reduce prices or offer some sort of...more

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