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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

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

Cooley LLP

Complaint Against Uniform Company for Customs Duties Underpayment Highlights False Claims Act Risks for Tariff Compliance

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As we discussed in this April 7 blog post, the US Department of Justice (DOJ) can pursue civil penalties for tariff evasion under the False Claims Act (FCA), including against companies that are aware of tariff evasion by...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

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

Cooley LLP

Tariffs Are Here – Be Aware of Criminal and Civil Enforcement Risks

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On April 2, 2025, President Donald Trump, citing national security concerns, used authority granted under the International Emergency Economic Powers Act of 1977 (IEEPA) to announce a sweeping new tariff regime, with a 10%...more

BakerHostetler

Should You Consider a Voluntary Self-Disclosure for a Tariff Violation?

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Tariff evasion techniques such as transshipping goods through third countries, underreporting the value of goods, and mislabeling goods as other items subject to lower tariff rates have resulted in hundreds of billions of...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … The Rising Risk of Customs False Claims Act Actions in the Trump...

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On February 20, 2025, the Deputy Assistant Attorney General for the Commercial Litigation Branch at the U.S. Department of Justice (DOJ), Michael Granston, emphasized using the False Claims Act (FCA) to address U.S. Customs &...more

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