Managing Whistlelbowers
10 For 10: Top Compliance Stories For the Week Ending August 23, 2025
Daily Compliance News: August 21, 2025, The Fabricated Evidence Edition
Adventure in Compliance: The Novels - The Valley of Fear, Whistleblowers and Corporate Compliance
Creativity and Compliance: Reinventing Compliance with Creativity: The Acteon I-Care Code
Moving Beyond the Usual Helpline Data
Podcast - Bring Out the Bad Stuff
Adventures in Compliance: The Novels - The Valley of Fear, Introduction and Compliance Lessons Learned
Episode 381 -- NAVEX's 2025 Annual Hotline Report
Compliance Tip of the Day: AI, Whistleblowing and a Culture of Speak Up
2 Gurus Talk Compliance: Episode 56 – The Grasshopper Edition
From the Editor’s Desk: Compliance Week’s Insights and Reflections from July to August 2025
Episode 379 -- Update on False Claims Act and Customs Evasion Liability
Everything Compliance: Episode 157, The Q2 2025 Great Women in Compliance Edition
10 For 10: Top Compliance Stories For the Week Ending July 19, 2025
2 Gurus Talk Compliance: Episode 55 – The From Worse to Worser Edition
Daily Compliance News: July 18, 2025, The Don’t Alter Docs Edition
Blowing the Whistle: What Employers Should Know About DEI & the False Claims Act
When DEI Meets the FCA: What Employers Need to Know About the DOJ’s Civil Rights Fraud Initiative
FCPA Compliance Report: Stay the Course: Ellen Lafferty on Navigating Anti-Corruption Compliance in 2025
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
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
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
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
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
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
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
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
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
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
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
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
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
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 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
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
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
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
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
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
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
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
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
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
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