Call of Duties: New U.S. Trade Fraud Task Force Signals Increased Tariff Enforcement is Coming
On August 29, 2025, the U.S. Department of Justice (DOJ) and Department of Homeland Security (DHS) announced their partnership on the cross-agency Trade Fraud Task Force. Per DOJ’s press release, the Task Force will bring robust enforcement against importers and other parties that seek to defraud the United States.
President Trump Signs “Fair Banking” Executive Order Directing Financial Regulators to Remedy Past and Present Debanking Practices
On August 7, 2025, President Donald Trump signed an executive order titled “Guaranteeing Fair Banking for All Americans,” directing federal agencies to combat “debanking” — the denial or termination of financial services based on political views, religious beliefs, or industry affiliation. The executive order expands on numerous recent federal and state initiatives targeting debanking — including the joint U.S. Department of Justice (DOJ)/Commonwealth of Virginia Equal Access to Banking Task Force, two recent bills introduced in the U.S. Senate, and actions by the federal financial regulators to remove “reputation risk” as a supervisory consideration.
Tariff Evasion Is Within DOJ’s Crosshairs: Potential Criminal and Civil Consequences for Noncompliance With Increased U.S. Tariffs
The first six months of the current Trump administration have made it clear that tariffs are here to stay and that noncompliance — intentional or otherwise — will be subject to potentially significant criminal and civil liability. Indeed, the administration has committed to an August 1, 2025, deadline for new country-specific tariffs to begin. The scale, speed, and complexity of the changes in the U.S. tariff landscape over the previous six months (which will likely continue) has created an environment ripe for noncompliance. (more…)
Whistleblower Rewards Continue to Grow: U.S. DOJ’s Antitrust Division Joins the Fray
On July 8, 2025, the U.S. Department of Justice (DOJ)’s Antitrust Division announced its partnership with the Postal Service to offer financial rewards to individuals who report violations of antitrust laws and related offenses affecting the Postal Service, its revenues, or its property.
U.S. DOJ Announces Renewal of FCA Working Group
On July 2, 2025, the U.S. Department of Justice (DOJ) announced the renewal of the DOJ-HHS False Claims Act Working Group (Working Group), a partnership with the U.S. Department of Health and Human Services (HHS) that aims to strengthen use of the False Claims Act (FCA) to combat healthcare fraud. (more…)
U.S. DOJ Civil Division to Investigate Possible Violations of the Food, Drug, and Cosmetic Act by Pharmaceutical Firms Manufacturing Drugs Used in Gender Transition Care
On June 11, 2025, the U.S. Department of Justice (DOJ) Civil Division issued a memorandum outlining five Trump administration policy objectives and “direct[ing] Civil Division attorneys to prioritize investigations and enforcement actions advancing these priorities.”1 The memorandum is signed by Assistant Attorney General Brett A. Shumate, who was confirmed by the Senate two days earlier, on June 9, 2025.2 One of the five policy objectives, entitled “Protecting Women and Children,” has potentially significant enforcement implications for pharmaceutical companies whose drugs may be used in gender transition care — even if they are used off-label.
U.S. DOJ Unveils White-Collar Enforcement Priorities and Corporate Enforcement Policy Revisions
On May 12, 2025, the Head of the U.S. Department of Justice Criminal Division, Matthew Galeotti, provided the Trump administration’s first comprehensive articulation of white-collar priorities and revised corporate enforcement policies in remarks delivered at the Securities Industry and Financial Markets Association Anti-Money Laundering and Financial Crimes Conference. (more…)
U.S. DOJ Shifts Focus in Digital Asset Enforcement
The U.S. Department of Justice (DOJ or Department) has announced a significant shift in enforcement priorities concerning digital assets. On April 7, 2025, Deputy Attorney General Todd Blanche issued a memorandum (Memorandum) announcing that the Department is not a “digital assets regulator” and will no longer pursue litigation or enforcement actions that “have the effect of superimposing regulatory frameworks on digital assets.” Instead, the Memorandum directs DOJ to focus on the prosecution of conduct that victimizes investors or uses digital assets in furtherance of crimes such as terrorism, narcotics trafficking, hacking, and human trafficking.