Clear and Present Danger: How DOJ Trade-Fraud and Anti-Corruption Priorities Show Trade & Customs Risks Are Here to Stay
The U.S. Department of Justice (DOJ) has signaled a renewed and sharpened focus on trade and customs-related misconduct, including tariff evasion. While DOJ’s emphasis on this enforcement area is notable in its own right, this Update highlights how DOJ’s prioritization of trade and customs fraud also brings Foreign Corrupt Practices Act (FCPA) exposure back to the forefront of risks for multinational companies. (more…)
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…)
