customs Archives - Corruption, Crime & Compliance

27 May, 2025

DOJ Applies False Claims Act to Tariff and Trade Violations (Part I of III)

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 mistake when they confuse a “pause” in FCPA enforcement to mean a reduction in federal criminal corporate prosecutions. This Administration has no problem in taking aggressive positions in the legal arena and I would...

General

18 Mar, 2025

Trade Policies and Initiatives — A Fresh Examination

Trade compliance officers are scrambling — they knew change was afoot but no one expected the speed and wide scope of upheaval in the trade arena. One day presents potential changes with serious ramifications. In this turbulent era, legal and compliance have to maintain calm, avoid over-reaction and remain close to their corporate values and principles. Legal and compliance have to present a steady confidence. ...

General

19 Feb, 2025

Import Enforcement and Compliance Risks

The scope of new import tariffs and regulations portends significant operational risks and disruptions. It is easy to imagine numerous companies that depend on imports for production purposes are facing a new set of challenges. This is when companies are at risk of significant disruptions. However, let us hope that many companies are prepared — the disruption caused from the 2020 Pandemic challenged companies to...

Uncategorized

21 Aug, 2016

Anti-Corruption, Sanctions and Export and Import Risks

Forgive me for overusing the term “convergence” but when the shoe fits, I say “wear it.” If you are managing corporate risks and are responsible for securing export licenses, ensuring that you are complying with OFAC sanctions requirements, interacting with customs and immigration officials around the globe, and conducting third party due diligence to onboard a new agent or distributor, there is no question that...