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 opportunities and risks for companies involved in international trade. DOJ’s intent is clear and companies should be aware of this growing risk area. In May 2025, DOJ designated “trade and...
With the rising importance of trade compliance programs, it is important to start with the law. (Spoken like a true lawyer). The U.S. relies on two powerful tariff tools — Section 301 and Section 232 tariffs. Relying on these provisions, the U.S. government can impose additional duties on imported goods. The key difference between the two is the specific legal authority and the different policy...
British American Tobacco’s deceit and elevation of business over compliance permeates its recent blockbuster settlement for $629 million with the Department of Justice and Office of Foreign Asset Control. Importantly, the BAT settlement confirms DOJ’s new, aggressive approach to sanctions and export enforcement, and OFAC’s imposition of a penalty equal to the statutory maximum. For compliance professionals, the BAT scheme is interesting to review because...
