The Trump Justice Department has fully embraced the False Claims Act, stretching its use to include trade enforcement. DOJ recognizes the power of the FCA, the issues at stake, and the ability to extract large settlements. DOJ has used the FCA to capture companies that evade customs duties. DOJ’s recent actions are a reminder for import companies to carefully scrutinize valuation and customs duties to...
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 __ (9th Cir. June 23, 2025). The decision clears the way for DOJ to pursue its aggressive strategy to prevent and punish customs evasion misconduct. Island Industries, a competitor, sued Sigma for...
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...
May 20, 2025 12 Noon EST SIGN UP HERE Enforcement risks and compliance are evolving. The Justice Department, DHS-Customs and Border Patrol, the Bureau of Industry and Security, and OFAC are focusing on a range of issues: tariff compliance, imports, sanctions and export controls, with a new emphasis on aggressive regulatory fines and criminal prosecutions. Companies face a fresh set of tariff and import risks,...
To keep track of the Trump Administration tariff plans and actions requires vigilance. The difficulty in monitoring daily tariff actions and the impact is a challenge to all trade compliance officers. Here is the best list that we have been tracking since the Trump Administration started to implement tariffs across a wide range of countries and industries. On April 5, 2025, the Trump Administration implemented...
Are You Ready for the Next Wave of Corporate Risk? Corporate risks are shifting, and every board, C-suite, and compliance team must take a fresh look at their risk landscape. While some risks like cybersecurity, data privacy, and artificial intelligence remain high priorities, others—such as anti-corruption and antitrust enforcement—are evolving in unexpected ways. With regulatory changes and new enforcement priorities emerging, businesses must stay ahead...
The 2nd Trump Administration will mean significant change in foreign policy, most especially the importance of ending the Russia-Ukraine war, increased focus on Iran and its proxies, and aggressive use of trade policies and tools to execute the policy and promote United States businesses. Since the start of the Russia-Ukraine war and the unprecedented global sanctions and export controls regime, trade enforcement and compliance have...
