Tag: Tariffs
DOJ Announces Priorities and Policy Updates – Including Tariff Compliance Enforcement, Expansion of Whistleblower Program
Over the last year, we have paid close attention to the increasingly complicated and evolving landscape companies are facing in light of changing government enforcement priorities, including the Department of Justice’s (DOJ’s) focus on tariff compliance and its pilot program to reward whistleblowers who report corporate wrongdoing to the government. […]
Complaint Against Uniform Company for Customs Duties Underpayment Highlights False Claims Act Risks for Tariff Compliance
As we discussed in this April 7 blog post, the US Department of Justice (DOJ) can pursue civil penalties for tariff evasion under the False Claims Act (FCA), including against companies that are aware of tariff evasion by their supply chain partners. The FCA risks are significant not only due […]
Tariffs Are Here – Be Aware of Criminal and Civil Enforcement Risks
On April 2, 2025, President Donald Trump, citing national security concerns, used authority granted under the International Emergency Economic Powers Act of 1977 to announce a sweeping new tariff regime, with a 10% baseline tariff for all countries, plus higher “reciprocal tariffs” for approximately 90 countries. These tariffs are “stackable” […]