Last month, the Department of Justice put trade, customs, and tariff fraud squarely in the spotlight. This isn’t just another line item on the compliance checklist, it’s a loud-and-clear signal that import-related enforcement...more
6/10/2025
/ Corporate Counsel ,
Customs ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Fraud ,
Imports ,
Manufacturers ,
Risk Management ,
Supply Chain ,
Tariffs ,
White Collar Crimes
Less than five months into the new administration, we have already seen more than 50 tariff proclamations. With new tariffs being proposed, imposed, revoked, suspended, and sometimes reimposed, it can be difficult for...more
6/5/2025
/ China ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Multinationals ,
Popular ,
Section 232 ,
Supply Chain ,
Tariffs ,
Trade Relations ,
Trump Administration
One of the most common questions we get from clients is, “What is the future of the Trump administration’s tariff strategy?” With President Trump having issued over 50 tariff proclamations — a six-month sprint of more major...more
Share on Twitter Print Share by Email Share Back to top This year, U.S. trade policy has undergone a dramatic shift, driven by a series of presidential proclamations that have raised tariff rates sharply. Some tariffs (such...more
This Memorial Day marks 35 years since Jim Henson, creator of the Muppets, passed away. Among his many accomplishments, the Muppets were essential to the creation of the longest-running children’s television show, “Sesame...more
Our previous article on What Every Multinational Company Should Know About … Customs Enforcement and False Claims Act Risks (Part I) outlined how import-related risks have substantially increased given the combination of the...more
As detailed in Part I of our three-part series on Minimizing Customs Enforcement and False Claims Act Risks, the combination of the new high-tariff environment, the heightened ability of Customs (and the general public) to...more
4/25/2025
/ Anti-Dumping Duty ,
Classification ,
Compliance ,
Countervailing Duties ,
Country of Origin ,
Customs and Border Protection ,
Duty Free ,
Enforcement Actions ,
False Claims Act (FCA) ,
Free Trade Agreements ,
Imports ,
International Trade ,
Misclassification ,
Misrepresentation ,
Penalties ,
Risk Management ,
Tariffs ,
Valuation
Assessing Tariff Impacts in Commercial Contracts -
With the size and scope of President Trump’s tariffs continuing to shift, this is a critical time for businesses to assess their contracts and determine how increased...more
So, just before Easter, in 1957, a little book you may have heard of, called The Cat in the Hat, made its first appearance. Theodore Geisel — writing under the name “Dr. Suess” — later said that of all his children’s books,...more
4/18/2025
/ Anti-Corruption ,
Bribery ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Corporate Governance ,
Ethics ,
Export Controls ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Sanctions
Share on Twitter Print Share by Email Share Back to top The recent announcement of a pause in the rollout of reciprocal tariffs has created some confusion — and some hope — for multinationals and importers around the world....more
4/14/2025
/ Automotive Industry ,
China ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
Multinationals ,
Retaliatory Tariffs ,
Risk Management ,
Supply Chain ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
On April 3, 2025, President Trump issued the full details of the automotive tariffs, including the exact Harmonized Tariff Schedule (HTS) subheadings to which the automotive tariffs apply. This completed the implementation of...more
4/14/2025
/ Automotive Industry ,
China ,
Customs and Border Protection ,
Foreign Trade Zones ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Supply Chain ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
As detailed in our prior article on “What Every Multinational Company Should Know About … The Rising Risk of Customs False Claims Act Actions in the Trump Administration,” the Department of Justice (DOJ) is encouraging the...more
4/10/2025
/ Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement ,
False Claims Act (FCA) ,
Imports ,
International Trade ,
Multinationals ,
Penalties ,
Risk Management ,
Settlement ,
Tariffs
On April 2, 2025, President Trump implemented the steepest American tariffs in over a century. The implications for numerous multinational companies — including importers, manufacturers, distributors, and retailers — will be...more
4/4/2025
/ Anti-Dumping Duty ,
Automotive Industry ,
China ,
Compliance ,
Corporate Counsel ,
Countervailing Duties ,
Country of Origin ,
Customs and Border Protection ,
Distributors ,
Imports ,
International Trade ,
Manufacturers ,
Multinationals ,
Retailers ,
Supply Chain ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
In less than 100 days, the Trump administration has implemented a dizzying array of new tariffs, significantly increasing costs and complexity for U.S. importers. The administration is keenly aware that companies operating in...more
3/26/2025
/ China ,
Criminal Prosecution ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Statements ,
Foreign Trade Regulations ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Regulatory Requirements ,
Risk Management ,
Risk Mitigation ,
Smuggling ,
Tariffs ,
Trump Administration ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes ,
Wire Fraud
Although we are only two months into the new administration, we have seen a dizzying array of new tariffs that have been proposed, imposed, revoked, suspended, and sometimes reimposed. It can be difficult for importers to...more
3/20/2025
/ Canada ,
China ,
International Trade ,
Mexico ,
Popular ,
Risk Management ,
Section 232 ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trump Administration
On February 20, 2025, the Deputy Assistant Attorney General for the Commercial Litigation Branch at the U.S. Department of Justice (DOJ), Michael Granston, emphasized using the False Claims Act (FCA) to address U.S. Customs &...more
3/7/2025
/ Compliance ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Globally Harmonized System ,
Imports ,
International Trade ,
Misclassification ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trump Administration ,
US Enforce and Protect Act (EAPA) ,
Whistleblowers
Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more
3/7/2025
/ Anti-Money Laundering ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Management ,
Supply Chain
As reported in our prior article, “What Every Multinational Company Should Know About … The New Steel and Aluminum Tariffs (Part I),” President Trump signed two proclamations on February 10, 2025, imposing 25-percent tariffs...more
2/26/2025
/ Compliance ,
Customs and Border Protection ,
Imports ,
International Trade ,
Risk Management ,
Section 232 ,
Steel Industry ,
Supply Chain ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department
What Has President Trump Announced?
On February 10, 2025, President Trump signed proclamations titled Adjusting Imports of Steel Into the United States and Adjusting Imports of Aluminum into the United States. The...more
As an accompaniment to our “What Every Multinational Should Know” biweekly series, below find an update to our “Five Compliance Best Practices” series, which provides quick-hit advice for multinational companies to implement...more
As Trump seeks to raise U.S. tariffs (which currently tend to be among the lowest worldwide), manufacturers, distributors, retailers, and other companies that frequently import (“importers”) must determine the best strategy...more
2/18/2025
/ China ,
Compliance ,
Customs and Border Protection ,
Forced Labor ,
Human Trafficking ,
Imports ,
Risk Management ,
Supply Chain ,
Tariffs ,
Trade Wars ,
Trump Administration ,
US Trade Policies ,
Uyghur Forced Labor Prevention Act (UFLPA)
Everyone knows — or should know — that “The Terminator” is the best Halloween movie release and that “Die Hard” is the best Christmas movie (even though it was released in July). But while it’s hard to come up with a best...more
On February 10 President Trump issued an Executive Order, Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security, signaling a shift in U.S. enforcement priorities regarding...more
Our previous article on What Every Multinational Company Should Know About … Managing Import Risks Under the New Trump Administration (Part I) identified the 12 main import-related risks (and opportunities) likely to arise in...more
1/29/2025
/ Corporate Counsel ,
Customs and Border Protection ,
International Trade ,
Risk Management ,
Supply Chain ,
Tariffs ,
Trade Agreements ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
Uyghur Forced Labor Prevention Act (UFLPA)
During his campaign, President Trump often stated that he would be implementing an “America First” international trade policy, which he said explicitly would include higher tariffs, potentially on imports from the entire...more
1/24/2025
/ America First Trade Policy ,
China ,
Corporate Counsel ,
Export Controls ,
Free Trade Agreements ,
Imports ,
National Security ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trade Relations ,
Unfair or Deceptive Trade Practices ,
United States-Mexico-Canada Agreement (USMCA) ,
USTR