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Takeaways The Trade Fraud Task Force is now operational, with DOJ and DHS resolving high-dollar enforcement actions that targeted alleged tariff and customs fraud involving China-origin imports. The trio of actions reflect DOJ’s readiness to pursue a combination of criminal charges, civil FCA liability and individual accountability for alleged trade violations. Country-of-origin misstatements and transshipment schemes of Chinese merchandise are emerging as primary enforcement targets.
After months of anticipation, on February 1, 2025, President Trump announced the imposition of significant tariffs on Mexico, Canada, and China through three Executive Orders (EOs). While additional details are expected to be published in the Federal Register in days to come, the tariffs mark a significant shift in U.S. trade policy. Key points are outlined below.
Government investigations pose many risk management challenges. They are unpredictable, political and often public. If handled incorrectly, they can last for many years, spiral into multiple Congressional, criminal, and/or regulatory investigations at the state and federal levels, and generate serious reputational harm. Potential targets can take proactive steps to mitigate their risks.
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