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
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
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)
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
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has promulgated a Final Rule prohibiting the import and sale of connected vehicles and related components linked to the People’s Republic of China (PRC)...more
1/16/2025
/ Automation Systems ,
Automotive Industry ,
Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Cybersecurity ,
Final Rules ,
National Security ,
OEM ,
Regulatory Requirements ,
Russia ,
Supply Chain ,
Transparency ,
U.S. Commerce Department
The expected focus on tariffs and supply chain issues by the Trump administration presents significant risks for frequent importers. Determining the best strategy to deal with potential import uncertainties are muddled by...more
1/9/2025
/ Anti-Dumping Duty ,
China ,
Compliance ,
Countervailing Duties ,
Customs and Border Protection ,
Free Trade Zone ,
Government Agencies ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Relations ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
Uyghur Forced Labor Prevention Act (UFLPA)
The U.S. government has increasingly emphasized the importance of supply chain integrity, particularly in relation to eliminating forced labor. U.S. policymakers are actively passing legislation, including the Uyghur Forced...more
12/5/2024
/ Automotive Industry ,
China ,
Compliance ,
Customs and Border Protection ,
Due Diligence ,
Forced Labor ,
Human Trafficking ,
Multinationals ,
Regulatory Requirements ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA)
We have received requests to publish a comprehensive set of Customs and import compliance best practices that covers all aspects of importation and supply chain management. As part of this series, the topic this week is best...more
10/24/2024
/ Brokers ,
Compliance ,
Customs ,
Documentation ,
Duties ,
Fraud ,
Freight Forwarding ,
Importers ,
Multinationals ,
Recordkeeping Requirements ,
Regulatory Requirements ,
Risk Management ,
Supply Chain
Share on Twitter Print Share by Email Share Back to top On September 26, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) published a Notice of Proposed Rulemaking that, if finalized, would prohibit...more
10/11/2024
/ Automotive Industry ,
Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Data Collection ,
Driverless Cars ,
Due Diligence ,
Export Controls ,
Foreign Adversaries ,
Hardware ,
International Trade ,
Proposed Rules ,
Recordkeeping Requirements ,
Russia ,
Software ,
Supply Chain ,
Vulnerability Assessments
Share on Twitter Print Share by Email Share Back to top Conducting effective cross-border internal investigations is more critical than ever for companies facing increasingly complex regulatory frameworks across the globe....more
10/10/2024
/ Attorney-Client Privilege ,
California Consumer Privacy Act (CCPA) ,
Compliance ,
Confidentiality Policies ,
Data Privacy ,
General Data Protection Regulation (GDPR) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
India ,
Internal Investigations ,
Japan ,
Multinationals ,
Sweden ,
Whistleblowers
Many Americans value domestically made goods. A “Made in USA” label can hold special meaning for these consumers, as it serves as a symbol of patriotism, a sign of quality craftsmanship, and a show of solidarity with local...more
9/12/2024
/ Buy American Act ,
Country of Origin ,
Customs and Border Protection ,
Due Diligence ,
Federal Trade Commission (FTC) ,
FTC Act ,
Labeling ,
Made in the USA ,
Marketing ,
Multinationals ,
Penalties ,
Regulatory Standards
CFIUS is an interagency committee that evaluates the national security implications of foreign investments on the U.S. economy and infrastructure. CFIUS possesses statutory authority to “make an investigation to determine the...more
The risks for international investments have sharply expanded in recent years. Identifying, managing, and mitigating investment risk, in the current regulatory environment, can be just as essential as managing risk in any...more
8/2/2024
/ Acquisitions ,
Anti-Corruption ,
Anti-Dumping Duty ,
Anti-Money Laundering ,
Antitrust Provisions ,
CFIUS ,
Compliance ,
Countervailing Duties ,
Due Diligence ,
ECCNs ,
Employee Training ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Imports ,
Mergers ,
Military Service Members ,
Multinationals ,
Supply Chain ,
Tariffs ,
Uyghur Forced Labor Prevention Act (UFLPA)
The United States-Mexico-Canada Agreement (USMCA) automotive sector must be prepared to navigate a new set of requirements that will likely reshape supply chains, impact costs, and alter the competitive dynamics within the...more
...As covered in previous articles in our biweekly series, the U.S. government maintains prohibitions on participating in the Arab League boycott of Israel. Especially for companies that frequently deal with the Middle East,...more