Are your trade compliance programs truly airtight - or are they just good enough to get caught? In this episode, Michael breaks down why tariff and trade violations are now squarely on DOJ’s radar, and why the heat is rising fast for importers, especially those dealing with Chinese goods. With enforcement priorities shifting, companies are at increased risk of both regulatory investigations and full-blown criminal prosecutions. This episode is a wake-up call for compliance professionals and legal teams - if you think tariff enforcement is still a civil issue, think again.
You’ll hear him discuss:
- Why Customs and Border Patrol and Homeland Security Investigations are stepping up referrals and actions
- How companies try to gain a competitive advantage by evading tariffs - and why it’s an “inevitable result” regulators are watching closely
- The most common tariff evasion schemes, including misclassification under HTS codes, transshipment, undervaluation, and false certification of origin
- Why importing from China under Section 301 is now considered a high-risk activity
- The specific risks surrounding steel and aluminum imports under Section 232 tariffs
- Examples of recent DOJ cases, including plywood, flooring, and mosaic tile fraud, and what they signal for future enforcement
- How AI and data analytics are being used by investigators to spot anomalies and build cases
- The difference between Section 301 and 232 tariffs - and how they reflect different policy objectives
- How rising tariffs and fewer exclusions under the Trump administration are reshaping the trade compliance landscape
- The statutes DOJ is using for criminal charges, including 18 U.S.C. §§ 371, 545, and 1341
Resources
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The Volkov Law Group
