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Abbey offers pragmatic counsel to clients, helping protect their businesses during turbulent times and navigating through their most significant and sensitive government and internal investigations.

Summary

On August 29, 2025, the U.S. Department of Justice (DOJ) announced the formation of a cross-agency Trade Fraud Task Force in partnership with the Department of Homeland Security (DHS). This initiative is designed to strengthen enforcement against importers and other parties who seek to defraud the U.S. by evading tariffs, duties, and other trade regulations. The Trade Fraud Task Force is focused on ensuring compliance with trade laws, including all applicable tariffs and duties, such as antidumping and countervailing duties, as well as Section 301 tariffs on Chinese-origin goods. The task force will leverage resources and expertise from both DOJ’s Civil and Criminal Divisions, and DHS agencies, including U.S. Customs and Border Protection (CBP), and Homeland Security Investigations (HSI).

The Trump administration’s implementation of tariffs on August 7, 2025, will have profound implications for companies engaged in international supply chains. These tariffs are poised to increase business costs, affecting a wide range of industries reliant on global trade. However, the financial impact is not the only concern for businesses. With the Department of Justice (DOJ) intensifying its focus on enforcement actions related to international trade compliance, companies that attempt to evade these tariffs or fail to establish robust compliance policies and procedures may find themselves among the DOJ’s targets.

On May 19, 2025, the U.S. Department of Justice (DOJ) announced the launch of a Civil Rights Fraud Initiative, which will use the False Claims Act (FCA) as a basis for investigating the diversity, equity, and inclusion (DEI) practices of recipients of federal funds, including colleges and universities who receive Title IV student financial aid and research grants. Calling out academic institutions specifically, the Civil Rights Fraud Initiative will invoke the FCA “against those who defraud the United States by taking its money while knowingly violating civil rights laws.”