Seizures, penalties and forfeiture
Currency seizures at the airport, 19 U.S.C. § 1592 penalties, liquidated damages, False Claims Act.
- IEEPA refunds and CAPE
- Section 232
- Section 301 and China
- Antidumping and countervailing duties
- Seizures, penalties and forfeiture
- Customs compliance
- Export controls and sanctions
- FMC and maritime
- Forced labor and UFLPA
- Trade agreements and origin
- Intellectual property
- Business and litigation
- Trade policy
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U.S. Department of Justice Announces Creation of Global Trade & Commerce Enforcement Section and Stricter Civil and Criminal Trade Law Enforcement
In less than one year of operation, the Trade Fraud Task Force (TFTF)- a joint initiative launched in August 2025 by the Department of Justice (DOJ) and the Department of Homeland Security (DHS)- has officially crossed the $1 billion…
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CBP Issues Two New Withhold Release Orders Against Jordanian Garment Manufacturers
On June 23, 2026, U.S. Customs and Border Protection (CBP) issued two new Withhold Release Orders (WROs) against garments produced by Needle Craft Ltd. and Casual Wear Apparel L.L.C., two garment manufacturers located in Jordan.…
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CBP Releases Comprehensive Forced Labor Enforcement Guidance for Importers
On June 12, 2026, U.S. Customs and Border Protection (CBP) released its new Forced Labor Enforcement Operational Guidance for Importers (Publication No. 5560-0526), providing importers with a consolidated reference guide covering the…
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When Importers Cheat Customs: Los Angeles Apparel Company Sentenced for $8 Million Duty Evasion — and Why Whistleblowers Matter
Federal prosecutors recently announced the sentencing of a Los Angeles-based apparel importer and its executives for a sweeping customs fraud and money laundering scheme — a case that highlights how import duty evasion can trigger not…
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Trump Threatens 100% Tariff on BRICS Over Plan to Replace U.S. Dollar as Global Reserve Currency
This weekend President-Elect Donald Trump threatened a 100% tariff on BRICS countries. This is in response to an initiative by the nine member international organization to replace the U.S. Dollar (USD) as the global reserve currency,…
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FMC Increases Penalties for Shipping Act Violations
The Federal Maritime Commission has increased the maximum penalties assessed for statutory violations effective January 15, 2021, as required by the Federal Civil Penalties Inflation Adjustment Act of 2015. The increases are tied to the…
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Have A Billion Dollar Export Penalty? Let’s Not.
This is an old blog we lost during our transfer of site hosting. A record-setting payment of $1,190,000,000.00 by ZTE Corporation of Richardson, Texas (“ZTE”) shows the enormous risks today of underestimating U.S. export enforcement.…
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When the Broker Must be the Importer of Record
The Importer of Record, or “IOR” has a lot of liability for entry. Any penalties resulting from discrepancies relating to classification of the goods or admissibility issues, and the duties to be paid, must be covered financially by the…
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U.S. CBP New Regulations
This is an old blog we lost during our transfer of site hosting. Update on this topic is forthcoming in a future blog. When foreign manufacturers sell below the cost of production or “fair market value”, it is known as “dumping.”…
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Shedding Light on the Gray Market
Counterfeit goods and other methods of product reproduction that infringe upon the intellectual property of the owner are strictly illegal, and heavily regulated, especially within the US. The gray, or “grey”, market however, enjoys…
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FMC Remains Aggressive with Penalties
Since the summer (2015) there have been penalty settlements announced by the Federal Maritime Commission (FMC) which total in excess of $2,000,000.00. Its Bureau of Enforcement (BOE) is the arm of the Commission specifically focused on…
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The Trade Facilitation and Enforcement Act of 2015
The Trade Facilitation and Enforcement Act of 2015 was passed by the Senate on February 11th, 2016 in a 75-20 vote. Now that the bill has been passed by the House and the Senate, the final piece of the puzzle is for President Obama to…
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New BIS Export Enforcement Guidelines
As we start off this new year there are some important new changes to be aware of; this includes the Bureau of Industry and Security’s (BIS) proposed changes to export enforcement guidelines. This bureau is the agency responsible for…
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New Customs Regulations Regarding Trademark Disclosure
On September 18, 2015, US Customs and Border Protection (CBP) published a final rule regarding the disclosure of information on goods suspected of bearing counterfeit trademarks or trade names. This new rule allows Customs to share more…
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CAFRA Seizures
In 2000, the Civil Asset Forfeiture Reform Act (CAFRA) was signed into law. This act was passed as a response to a seizure system that had become rife with abuse as law enforcement agencies seized personal property from citizens,…
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Money Seizures: What You Need to Know
When entering the United States, it is required that all passengers report any amount of money with them that is in excess of or equivalent to $10,000. If there is a failure to correctly report, this money can be seized. This reporting…
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Customs Seizure of Goods In-Transit – Part One: Authority 19 USC 1526
Customs often seizes goods bearing allegedly counterfeit marks which were shipped from a foreign country through the United States with a third country as the final destination. The seizure notice always cites 19 USC 1526(e)[1].…
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Wholesalers To Colombia Beware: Your Business Could Be Part Of An International Money-Laundering Scheme
The Black Market Peso Exchange (BMPE) is a long lived and widely used method for converting Colombian pesos into US dollars and vice versa. Boasting the ability to exchange money at a much lower rate, the BMPE evolved from the black…
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Behind the Scenes: CBP Fines, Penalties, and Forfeitures Processes
Yesterday, the American Bar Association’s Section of International Law hosted a program for its members to hear from and speak directly with CBP Office of Regulations and Rulings, represented by Chief of the Penalties Branch, John…
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Customs Seizure Benefits Florida
In August 2008, a piece of America’s aviation history, the Douglas AD-4N Skyraider*, reentered its home territory under false pretenses, which ultimately led U.S. Customs and Border Protection (CBP) agents to seize the aircraft nearly a…
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Freight Forwarder Settles Charge of Antiboycott Violation for Furnishing Negative Certification of Origin on Shipper’s Invoice
Most trade intermediaries are familiar with the antiboycott provisions contained in Part 760 of the Export Administration Regulations (EAR). These regulations prohibit U.S. persons’ participation in or cooperation with the Arab League’s…
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CBP and CPSC Take Steps To Increase Import Targeting Effectiveness: CPSC To Issue Detention Notices
In 2008, the Consumer Product Safety Improvement Act became law. To implement the Act’s mandate to develop targeting methods to improve consumer safety, CBP and the Consumer Product Safety Commission (CPSC) have joined together to…
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