In a recently published Bloomberg Law article, “Aggressive FCA Enforcement in Customs Calls for Compliance Review,” Crowell’s Agustin Orozco, Jason Crawford, and Katherine Quinn discuss how importers face increased risk of False Claims Act enforcement as the Department of Justice focuses on illegal foreign trade practices. The article explains how FCA liability arises in the trade context, discusses common customs fraud enforcement actions, and highlights additional civil and criminal enforcement risks. The article also outlines steps companies can take to minimize their exposure.

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Photo of Agustin D. Orozco Agustin D. Orozco

Agustin D. Orozco is a partner in the Los Angeles office and is a member of the firm’s White Collar & Regulatory Enforcement and Government Contracts groups. As a former federal prosecutor, Agustin is a skilled trial lawyer focused on directing complex white…

Agustin D. Orozco is a partner in the Los Angeles office and is a member of the firm’s White Collar & Regulatory Enforcement and Government Contracts groups. As a former federal prosecutor, Agustin is a skilled trial lawyer focused on directing complex white collar cases and investigations, handling contentious and sophisticated pretrial litigation, and successfully proving highly difficult cases at trial. Agustin’s background as a federal prosecutor and government contracts attorney leaves him uniquely situated to help clients where government contracts and white collar intersect.

Agustin represents clients in criminal and civil government investigations and enforcement actions. He also represents and counsels clients on matters involving federal, state, and local government contracts. Agustin has litigated civil False Claims Act (FCA) matters and other government contracts issues, such as disputes, claims, and terminations. He is also experienced in matters involving the Foreign Corrupt Practices Act (FCPA), including conducting investigations abroad and counseling clients on compliance issues.

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Photo of Jason Crawford Jason Crawford

When facing government investigations or high stakes litigation, clients trust Jason Crawford to evaluate allegations, identify risks, and formulate strategies to achieve the appropriate resolution. Jason advises and advocates for government contractors and companies from regulated industries in matters involving civil, criminal, and…

When facing government investigations or high stakes litigation, clients trust Jason Crawford to evaluate allegations, identify risks, and formulate strategies to achieve the appropriate resolution. Jason advises and advocates for government contractors and companies from regulated industries in matters involving civil, criminal, and administrative enforcement, with a particular focus on the False Claims Act (FCA).

As a litigator, Jason has defended government contractors, drug manufacturers, grant recipients, health care companies, importers, and construction companies sued under the FCA by whistleblowers and the Department of Justice (DOJ) in federal courts throughout the country. He also helps clients conduct complex internal investigations and respond strategically to Office of Inspectors General inquiries, grand jury investigations, search warrants, and civil investigative demands.

Jason previously served as a DOJ Trial Attorney in the Civil Division, Fraud Section where he investigated and litigated FCA cases involving government contractors, importers, and health care companies. He also previously worked with the U.S. Attorney’s Office for the District of Columbia where he prosecuted federal criminal cases.

A recognized thought leader on FCA developments, Jason has written and presented extensively on the fraud statute, and he is a co-host of the Let’s Talk FCA podcast.

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Photo of Simeon Yerokun Simeon Yerokun

imeon Yerokun is a counsel in Crowell & Moring’s International Trade group and based in the firm’s Washington, D.C. office. He advises clients on all areas of import regulatory compliance, trade remedies, and international trade litigation.

Simeon has extensive experience counseling companies in

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imeon Yerokun is a counsel in Crowell & Moring’s International Trade group and based in the firm’s Washington, D.C. office. He advises clients on all areas of import regulatory compliance, trade remedies, and international trade litigation.

Simeon has extensive experience counseling companies in the areas of business and human rights law, including compliance with global anti-forced labor and human rights requirements. He regularly represents companies before U.S. government agencies on forced labor-related matters, including securing the release of goods detained and seized by U.S. Customs and Border Protection. He also offers deep experience assisting companies in mapping their supply chains, including linking imported products back to their raw materials using enterprise software and other inventory management audit tools. Simeon is highly accomplished in forced labor supply chain mapping and risk assessments, as well as verifying due diligence efforts with on-the-ground visits to client facilities, incorporating third-party intelligence and audit resources.

Simeon’s experience also covers a broad spectrum of trade and customs issues, including those related to import regulatory compliance matters such as valuation, classification, duty drawback, marking and labeling, entry procedures, and penalties; free trade agreements; antidumping and countervailing duty issues; trade litigation; intellectual property issues such as trademark and copyright infringement; the enforcement of exclusion orders issued by the International Trade Commission (ITC); steel and aluminum tariffs under the Section 232 National Security Investigation; and the additional tariffs on products from China under Section 301 of the Trade Act of 1974.

Additionally, Simeon handles antidumping (AD) and countervailing duty (CVD) investigations before the U.S. Department of Commerce’s International Trade Administration (ITA) and the U.S. International Trade Commission (ITC) under the Tariff Act of 1930, and litigation involving the U.S. Court of International Trade (CIT).

Prior to joining Crowell, Simeon was a trade and finance attorney in the Office of Chief Counsel—U.S. Customs and Border Protection (CBP), and before that, he served as counsel to Commissioner Irving A. Williamson at the U.S. International Trade Commission.

Simeon is a proud graduate of Howard University School of Law, where he served as technical editor of the school’s Human Rights and Globalization Law Review.

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Photo of David H. Favre David H. Favre

David’s practice focuses on government contracts and white collar matters, including investigations and bid protests.  He draws on his prior service at the U.S. Court of Federal Claims to help counsel government contractors on a range of issues.

David advises clients on government

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David’s practice focuses on government contracts and white collar matters, including investigations and bid protests.  He draws on his prior service at the U.S. Court of Federal Claims to help counsel government contractors on a range of issues.

David advises clients on government investigations and bid protests before the Government Accountability Office and the U.S. Court of Federal Claims. With the challenge of meeting accelerated timelines and complex bid protest requirements, his prior government experience adds value to the strategies he recommends to clients.

Before joining the firm, David clerked for the Honorable Richard A. Hertling on the U.S. Court of Federal Claims.

While at Georgetown University Law Center, David represented juveniles in delinquency proceedings in D.C. Superior Court with the Juvenile Justice Clinic. He served on the American Criminal Law Review, where he was an editor of the Annual Survey of White Collar Crime articles on health care fraud, Racketeer Influenced and Corrupt Organizations, and false statements and false claims. He also interned for the Honorable Rosemary M. Collyer on the U.S. District Court for the District of Columbia.

David served as a combat engineer in the U.S. Marine Corps. He is a veteran of Operation Enduring Freedom in Afghanistan.

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Photo of Katherine Quinn Katherine Quinn

Katherine Quinn is an associate in the firm’s Washington, D.C. office, where she practices in the White Collar and Regulatory Enforcement group.

Prior to joining Crowell, Katherine served as a law clerk for the Honorable Reggie B. Walton of the U.S. District Court

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Katherine Quinn is an associate in the firm’s Washington, D.C. office, where she practices in the White Collar and Regulatory Enforcement group.

Prior to joining Crowell, Katherine served as a law clerk for the Honorable Reggie B. Walton of the U.S. District Court for the District of Columbia. She also previously worked as a law firm associate, focusing on commercial litigation and regulatory insurance matters.

Katherine received her J.D. from the University of Virginia School of Law, where she was an articles editor for the Virginia Law & Business Review and a member of the Criminal Defense Clinic. She also competed as a finalist in UVA’s 2019 Lile Moot Court Competition. During her undergraduate studies, Katherine was an NCAA Division I student-athlete and captain of the soccer team.

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