The Trump administration continues to raise the stakes for importers and other actors in the international trade space. Bloomberg Law reports that the Department of Justice has tasked its MIMF (Market Integrity and Major Frauds) Unit with investigating fraud schemes by companies dodging U.S. tariffs. The MIMF Unit is already well-versed in financial fraud investigations

Derek Hahn
Derek Hahn is a partner in Crowell & Moring's White Collar & Regulatory Enforcement Group and a member of the firm’s Investigation Practice. Derek’s practice focuses on white collar defense, internal investigations, complex litigation, and compliance counseling. He represents clients in an array of government investigations and enforcement actions alleging financial fraud, public corruption, conflicts of interest, counterfeiting, procurement integrity, and health care fraud. Derek has also defended clients in several multi-million dollar environmental enforcement matters at both the federal and state level.
Derek has extensive experience managing matters involving the Foreign Corrupt Practices Act (FCPA) having counseled clients in multiple industries on FCPA matters across six continents. His FCPA experience includes government and internal investigations, third-party due diligence reviews, compliance program and training development, and anti-corruption risk assessments. He has defended multiple FCPA investigations brought by the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC).
Ninth Circuit Decision Underscores Increasing False Claims Act Risks to U.S. Importers
On June 23, 2025, the Ninth Circuit issued a long-awaited decision in Island Industries Inc. v. Sigma Corp. affirming a $26M False Claims Act (“FCA”) judgment against the defendant importer. Sigma had appealed the judgment after a jury found the company violated the FCA by failing to pay customs duties owed to U.S. Customs…
SEC Warns Against Insider Trading Risks from Pandemic Fallout
On March 23, 2020, the co-directors of the SEC’s Division of Enforcement, Stephanie Avakian and Steve Peikin, issued an unambiguous warning against insider trading and other illegal practices stemming from the COVID-19 fallout. In their joint statement, the co-directors explained that “[i]n these dynamic circumstances, corporate insiders are regularly learning new material nonpublic information…
DOJ Centralizes Guidance on “The Evaluation of Corporate Compliance Programs”
On April 30, 2019, the Department of Justice (DOJ) Criminal Division issued an updated version of the “Evaluation of Corporate Compliance Programs” guidance originally published by the Criminal Division’s Fraud Section in February 2017. The update is more of a consolidation of various compliance program evaluation sources under the broader Criminal Division umbrella…
DOJ’s FCPA Pilot Program Issues First Public Declination Under Trump Administration
Jun.21.2017
Last Friday, the Department of Justice publicly disclosed another declination under its FCPA pilot program. This is the sixth public declination by the Department since first launching the program in April 2016 (as previously discussed in a Crowell & Moring alert). It also represents the first public declination since the Department announced the…