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

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 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.
CBP Issues First Comprehensive Guide to Modifying a Withhold Release Order (WRO)
An update on Anti-Forced Labor guidance issued by US Customs in the context of Withhold Release Orders (WROs).
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CBP Announces Forced Labor Allegations Portal Rollout
On June 20, 2025, U.S. Customs and Border Protection (“CBP”) deployed its new Forced Labor Allegations Portal, which allows users to submit allegations of forced labor. The new portal replaces CBP’s Trade Violations Reporting (“TVR”) system for submitting forced labor allegations, and complaints can be submitted anonymously by trade users. Users are also able…
Let’s Talk FCA: Growing FCA Risks Amidst “America First” Trade Policy
In this episode, Crowell’s hosts Agustin Orozco and Jason Crawford speak with Crowell attorneys Simeon Yerokun and Katherine Quinn about DOJ’s plan to aggressively use the FCA against illegal foreign trade practices. This episode includes discussion of common areas of FCA enforcement in cases involving allegations of customs fraud, and the hosts address steps that…
Client Alert: Aggressive FCA Enforcement in Customs Calls for Compliance Review
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…
CBP Proposes Rule Imposing Greater Regulation of De Minimis Imports
U.S. Customs and Border Protection (CBP) issued a notice of proposed rulemaking concerning the de minimis exemption under 19 U.S.C. § 1321 (Section 321). Currently, the de minimis exemption allows goods with an aggregate value under $800 to enter the U.S. duty-free and via an expedited process. The proposed amendment is intended to stem the…
Global Trade Talks: Forced Labor – Mitigating Risk in Auto Industry and Other Sectors
Global Trade Talks is a podcast that shares brief perspectives on key global issues on international trade, current events, business, law, and public policy as they impact our lives. In this session, hosts and International Trade Practice Leaders Nicole Simonian and Dj Wolff talk with Crowell lawyers David Stepp and Simeon Yerokun about Uyghur Forced…
DHS Adds Chinese Firms to Entity List for UFLPA Violations
Following the United States House Select Committee on Strategic Competition between the United States and the Chinese Communist Party (“Chinese Select Committee”) request in January calling for a strengthened enforcement of the UFLPA, DHS adds 26 new entities to the UFLPA entity list.
The United States Department of Homeland Security (“DHS”) announced today the addition…
New Reports Document Best Practices for Avoiding Uyghur Forced Labor in RE Supply Chains
Jan. 25, 2024—The United Kingdom (“UK”)-based Anti-Slavery International, in combination with the Investor Alliance for Human Rights and the Helena Kennedy Centre for International Justice at Sheffield Hallam University, has published a series of reports addressing the issue of forced labor in solar and electric vehicle supply chains relating to Uyghur and other Turkic ethnic…
Customs Ruling of the Week – Classification and Subheading Applicability of a Rotation Cushion
Main Idea: HTSUS Chapter 98, Subchapter 17, U.S. Note 4(b) exclusions are determined based on weighing all criteria. Although a product may meet the definition outlined in U.S. Note 4(a), they may fit the criteria outlined in U.S. Note 4(b) and therefore be excluded.
In ruling N330488 (Feb. 9, 2023), Customs and Border Protection (CBP)…