On December 19, 2025, the Department of Justice (DOJ) announced a $54.4 million settlement with Ceratizit USA, LLC, a distributor of tungsten carbide products, resolving allegations that the company violated the False Claims Act (FCA) by evading customs duties on products imported from China. This settlement is believed to be the largest ever customs-related
Department of Justice
Joint Criminal and Civil Export Controls Enforcement: Lessons from the Cadence Case
On July 28, 2025, Cadence Design Systems Inc., a global electronic design automation technology company based in San Jose, California, agreed to plead guilty to export violations in a settlement with the U.S. Department of Justice’s National Security Division and the U.S. Attorney’s Office for the Northern District of California, and resolved a civil enforcement…
US Tariff Enforcement Risk Continues to Rise as DOJ Assigns Unit to Criminally Prosecute Violators
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…
Client Alert: DOJ Reprioritizes Corporate Enforcement with Key Policy Revisions
In a May 12, 2025 speech that signaled both a recalibration of and recommitment to prosecuting white-collar crime, Matthew R. Galeotti, the newly appointed Head of the Department of Justice’s Criminal Division, said that the Division is “turning a new page” and embracing an enforcement approach that aims to elevate efficiency, predictability, and fairness. The…
DOJ Announces Safe Harbor for Acquirers Who Disclose Pre-Acquisition Misconduct
On October 4, 2023, Deputy Attorney General (DAG) Lisa O. Monaco announced the Department of Justice’s (DOJ) new safe harbor policy for voluntary self-disclosures made in connection with mergers and acquisitions (Safe Harbor Policy).
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DOJ, OFAC, and BIS Issue “Tri-Seal Compliance Note” Focusing on Voluntary Self-Disclosures
- Key takeaway #1 Companies should be mindful that the U.S. agencies responsible for civil and criminal export controls and sanctions compliance maintain separate VSD policies. This announcement highlights key aspects of each VSD policy.
- Key takeaway #2 Failure to initiate an internal investigation promptly after discovering a potential export controls or sanctions
The United States Imposes New Sanctions and Export Controls Targeting Russia and Belarus, Issues Joint Compliance Guidance, and Announces Corporate Compliance with Sanctions and Export Controls as an Enforcement Priority
On February 24, 2023, the United States and other G7 nations announced a number of new sanctions and export control measures coinciding with the one-year mark of Russia’s military invasion of Ukraine. Shortly after these expansive sanctions and export controls were announced, the Departments of Justice (“DOJ”), the Treasury (“Treasury”), and Commerce (“Commerce”) issued their…
New U.S. Disruptive Technology Strike Force Highlights Risks for Research Facilities and Universities in the U.S.-China Competition for Technical Supremacy
Last week the U.S. Department of Justice (“DOJ”) and U.S. Department of Commerce announced a new Disruptive Technology Strike Force (the “DIS-TECH Strike Force”). The Strike Force will bring together experts throughout government – including the Federal Bureau of Investigation (“FBI”), Homeland Security Investigations (“HSI”), and 14 U.S. Attorneys’ Offices in 12 metropolitan regions across…
DOJ’s “Déjà vu All Over Again” for Corporate Crime
On October 28, Deputy Attorney General (“DAG”) Lisa O. Monaco delivered remarks at the ABA’s 36th National Institute on White Collar Crime. Department of Justice (“DOJ” or “Department”) officials have recently referenced the coming enforcement “surge,” and the DAG’s remarks last week provide a roadmap to corporate criminal enforcement under the current…
Preparing for the “Surge”: Enhanced Corporate Enforcement is Coming
After a predictable lull in corporate enforcement actions during the recent transition between administrations, and following a near quarter-century low in such actions under the previous administration, the Department of Justice (“DOJ”) announced this week that a “surge” of corporate enforcement is coming. Recent comments from DOJ officials indicate that, in addition to a significant…