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International Trade

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ICYMI: Electronics Company Pays $11.8M to Resolve Duty Evasion Allegations

The Department of Justice announced that Harman International Industries, Inc., an audio electronics company, agreed to pay $11.8M to settle allegations of evading duties on goods made of aluminum from China.

What Happened

For a period of over ten years, from June 2011 to March 2023, Harman knowingly imported heat sinks that contained extruded aluminum from China without paying the required antidumping and countervailing duties (AD/CVD).

The settlement also reveals that when Harman discovered its failure to pay AD/CVD, the company concealed this fact and decided not to disclose it to the U.S. government. 

This case arose from a whistleblower lawsuit filed under the False Claims Act, which permits private parties to file suit on behalf of the United States for false claims and share in a portion of the government’s recovery. The whistleblower in this case will receive over $2M of the settlement proceeds.

Enforcement is a Top Priority for the U.S. Government

High tariffs in the current trade environment have created a higher incentive to cheat. The U.S. government has made clear that enforcing customs laws is a top priority. 

For example, on May 12, 2025, Matthew Galeotti, the Head of the U.S. Department of Justice’s Criminal Division, sent a memo to all criminal division personnel highlighting the focus areas of the division for white-collar crime.

The memo included a […]

By |2025-12-12T09:10:25-05:00December 12, 2025|Enforcement, Import, International Trade, U.S. Customs and Border Protection (CBP), U.S. Department of Justice (DOJ)|0 Comments
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New WRO Issued Against Goods Made in Mauritius by Firemount Group

U.S. Customs and Border Protection (CBP) issued a  Withhold Release Order (WRO) against imports made in Mauritius by manufacturer Firemount Group Ltd. (Firemount) after an investigation indicated forced labor use. This WRO was the fourth issued in 2025. CBP now oversees and enforces 54 WROs and nine Findings.

What Happened

On November 18, 2025, CBP issued the WRO against garments, apparel, and textiles manufactured in Mauritius by Firemount. CBP will immediately detain imports subject to the Order. The WRO was issued based on information that reasonably indicates forced labor was used in violation of 19 U.S.C. §1307.

In making this determination, CBP conducted an investigation and analyzed supporting evidence, including interview questionnaires, audio recordings and transcripts, open-source reports from nongovernmental organizations, news media, and academic research.  

The evidence demonstrated that Firemount workers are subject to four International Labour Organization indicators of forced labor: abuse of vulnerability, debt bondage, deception, intimidation, and threats. 

WRO Background 

The strategic use of WROs by CBP has been especially effective at identifying certain nations, industries, and companies that employ forced labor. CBP issues WROs after receiving information that reasonably indicates the use of prison or forced labor at any point in an imported product’s supply chain. Before the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), the United States had only implemented 30 WROs in the previous five decades. […]

By |2025-12-01T10:04:19-05:00December 1, 2025|Enforcement, Forced Labor, Import, International Trade, U.S. Customs and Border Protection (CBP)|0 Comments
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Jewelry Company Charged in $86M Duty Evasion Scheme

On November 17, 2025, the owner of an Indonesian jewelry company (USB Gold) and two employees were charged with taking part in a scheme to evade over $86 million in duties on jewelry imports. 

The employees were arrested and charged with one count of conspiracy to commit wire fraud and were detained. The company co-owner, who was also charged, remains in Indonesia and has not yet been arrested.

The defendants allegedly engaged in a complex scheme to import over $1.2 billion of jewelry and illegally defraud the United States out of more than $86 million in customs duties and tariffs. 

The alleged scheme included two parts:

  • First, UBS Gold made jewelry in Indonesia and shipped it to Jordan, which had a Free Trade Agreement with the United States, before sending it to the United States. The defendants then falsely claimed that UBS Gold jewelry had been manufactured in Jordan, which avoided the duty that would otherwise apply.
  • Second, when the U.S. announced additional tariffs on Indonesia and Jordan earlier this year, the company began shipping scrap gold from the U.S. to Jordan, which they falsely claimed was gold jewelry that simply needed to be assembled or finished in Jordan. Instead, the defendants and co-conspirators swapped the scrap gold for UBS Gold jewelry made in Indonesia, which they then shipped from Jordan to the U.S. The […]
By |2025-11-26T07:43:19-05:00November 26, 2025|Enforcement, Import, International Trade, Pre-compliance, U.S. Customs and Border Protection (CBP)|0 Comments
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ICYMI: Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria

On November 7, 2025, the Office of Foreign Assets Control (OFAC), alongside the U.S. Department of State and the U.S. Department of Commerce, issued a Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria. 

The Advisory follows President Trump’s Executive Order on June 30, 2025, formally removing U.S. sanctions on Syria and directing agencies to take additional measures to encourage U.S. private sector and foreign partner reengagement in Syria.

New Opportunities & Remaining Restrictions

The Advisory outlines what business with Syria is now permissible as well as what restrictions remain.

Permissible Business:

  • The United States no longer imposes comprehensive sanctions on Syria. 
  • The Caesar Act is suspended, except for sanctionable transactions with Russia and Iran.
  • The transfer of most basic civilian use U.S.-origin goods, as well as software and technology, to or within Syria is permitted without a license. 

Remaining Restrictions:

  • Sanctions remain on “the worst of the worst:” Bashar al-Assad and his associates, human rights abusers, drug traffickers, and other destabilizing regional actors.
  • The U.S. Government continues to review Syria’s State Sponsor of Terrorism (SST) designation. 
  • Most Commerce Control List items going to Syria still require a U.S. export license.

What Exporters Should Do

The removal of Syria sanctions and the easing of […]

By |2025-11-24T11:18:20-05:00November 24, 2025|Export, International Trade, U.S. Bureau of Industry and Security (BIS), U.S. Department of Commerce (DOC), U.S. Department of State (DOS), U.S. Office of Foreign Assets Control (OFAC)|0 Comments
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Act NOW to Preserve Potential Tariff Refunds

Tariff policy is changing overnight, and all indicators signal that the Trump Administration will continue to impose tariffs to achieve its trade agenda. There are several lawsuits pending that may eventually invalidate some of the Administration’s tariffs. However, importers should not sit around and wait for the dust to settle. Importers must act NOW and take proactive measures to protect their ability to seek refunds if tariffs are ultimately found to be unlawful. 

IEEPA Tariffs at the Supreme Court

The Supreme Court (SCOTUS) heard oral arguments in Learning Resources, Inc. v. Trump on November 5, 2025. The case challenges whether the President has the authority to impose tariffs under the International Emergency Economic Powers Act (IEEPA). The Administration relied heavily on IEEPA to impose new tariffs – including fentanyl tariffs on China, Canada, and Mexico, and global reciprocal tariffs. Many trade lawyers are predicting that the Court will rule in favor of importers and find that IEEPA does not grant the President the authority to impose sweeping tariffs. 

Potential Refunds & What Importers Should Do

Although it remains unclear how CBP will handle refunds (should SCOTUS agree with the lower courts), it is likely that once an entry is liquidated and the liquidation becomes final, CBP may not grant a refund of duties paid, regardless of SCOTUS’s outcome. It will likely be the position that CBP only has to grant refunds to those parties that have a Court […]

By |2025-11-17T09:01:16-05:00November 17, 2025|International Trade, Pre-compliance, tariffs|0 Comments
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