On November 19, Ashley Craig, Elizabeth Lowe, George Kostolampros, Nicholas Mongelluzzo, Ashley Luong, and Daniel Everson published, “How Tariff Evasion Heightens False Claims and Anti-Corruption Risks” in the Anti-Corruption Report. The following is an excerpt:
Unpredictable and oft-changing tariff developments in the United States continue to dominate re-cent news cycles and underscore the challenges faced by U.S. importers and their supply chain partners, including increased risks of possible tariff evasion schemes.
In response to these increased risks, the DOJ has promised – in a May 2025 memorandum on white-collar criminal enforcement priorities issued by Acting Assistant AG Matthew Galeotti (Focus Memo) – to crack down on tariff evasion. The Focus Memo announces that resources will be concentrated on “threats to the U.S. economy, American competitiveness, and our national security” in an effort to root out “[t]rade and customs fraudsters.”
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