Administration Heightens Enforcement Focus on Tariff Evasion & ‘Transshipment’

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Paul, Weiss associate Brandon Rosenberg contributed to this report. 

As the Trump Administration tightens the screws on tariff evasion, it’s also introduced a new area of focus: “transshipment.” Jessica Carey, Roberto Gonzalez, Samuel Kleiner & Samuel Rebo of law firm Paul, Weiss explore what the administration’s America-first trade policy means for importers and other companies involved in global supply chains.

As the Trump Administration continues to use tariffs in furtherance of its America-first trade policy, the administration has signaled an increased focus on tariff evasion and “transshipment” as enforcement priorities. Tariff evasion has emerged as a top priority for the DOJ, and the White House has established new “transshipment” tariffs.

The DOJ has emphasized that “tariff evasion” is an enforcement priority and it is reportedly establishing a new unit that will focus on bringing tariff evasion cases. The department has already brought a number of tariff evasion cases under the False Claims Act this year. Most recently, in mid-August the DOJ announced a $12.4 million settlement under the False Claims Act with a Texas-based company and its president for allegedly evading duties on imports from China. Assistant Attorney General Brett A. Shumate said the DOJ “will zealously…

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