A serious step up in civil and criminal enforcement of customs laws, including tariff evasion, is imminent. In a May 12 memorandum, the Department of Justice’s new Chief of the Criminal Division, Matthew Galeotti, counted as one of the “most urgent” threats to the country “[t]rade and customs fraud, including tariff evasion.” Earlier in the Administration, in a February 2025 speech, Michael Granston, Deputy Assistant Attorney General for the DOJ’s Commercial Litigation Branch identified, as a key example of new enforcement activity, efforts to enforce payment of customs duties on imported goods and reiterated that enforcement against “illegal foreign trade practices” would be a priority for the Administration. Continue Reading Department of Justice Tariff Enforcement Likely to Surge After Tariff Increases and the Administration’s Increased Focus on Protecting Domestic Business

The U.S. Department of Justice (DOJ)’s new data security rule went into effect April 8, 2025. The rule creates what are effectively export controls and requires companies to take measures to prevent U.S. sensitive personal and government-related data from falling into the hands of foreign adversaries. The rule targets transactions (including data brokerage, vendor agreements, employment agreements, and investment agreements) involving access to bulk sensitive personal data or government-related data when those transactions involve identified covered persons or countries of concern (China, Russia, Iran, North Korea, Cuba, and Venezuela). Continue Reading DOJ Announces 90-Day Grace Period for Companies to Comply with New Data Security Rules on Foreign Adversary Access to U.S. Sensitive Data

On October 29, 2024, the Department of Justice (DOJ) published its Proposed Rule outlining prohibitions and restrictions on certain transactions involving bulk U.S. sensitive personal data and U.S. Government-related data. As you may recall from our previous article, this rule stems from recent Executive Order (EO) 14117 on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern.” The Proposed Rule has potential implications for any business that collects, retains, or deals in data on U.S. persons or certain other data relating to the U.S. Government. Here, we discuss some of the more interesting developments in the Proposed Rule and how it could affect your business.Continue Reading Data, Deals, and Diplomacy, Part II: Big Obligations for Big Data