Gibson Dunn Lawyers Discuss the Application of the FCA in Relation to Trade and Customs Matters Following the Introduction of Tariffs

Article  |  April 30, 2025

Global Trade

In “Trump Tariffs Promise Increased False Claims Act Scrutiny for Companies Throughout the Import Chain” (Global Trade, April 17, 2025), partner Jake Shields and associates Michael Dziuban and Andrew Becker discuss the application of the False Claims Act (FCA) in relation to trade and customs matters following the introduction of tariffs.

With President Trump imposing steep tariffs on key U.S. trading partners and the Department of Justice (DOJ) simultaneously promising to ramp up use of the FCA — its primary tool against fraud on government agencies — to police tariff compliance, the effect, say our lawyers, “will likely be a redoubling of DOJ’s already aggressive application of the FCA to trade matters, fueled by tariffs’ status as a top policy and political priority. The risks for businesses are significant.”

Jake previously served as Senior Trial Counsel in the Fraud Section of the Civil Division of the U.S. Department of Justice, where he investigated and litigated False Claims Act cases, including in the areas of customs and tariffs enforcement.

Read the full article here: https://www.globaltrademag.com/trump-tariffs-promise-increased-false-claims-act-scrutiny-for-companies-throughout-the-import-chain/.