Partners Jacqueline Romero, Matt Caligur and Michael Snarr co-authored a client alert titled “New DOJ-DHS Trade Fraud Guide Raises Risks for Importers and Brokers” that was featured in TheCorporateCounsel.net within an article titled “Tariffs: DHS & DOJ Issue Trade Fraud Guide.” Published Aug. 7, 2026, the article and client alert focus on the recently issued enforcement guide and include some key takeaways on enforcement moving forward:
- Trade fraud enforcement is now a sustained DOJ priority
- Supply chain diligence should be tested against FCA standards
- Documentation should show the analysis, not just the conclusion
- Internal reporting systems are an important first line of defense
- Disclosure decisions should be assessed early
