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ARTICLE · 23 JUNE 2023

International Trade, Enforcement & Compliance Recent Developments Update (June 21, 2023)

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Recent developments include fair warning from the Department of Justice that national security concerns can invade even ordinary business activities...

United StatesInternational Law
Gregory Husisian
Gregory Husisian
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Welcome to Foley's International Trade, Enforcement & Compliance Recent Developments Update

Recent developments include fair warning from the Department of Justice that national security concerns can invade even ordinary business activities, a reminder that the False Claims Act increasingly is being used as a weapon against companies that underpay Customs duties, and a multimillion-dollar message that federal judges find it kind of fishy to see price fixing between competitors.

National Security Risks

According to Principal Associate Deputy Attorney General Marshall Miller, the Department of Justice is finding that two-thirds of the DOJ's major corporate criminal resolutions are now implicating U.S. national security. According to Mr. Miller, "[E]ven business operations and lines far removed from the defense sector - cigarettes, cement, information technology - can pose dire national security risks if the company is not highly sensitive to high-risk actors,

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