From Civil to Criminal: Increased Enforcement of Forced Labor Violations

From Civil to Criminal: Increased Enforcement of Forced Labor Violations

In the latest series of developments, U.S. Immigration and Customs Enforcement (ICE) plans to launch criminal investigations—within the next two years—against executives whose companies have benefited from forced labor in their supply chains. This is a considerable step up from limiting prosecutions to civil penalties, as criminal proceedings could end in 20-year prison sentences for…

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Penalties Increase for Export Violations

Penalties Increase for Export Violations

The Department of Commerce and Department of State have increased the civil monetary penalties for export violations to account for inflation. Regardless of when the violation occurred, it is important to recognize that these new amounts are retroactive and can be charged against each violation. Here is a summary of the penalty increases: The maximum…

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Why the Court of International Trade Punished a First-Time, Small Importer with Over $250K in Fines

Why the Court of International Trade Punished a First-Time, Small Importer with Over $250K in Fines

Importers are facing ever-evolving constraints from U.S. Customs and Border Protection (CBP) decisions now more than ever. Achieving and maintaining compliance through Reasonable Care and proper documentation is pertinent to avoid penalties, seizures of cargo, or criminal charges. “A Tangled Web of Changing Stories and Disputed Consequences” On April 22, 2019 the Court of International Trade…

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