Corruption Crime & Compliance Episode 389 -- 2025 Review of Trade Enforcement
6 snips
Jan 28, 2026 A brisk review of 2025 trade enforcement trends, from criminal indictments to administrative upticks at OFAC and BIS. The expanding use of the False Claims Act to target tariff and customs evasion is highlighted. Legal developments and court rulings shaping FCA jurisdiction get attention. Practical risks for importers and cooperation lessons from major resolutions are also explored.
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Trade Enforcement Remains The Top Risk
- Trade enforcement (sanctions and export controls) remained the top compliance risk in 2025 with continued government focus.
- OFAC and BIS increased activity in 2025, though OFAC enforcement was concentrated in a few big Russian-related cases.
High-Profile Multi-Agency Resolutions
- The Cadence Design Systems resolution followed DOJ's multi-agency model and resulted in a guilty plea and a $140 million payment.
- The White Deer/Unicat matter showed the value of post-closing audits and prompt voluntary disclosure, yielding a cooperation credit and a $3.3 million forfeiture for Unicat.
Refresh Trade Compliance Programs Now
- Reexamine and invest in your trade compliance program as DOJ has prioritized sanctions and export-control enforcement.
- Treat trade compliance refreshes as essential for the new administration and reallocated DOJ resources.