Compliance into the Weeds Special Holiday Episode: MGI’s Compliance Triumph in DOJ Tariff Evasion Case
Dec 31, 2025
Delve into the fascinating world of compliance with a gripping case of tariff evasion at MGI International. Explore how self-disclosure and robust internal investigations earned them a declination from the DOJ. The discussion includes insights on the importance of cooperation and the implications for future compliance policies. Hear about the COO's guilty plea and the evolving DOJ landscape that encourages voluntary disclosures. It's a roadmap for navigating the complexities of compliance, wrapped in an engaging holiday context!
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Follow The Voluntary Self-Disclosure Roadmap
- Do voluntarily self-disclose, fully cooperate, and remediate to maximize chances of a DOJ declination.
- Target the individual wrongdoer and implement compliance reforms to demonstrate good-faith remediation.
MGI's Discovery And Response
- MGI discovered its COO orchestrated tariff-evasion by falsifying country-of-origin paperwork for resins from China.
- The company suspended and later fired the COO, self-disclosed to DOJ, cooperated, and pursued internal and civil resolutions.
Senior Execs Aren't An Automatic Deal-Breaker
- Declinations can occur even when senior executives commit the misconduct if the company provides exceptional cooperation and remediation.
- Senior management involvement is an aggravating factor but not an absolute bar to favorable DOJ treatment.