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From Settlements to Strategy: The Fraud Division’s Trade Enforcement Priority and What It Means for Importers

By Nithya Nagarajan & Kip Randall on September 1, 2026
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On September 1, we posted on the Government Enforcement Report about how a Taiwan-based LED manufacturer and its U.S. subsidiary agreed to pay $5.15 million to resolve False Claims Act allegations that they evaded Section 301 tariffs by transshipping Chinese-origin LEDs through Taiwan. The settlement, announced August 5, 2026 by the U.S. Attorney’s Office for the District of Maryland, also addressed the company’s failure to segregate Chinese-origin component dice from Taiwanese-origin components during manufacturing. The post places this resolution alongside the year’s other major customs-fraud settlements—including the $549.5 million aluminum extrusion case and the $19 million steel importation case—to map the accelerating enforcement trend. It also covers the August 13, 2026 McDonald memo formally designating global trade and commerce as one of the Fraud Division’s five enforcement priorities, with transshipment, country-of-origin fraud, and duty evasion among its stated targets. The post identifies four practical takeaways for importers, from transshipment risk and mixed-origin sourcing liability to whistleblower exposure and the signals sent by the Fraud Division’s permanent enforcement posture.

Read the full post here.

Tags: Trump Tariffs
Photo of Nithya Nagarajan Nithya Nagarajan

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory…

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory actions before the Department of Commerce, International Trade Commission and U.S. Customs and Border Protection (CBP) and defends clients in appeals before the Court of International Trade, Court of Appeals for the Federal Circuit, NAFTA panels and the World Trade Organization. In addition to her body of U.S. experience, Nithya is also well-versed in international trade issues in China and India.

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Photo of Kip Randall Kip Randall

A former Army officer, Kip now helps corporate and individual clients navigate government investigations. Kip counsels clients through investigations by the Securities and Exchange Commission (SEC); Environmental Protection Agency (EPA); Internal Revenue Service (IRS); Department of Justice (DOJ), including allegations of antitrust and

…

A former Army officer, Kip now helps corporate and individual clients navigate government investigations. Kip counsels clients through investigations by the Securities and Exchange Commission (SEC); Environmental Protection Agency (EPA); Internal Revenue Service (IRS); Department of Justice (DOJ), including allegations of antitrust and False Claims Act violations; and state attorneys general. As a member of the eDiscovery Solutions group, Kip works at the intersection of eDiscovery and Government Investigations.

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  • Posted in:
    Administrative and Regulatory, Antitrust, Competition and Trade
  • Blog:
    International Trade Insights
  • Organization:
    Husch Blackwell LLP
  • Article: View Original Source

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