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The US Department of Justice (DOJ) has established the permanent Global Trade & Commerce Enforcement Section (GTCES) to investigate and prosecute criminal import, trade, and customs fraud. Working with the Department of Homeland Security, the DOJ also released "A Resource Guide to Trade Fraud Enforcement," its first comprehensive framework on the topic.

This development signals a heightened and enduring government focus on trade compliance. The guide specifically emphasizes the use of the False Claims Act (FCA), including its "reverse false claim" provision, to pursue customs fraud, tariff evasion, and duty underpayment. This substantially increases financial risk for companies, as the FCA allows for treble damages and significant civil penalties, and enables qui tam lawsuits. Corporate counsel should note the guide's focus on robust internal compliance, active supply chain auditing, and the benefits of the DOJ's voluntary self-disclosure policy. Companies should review their trade compliance programs in light of these announced priorities.

The Federal Communications Commission (FCC) has added foreign-produced advanced robotic devices and power inverters to its "Covered List," blocking any new models from receiving the authorization required for importation and sale in the United States. The commission cited unacceptable risks to national security for the move, which follows similar recent restrictions on foreign-produced drones and routers. Existing models that received FCC authorization before July 28, 2026, are not affected and can continue to be imported, sold, and receive software updates.

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The UK government has initiated a call for evidence to assess the potential introduction of a domestic digital product record (DPR) framework, a move that parallels the EU’s established Digital Product Passport (DPP) system. The inquiry, open for stakeholder input until September 21, 2026, seeks to determine how digital records could enhance product transparency, streamline compliance, and support market surveillance.

For businesses operating across Europe, this development raises critical questions about future regulatory alignment. While the EU’s DPP requirements are already being implemented and apply in Northern Ireland under the Windsor Framework, the UK’s approach for Great Britain remains undecided. A divergent UK standard could create a separate compliance track, complicating product data management, labeling, and supply chain logistics for manufacturers and retailers.

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The U.S. Department of Justice has established the permanent Global Trade & Commerce Enforcement Section to investigate and prosecute criminal import and trade fraud. Working with the Department of Homeland Security, the DOJ also released A Resource Guide to Trade Fraud Enforcement, described as the first comprehensive framework of its kind for these matters. The guide and new section signal a heightened federal priority on combating conduct that undermines US industries, evades tariffs, or introduces illicit goods into supply chains. For corporate counsel, the development highlights increased enforcement risk, particularly through the False Claims Act, which allows for treble damages and is a key tool for pursuing customs fraud and duty underpayments. The governments guidance emphasizes the importance of robust corporate compliance programs, including active supply-chain auditing and verification of partner representations. Companies involved in international trade should review their compliance and disclosure policies in light of the specific priorities and authorities outlined in

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The Committee on Foreign Investment in the United States (CFIUS) has released its annual report for calendar year 2025, revealing important trends for cross-border dealmakers. While total filings increased, driven by a 21% rise in short-form declarations, the committee's willingness to quickly clear them has fallen sharply. The proportion of declarations cleared within the 30-day assessment period dropped to 66% from 78% in 2024. Correspondingly, CFIUS more frequently requested parties to file a longer, more detailed notice after reviewing a declaration, a trend that can add significant delays to transaction timelines.

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On August 13, 2026, the U.S. government implemented a dual-track strategy to bolster the domestic drone industry. The Commerce Department's Bureau of Industry and Security (BIS) issued a final rule, effective immediately, that eases export control restrictions on many commercial unmanned aerial vehicles (UAVs), related parts, and associated technology. In a parallel action, the White House announced new Section 232 tariffs on certain drone imports and critical components, framing the move as a matter of national security.

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An analysis of the high-profile Sime Darby palm oil forced labor matter provides key lessons for companies navigating supply chain due diligence. The case, which resulted in a U.S. Customs and Border Protection (CBP) finding and import ban under Section 307 of the Tariff Act of 1930, serves as a case study for the severe operational and reputational risks of inadequate human rights compliance. For sophisticated counsel and clients with global supply chains, the matter underscores the aggressive enforcement posture of U.S. authorities and the need for proactive, evidence-based diligence systems. The key takeaway is that companies must go beyond contractual assurances and implement robust mechanisms for supply-chain mapping, risk assessment, on-the-ground auditing, and timely remediation. Counsel should advise clients to review compliance programs in light of evolving standards to affirmatively demonstrate the absence of forced labor.

On August 13, 2026, the U.S. Court of International Trade ruled that the president possesses the legal authority to eliminate the $800 de minimis tariff exemption under the Trade Act of 1974. The decision stems from a challenge to a prior executive action that sought to revoke the exemption for certain goods. The court’s affirmation of presidential power removes a significant judicial barrier to future tariff policy shifts. Companies with cross-border e-commerce, retail, and supply chain operations should evaluate exposure to potential tariff reinstatement, review import classification strategies, and consider contingency plans for cost pass-through or sourcing adjustments.

The U.S. has imposed new Section 232 tariffs on imported unmanned aircraft systems (UAS) and their components, with rates reaching up to 100% and an effective date of September 3. This action directly impacts manufacturers that rely on foreign-made parts, operators that import ready-to-fly systems, and any entity involved in the UAS supply chain. Companies should immediately review their import volumes, evaluate alternative sourcing from domestic or unaffected countries, and model the financial impact of these duties on pricing and margins. Engaging trade counsel to explore potential exclusions, tariff classification strategies, and supply chain restructuring is critical to mitigating exposure and maintaining competitiveness.

The Department of Justice and Department of Homeland Security have released a joint enforcement guide that elevates trade fraud—particularly misclassification, undervaluation, and origin fraud—as a sustained priority. The guide effectively applies False Claims Act standards to import-related conduct, meaning that supply-chain diligence must be documented with the underlying analysis, not just conclusions. Importers and brokers should test their existing compliance frameworks against this guidance, strengthen internal reporting channels, and assess disclosure decisions early to mitigate exposure to government investigations and civil penalties.

The Supreme Court's decision in Learning Resources v. Trump invalidated tariffs imposed under IEEPA, opening the door for importers to recover duties already paid. Two procedural paths exist: filing suit in the Court of International Trade under 28 U.S.C. § 1581(i), or seeking administrative reliquidation through CBP. Each carries distinct risks—litigation offers broader remedies but requires timely filing, while administrative channels may be faster but offer narrower relief. Importers should immediately inventory IEEPA tariff payments, assess statute-of-limitations exposure, and weigh forum selection carefully. Companies that delayed filing protests or suits now face compressed decision windows, and the choice of forum will shape refund scope, interest recovery, and the ability to challenge future tariff actions.

Following the U.S. Supreme Court's decision striking down tariffs imposed under the International Emergency Economic Powers Act, billions in refunds are flowing through shippers and retailers, and a wave of consumer class actions has followed seeking to recover amounts consumers paid directly or indirectly. Practitioners note that plaintiffs in these cases face significant evidentiary hurdles: tracing any specific price increase to tariffs alone is difficult given that most companies set prices based on multiple inputs, including labor, materials, freight, and demand. Defendants should leverage this multifactorial pricing reality in motions to dismiss and class certification challenges, focusing on the absence of common, tariff-specific injury. Companies should also audit refund pass-through practices and document pricing methodologies now to support defenses and potential indemnification claims against upstream parties receiving IEEPA refunds.

A new Jones Day client alert details recent changes to foreign direct investment regulatory requirements across major global jurisdictions. The guidance covers revised transaction screening processes, updated ownership disclosure mandates, and adjusted national security review thresholds for both inbound and outbound cross-border deals. In-house counsel should use the alert to update their organization’s due diligence checklists and post-closing compliance frameworks, mitigating risk of transaction delays, deal blockage, or enforcement penalties for non-compliance with current rules.