S&c Critical Insights

In this episode of S&C’s Critical Insights, Eric Kadel and Sharon Cohen Levin, Co-Heads of S&C’s National Security Practice, Tom White, Co-Head of the Firm’s International Arbitration and Global Dispute Resolution Practice, and Litigation Special Counsel Andrew DeFilippis, provide an overview on supply chain enforcement and compliance. They explore key enforcement risks stemming from recent tariffs and discuss the potential for civil litigation under the False Claims Act. A preview of the conversation can be found in the Q+A below. Andrew: Customs fraud and tariff evasion are now listed as the Department’s second-highest white-collar criminal enforcement priority. What does that signal about how the government is approaching these issues today? Sharon: It’s a fundamental shift. For years, customs-related violations were typically addressed as regulatory infractions, or occasionally, in egregious cases as criminal prosecutions involving false statements, conspiracy to defraud the government, or smuggli