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ICYMI: Technology Company Pleads Guilty to Export Control Violations, Agrees to $140M Fine

The U.S. Attorney’s Office for the Northern District of California and the Counterintelligence and Export Control Section (CES) of the Department of Justice’s (DoJ) National Security Division announced that Cadence Design Systems, Inc. of San Jose, California, agreed to plead guilty to resolve criminal violations of export controls. 

As part of the plea agreement, Cadence will pay criminal penalties of nearly $118 million. 

In addition to the charges, the Department of Commerce’s Bureau of Industry and Security (BIS) also announced the resolution of a civil enforcement action against the company in which Cadence agreed to pay over $95 million in civil penalties. 

The DoJ and BIS have coordinated the resolution of the parallel investigation, and each agreed to a partial credit against their fine for payments made to satisfy the other agency’s fine. Under the coordinated agreement, Cadence will pay criminal and civil penalties of more than $140 million.

Cadence committed criminal violations of the export control laws by selling hardware, software, and semiconductor design intellectual property to the National University of Defense Technology (NUDT) in China. NUDT was added to the Department of Commerce’s Entity List in February 2015. The university was involved in the development of supercomputers with applications for military and nuclear explosive simulations. 

Cadence and its Chinese subsidiary engaged in a conspiracy to commit export control violations by exporting this technology to NUDT without obtaining the requisite licenses from […]

By |2025-08-07T11:02:32-04:00August 7, 2025|EAR, Enforcement, Export, International Trade, Technology, U.S. Bureau of Industry and Security (BIS), U.S. Department of Justice (DOJ)|0 Comments
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ICYMI: Patio Furniture Company Agrees to Pay $4.9 Million to Resolve Duty Evasion Allegations

On July 24, 2025, the Department of Justice (DoJ) announced that Grosfillex, Inc., a Pennsylvania furniture company, agreed to pay $4.9 million to resolve allegations it evaded antidumping and countervailing duties (AD/CVD).

Grosfillex submitted false forms to Customs and Border Protection (CBP) claiming that furniture parts made of extruded aluminum from China were not subject to AD/CVD. The company attempted to hide the aluminum extrusions by falsely packing them as sham “furniture kits.” Additionally, for a different subset of extrusions, the company failed to correct customs forms it had submitted previously, even after learning that the forms contained false information.

The investigation arose from a whistleblower lawsuit filed under the False Claims Act by a former employee of Grosfillex. Under the False Claims Act, private citizens can sue on behalf of the government and share in any recovery. In this case, the whistleblower will receive $962,662.74.

Duty Evasion is on the Rise

This case is just one example of the growing incentive to cheat that comes with higher tariffs. Whether it’s through misclassifying goods, undervaluing imports, or using deceptive transshipment routes, some companies think they are being creative, but, instead, are participating in outright illegal strategies to reduce their tariff liability.

Higher tariffs have even contributed to the emergence of a cottage industry of “tariff reduction” companies that suggest ways to cut import costs. However, many of these so-called strategies amount to evasion, […]

By |2025-08-01T10:51:46-04:00August 1, 2025|AD/CVD, Enforcement, Import, International Trade, penalty, Reasonable Care, U.S. Customs and Border Protection (CBP), U.S. Department of Justice (DOJ)|0 Comments
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CIT Hands Down $3.4M Penalty for Duty Evasion

On July 18, 2025, the Court of International Trade (CIT) granted the government’s motion for default judgment against importer Rayson Global and its owner, Doris Cheng, for negligently failing to pay duties. 

The Case

The government’s case was filed in 2023, alleging that the importers had falsely declared that Chinese-origin goods as Thai origin to evade duties. The government asserted this false declaration avoided payment of ordinary 6% duties, Section 301 duties ranging from 10% to 25%, and 234.51% antidumping duties. 

The government asked the court to impose a penalty for negligence. The penalty amount is twice the loss of revenue or the domestic value, whichever is lower. After the importer failed to answer the complaint (a huge mistake), the U.S. moved for summary judgment.

The CIT granted the government’s motion and ordered the importer to pay a nearly $3.4 million penalty as well as all unpaid duties, taxes, and cash deposits on the unliquidated entries in question.

Duty Evasion is on the Rise

This case is just one example of the growing incentive to cheat that comes with higher tariffs. Whether it’s through misclassifying goods, undervaluing imports, or using deceptive transshipment routes, some companies are turning to creative or outright illegal strategies to reduce their tariff liability.

These incentives have even contributed to the emergence of a cottage industry of “tariff reduction” companies that suggest ways to cut import costs. However, many of these so-called strategies amount […]

By |2025-07-25T10:16:59-04:00July 25, 2025|Enforcement, Import, International Trade, penalty, Reasonable Care, U.S. Consumer Product Safety Commission (CPSC), U.S. Department of Justice (DOJ)|0 Comments
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ICYMI: BIS Initiates 232 Investigations of UAS and Polysilicon Imports

On July 15, 2025, the Bureau of Industry and Security announced Section 232 National Security Investigations of: (i) Unmanned Aircraft Systems (UAS) and their parts/components, and (ii) polysilicon and related derivatives.

The Federal register notices are available here (UAS) and here (polysilicon).

BIS is specifically interested in the following information:

  1. The current and projected demand for these products and the extent to which domestic production can meet this demand
  2. The role of foreign supply chains, particularly of major exporters, in meeting United States demand 
  3. The concentration of U.S. imports from a small number of suppliers and the associated risks
  4. The impact of foreign government subsidies and predatory trade practices 
  5. The economic impact of artificially suppressed prices due to foreign unfair trade practices and state-sponsored overproduction
  6. The potential for export restrictions by foreign nations
  7. The feasibility of increasing domestic capacity to reduce import reliance
  8. The impact of current trade policies on domestic production and whether additional measures, including tariffs or quotas, are necessary to protect national security

The deadline to submit comments is August 6, 2025.

The investigations could result in new trade restrictions, including tariffs. If you import products covered under these investigations, make your […]

By |2025-07-22T07:45:47-04:00July 22, 2025|Enforcement, Export, Import, International Trade, tariffs, Trade Policy, U.S. Bureau of Industry and Security (BIS)|0 Comments
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ICYMI: President Trump Lifts Syria Sanctions

On June 30, 2025, President Trump issued an Executive Order formally terminating the Syria sanctions program, which had been in place for two decades.  

The Executive Order (effective July 1, 2025) revoked the following six prior executive orders dating back to 2004:

  • Executive Order 13338 of May 11, 2004 (Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria),
  • Executive Order 13399 of April 25, 2006 (Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria)
  • Executive Order 13460 of February 13, 2008 (Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria)
  • Executive Order 13572 of April 29, 2011 (Blocking Property of Certain Persons with Respect to Human Rights Abuses in Syria)
  • Executive Order 13573 of May 18, 2011 (Blocking Property of Senior Officials of the Government of Syria)
  • Executive Order 13582 of August 17, 2011 (Blocking Property of the Government of Syria and Prohibiting Certain Transactions with Respect to Syria).

The revocation of Executive Order 13338 ended the national emergency that underpinned the subsequent executive orders.

The Executive Order also waived certain sanctions imposed by the Syria Accountability Act and the Chemical and Biological Weapons Control and Warfare Elimination Act.

On […]

By |2025-07-03T09:29:53-04:00July 3, 2025|Countries, Enforcement, U.S. Department of State (DOS), U.S. International Trade Commission (USITC), U.S. Office of Foreign Assets Control (OFAC)|0 Comments
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