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Rise in Reverse FCA Cases Amidst ‘America First’ Trade Policies

Client Alert | 1 min read | 04.25.19

On March 27, 2019, the U.S. Department of Justice intervened in United States ex rel Vale v. Selective Marketplace Ltd., a False Claims Act (FCA) suit brought against a clothing importer for allegedly evading customs duties. The suit is the latest example in a growing number of FCA actions brought against importers for allegedly concealing obligations to pay duties to U.S. Customs and Border Protection. The rise in qui tam suits based on avoidance of duties, combined with the administration’s protectionist policies, means that importers could face increased FCA risks for years to come. In an Expert Analysis article published in Law360, C&M attorneys analyze recent enforcement trends and discuss practical steps that importers can take to mitigate risks.

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Client Alert | 4 min read | 02.21.25

An Un[waiver]ing Commitment to CMMC: The Department of Defense Issues Guidance for Determining Assessment Levels

Amidst a flurry of executive cost-cutting, the Department of Defense’s (DoD) Cybersecurity Maturity Model Certification program—often known just as “CMMC”— appears to be defying the odds and only picking up steam. Marking the first CMMC developments under the new administration, the DoD has published guidance that previews what to expect once CMMC is finalized. These developments suggest that the current administration intends to pick up where it left off, having first introduced the CMMC program during President Trump’s first term....