In this article, authors Richard Mojica and Richard Gallena* discuss recent False Claims Act (FCA) settlements in the context of customs fraud violations and potential criminal risks, outlining the implications of those trends for companies facing exposure to customs-related FCA violations. "Consider conducting an internal investigation to determine what happened and whether there are enhancements that can be made to the company's existing compliance program. Depending on the results of the internal investigation, companies may choose to proactively approach DOJ and discuss the findings and remedial measures rather than waiting for the government to make the first move," the authors write.

*Former Miller & Chevalier attorney