Unpredictable and oft-changing tariff developments in the United States continue to dominate recent news cycles and underscore the challenges faced by U.S. importers and their supply chain partners, including increased risks of possible tariff evasion schemes. The current environment is ripe for heightened risks arising throughout the supply chain for foreign-origin merchandise imported into the U.S., and thus importers should exercise caution, conduct appropriate due diligence and carefully monitor their networks for these risks. In this guest article, Venable partners George Kostolampros, Ashley Craig and Elizabeth Lowe examine those risks and provide an overview of common tariff evasion schemes, the FCPA’s connection to tariff evasion prosecutions, and the host of other federal statutes available to meet the DOJ’s enforcement goals. See “Assessing the Criminal Division’s New Enforcement Focuses” (Jun. 18, 2025).