Import Trade Infractions Draw Fed Scrutiny

Active enforcement of “AD/CVD” evasion can be attributed in part to the simple fact there is more of it going on. AD stands for anti-dumping; CVD refers to so-called countervailing duties. Evasion may occur by such ploys as falsifying country of origin, routing goods through a third country or “performing minor alterations in a third country and declaring that country as the origin,” write Drinker Biddle & Reath attorneys Beata K. Spuhler and Douglas J. Heffner, as they survey recent enforcement activity. They outline an effective risk management program, which should include a good-faith effort to confirm the country of origin and the nature of the imported product.