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The Morning Risk Report: U.S. Poised for Wave of Criminal Tariff Evasion Cases
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By David Smagalla | Dow Jones Risk Journal
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Good morning. Happy New Year! Reporters for Risk Journal spent the last week of 2025 looking back at the issues facing risk and compliance executives during the year and looking forward to what they might expect in 2026. Here’s what you may have missed:
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Tariff evasion: Our Max Fillion looked at an expected wave of criminal tariff evasion cases in 2026. As the Trump administration blankets the globe with tough tariffs and prosecutors in Washington prioritize harsher crackdowns on those that evade them, white-collar lawyers told Max they believe it is only a matter of time before the Justice Department files a slew of criminal cases against companies.
Reorienting enforcement: The Treasury Department’s anti-money-laundering unit under Trump has intensified its focus on rules supporting core administration priorities, including narcotics trafficking and illegal immigration. In the new year, compliance experts told Mengqi Sun that financial institutions should reorganize accordingly, including by enhancing due diligence on business counterparts in Latin America and reviewing criteria for providing banking services to individuals to avoid criticism for debanking customers inadvertently.
Increased need for cyber compliance: The Securities and Exchange Commission is scrutinizing investment firms for compliance with newly in-force changes to a cybersecurity rule. The SEC has begun what is known as a sweep to check on efforts by firms to follow Regulation S-P, Richard Vanderford learned.
More from Risk Journal’s holiday week coverage:
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Content from our sponsor: Deloitte
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A List to Check Twice: What Your Peers Were Reading in 2025
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Reflect on the critical developments of the year with this C-suite “go-to” article list—curated to help you navigate the year ahead. Read More
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Deputy Attorney General Todd Blanche sent a memo outlining a new Justice Department initiative. PHOTO: Tom Williams/CQ Roll Call/ZUMA Press
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Justice Department using fraud law to target companies on DEI.
The Trump administration has launched investigations into the use of diversity initiatives in hiring and promotion at major U.S. companies, built on the novel use of a federal law meant to punish businesses that cheat the government.
The civil probes are proceeding under the umbrella of the False Claims Act, which has traditionally been used to go after contractors who bill the government for work that was never performed or inflate the cost of services rendered.
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Trump administration upends prosecution of white-collar crime.
President Trump’s first year back in office turned the world of white-collar enforcement upside down.
The Justice Department, focused on White House priorities such as immigration enforcement and violent crime, has stepped back from the kinds of complicated investigations into foreign bribery, money laundering and public corruption that former department leaders often cited among their greatest successes.
Along with that shift, administration officials have undone a number of notable Biden-era white-collar prosecutions. In some, the department dropped charges against executives that were pending. In others, Trump has used the pardon power to forgive a string of top company officials charged with or convicted of crimes related to their businesses.
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Trump administration officials are facing complaints from state utility regulators regarding a plan for federal oversight of data center grid connections.
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The Trump administration accused China of employing unfair trade practices in the semiconductor industry but said it would hold off on imposing additional tariffs until 2027.
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The Chinese government imposed sanctions on 20 U.S. defense companies and 10 of their executives in retaliation for the Trump administration’s approval of a large package of weapons for sale to Taiwan.
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China also revised its Foreign Trade Law expanding the authority to restrict trade with foreign entities and significantly increasing penalties for violations, Risk Journal’s Anwar Faruqi reports.
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The U.S. dropped sanctions against a former executive at Russia’s state-owned Sberbank, Risk Journal’s Richard Vanderford reports.
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Malaysia’s High Court sentenced former Prime Minister Najib Razak to 15 years in prison after convicting him on 25 charges of money laundering and abuse of power connected to the looting of the 1MDB sovereign-wealth fund.
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A federal judge rejected the Trump administration’s arguments that it couldn’t continue to fund the Consumer Financial Protection Bureau, reports Risk Journal’s Max Fillion, throwing a wrench into its latest attempt to dismantle the agency.
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The Financial Accounting Standards Board in 2026 will explore whether some cryptocurrency assets may qualify as cash equivalents and how to account for crypto transfers, as the Trump administration bolsters such investments.
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Chief Justice John Roberts said in his year-end message that the judiciary remains a constraint on political power, as the Supreme Court faces criticism that it was too deferential to President Trump in 2025.
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6
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The number of Foreign Corrupt Practices Act cases brought by the Justice Department in 2025, according to data maintained by law firm Gibson Dunn. The Securities and Exchange Commission brought no cases last year. Justice and the SEC combined brought about 33 such cases a year against companies or individuals between 2015 and 2024.
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RACHEL MENDELSON/WSJ; BLOOMBERG, ISTOCK
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A shrimper, a carmaker, a lawyer: How the world tackled Trump’s trade war.
Standing in the Rose Garden last spring flanked by American flags, President Trump declared war on free trade.
Nine months later, instead of crumbling under the highest U.S. tariffs in almost a century, the global trade system has been recast along new lines. The U.S. is buying less from China directly but more from Chinese-owned factories in lower-tariff places like Vietnam. China is exporting more to virtually everyone else, especially cheap stuff to Europe. Beijing’s stranglehold on rare-earth minerals sparked new efforts to produce the raw materials integral to cars and gadgets.
Here are six stories of how real people and companies in the global economy are rapidly adjusting to the new rules of trade.
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How an elusive banker allegedly kept North Korea’s dirty money flowing.
A few years ago, a California cryptocurrency developer hired a freelance coder remotely for a project. What he didn’t know: The salary he paid landed in the hands of North Korea.
The $216,000 paid in cryptocurrency was supposed to go to the coder in Singapore. Instead, it went to a digital wallet controlled by a North Korean named Sim Hyon Sop, according to crypto-analytics firm TRM Labs, which tracked the transactions. U.S. prosecutors allege that Sim has engaged in money laundering and sanctions evasion on behalf of the Kim Jong Un regime.
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U.S. national-security officials said Wednesday that Ukraine didn’t target Russian President Vladimir Putin or one of his residences in an alleged drone operation, challenging Moscow’s assertion that Kyiv sought to kill the Russian leader.
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A day before President Volodymyr Zelensky made his case for more American support at President Trump’s Mar-a-Lago resort over the weekend, Russia slammed another wave of drones into a slice of Ukraine’s own prime beachfront real estate: the Black Sea port of Odesa.
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For Steve Witkoff and Jared Kushner, President Trump’s billionaire envoys working on a deal to end the Ukraine war, Russia is a land of vast natural resources and rich business opportunities. But many veterans of its volatile economy are skeptical that the country will handsomely reward U.S. capital.
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The EU is increasing scrutiny of Turkish terminals and considering sanctions on ports suspected of facilitating the backdoor flow of Russian fuel into Europe.
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Violence erupted between Iranian protesters and police during unrest on Thursday, leaving at least five dead on the fifth day of demonstrations over the country’s economic crisis.
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Tens of thousands of imports have been blocked from entering the U.S. in recent months and stacked in vast warehouses. Many get to their destinations after buyers complete government paperwork. Yet some that can’t clear customs because of missing or incomplete information are returned—or destroyed.
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China intends to keep playing in the U.S. backyard, Latin America.
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The festive mood that powered the crypto market in early 2025 has given way to a hangover.
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The corporate playbook for 2026? Don’t hire.
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The Trump administration has shifted to offense in combating nation-state hackers. PHOTO: Saul Loeb/Agence France-Presse/Getty Images
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Washington wants to get tough on nation-state hackers. Are infrastructure operators ready?
The Trump administration’s shift to offense in combating nation-state hackers calls on state governments and private-sector infrastructure operators to play a bigger role in national security.
That may be a tough sell. Together, states and private-sector firms run most of the critical infrastructure across the U.S., including water systems, electricity grids, transportation networks and hospitals that are prized targets for adversarial cyberattacks.
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President Trump in an interview with The Wall Street Journal, says he is taking more aspirin than his doctors recommend. He briefly tried wearing compression socks for his swelling ankles, but stopped because he didn’t like them. And he regrets undergoing advanced imaging because it generated scrutiny of his health.
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Zohran Mamdani became the mayor of New York City on Thursday, declaring he will govern “expansively and audaciously” and promising to make good on his pledge to lower the cost of living for New Yorkers.
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An office romance at Nestlé cost the chief executive his job. Now it’s giving way to an overhaul at the food-and-drink maker under new boss Philipp Navratil.
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When Graham Walker sold his family’s Louisiana company, he made sure his 540 employees got a $240 million cut.
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Logistics Report's Paul Berger reports on the voyage of a Chinese ship sailing the long way around the world to deliver cranes to the U.S. Gulf Coast and Jamaica, epitomizing a moment of peak globalization that could be coming to an end.
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