by Gina Parlovecchio, Hiral Mehta, Arun Rao and Xiamora Damour
Left to Proper: Gina Parlovecchio, Hiral Mehta, Arun Rao and Xiamora Damour (images courtesy of Mayer Brown).
On November 17, 2025, the US Lawyer’s Workplace within the District of New Jersey filed a prison criticism alleging that Indonesian jewellery firm UBS Gold, its Indonesian co-owner Michael Yahya, and two firm workers engaged in a five-year-long conspiracy to evade duties and tariffs owed for shipments of knickknack to america. The criticism alleges that defendants prevented over $86 million in duties and tariffs on greater than $1.2 billion in jewellery shipments. That is the second high-profile prison tariff evasion case introduced because the Division of Justice (DOJ) introduced commerce and customs fraud as certainly one of its areas of focus in its white collar Enforcement Steerage earlier this yr[1]—an space that doubtless will stay a precedence, whatever the final result of ongoing litigation difficult President Donald Trump’s imposition of tariffs. Importers ought to monitor their present tariff applications and, if wanted, develop compliant tariff methods.
On Might 12, 2025, the Felony Division of the DOJ issued a memorandum protecting new steering on white-collar enforcement priorities—certainly one of which is commerce and customs fraud, together with tariff evasion. By prioritizing commerce and customs fraud, the Felony Division is tackling “threats to the US economic system, American competitiveness, and our nationwide safety.”[2] Such threats “search to avoid the principles and laws that defend American customers and undermine the Administration’s efforts to create jobs and improve funding in america.”[3]
The UBS Gold case is the product of a joint investigation by Homeland Safety Investigations, Inner Income Service-Felony Investigation, and US Customs and Border Safety. On the finish of 2020, the duty-free remedy Indonesia had with america ended, and america imposed duties on merchandise imported from Indonesia originally of 2021. Thereafter, the criticism alleges that defendants and their co-conspirators engaged in a scheme to evade duties by delivery their jewellery via Jordan as a trans-shipment level, which had a Free Commerce Settlement with america, after which importing the merchandise duty-free into america, underneath the guise that they had been made in Jordan and thus not topic to any obligation.
The criticism additionally alleges that defendants and their co-conspirators developed a second tariff evasion scheme involving sending scrap gold from america to Jordan, switching the scrap gold out for UBS Gold jewellery made in Indonesia, delivery the product again to prospects in america, after which representing to Customs and Border Safety that the jewellery was manufactured in america.
The UBS Gold prison criticism demonstrates this administration’s continued dedication to cut back shopper hurt via fraud and to guard US financial pursuits, particularly when the alleged misconduct includes non-US based mostly people and entities, and makes clear that enforcement actions associated to commerce and customs fraud won’t be restricted to the usage of the False Claims Act alone. This matter additionally illustrates the shut coordination between the DOJ and the Division of Homeland Safety on this space, in step with the latest announcement of the DOJ’s cross-agency Commerce Fraud Activity Pressure in August 2025. The press launch saying the creation of the duty power particularly famous that prison prosecutions, penalties, and seizures can be pursued the place acceptable. As DOJ continues to sharpen its deal with situations of commerce and customs fraud, extra instances like UBS Gold will doubtless emerge—introduced underneath varied prison statutes, comparable to these protecting wire fraud and smuggling.
Given the targeted priorities of the present Administration on commerce, firms ought to intently supervise compliance with customs and tariff frameworks. Specifically, firms ought to contemplate partaking outdoors counsel to conduct (1) audits of import practices to establish potential areas of concern, overview of and enhancements to compliance applications (together with, within the case of importers, to insurance policies and procedures associated to classification, nation of origin, and valuation), and (2) well timed and thorough inner investigations of potential violations to mitigate each the chance of qui tam actions, in addition to prison enforcement for obligation and tariff evasion.
[1] On Might 28, 2025, two executives of a freight forwarding firm had been arrested for his or her position in an alleged scheme to keep away from customs duties funds. See Press Launch, US Dept. of Justice, Freight Forwarding Firm Govt Arrested on Federal Indictment Alleging Large Scheme to Keep away from Customs Duties Funds (Might 28, 2025). For extra details about the DOJ’s new Enforcement Steerage, please see our Authorized Replace, DOJ Pronounces White-Collar Enforcement Priorities and Revised Insurance policies.
[2] Matthew R. Galeotti, Focus, Equity, and Effectivity within the Battle In opposition to White Collar Crime, US Dept. of Justice 1, 3 (2025).
[3] Id.
Gina Parlovecchio, Hiral Mehta, Arun Rao are Companions and Xiamora Damour is an Affiliate at Mayer Brown. This submit first appeared as a shopper replace for the agency.
The views, opinions and positions expressed inside all posts are these of the creator(s) alone and don’t signify these of the Program on Company Compliance and Enforcement (PCCE) or of the New York College Faculty of Legislation. PCCE makes no representations as to the accuracy, completeness and validity or any statements made on this website and won’t be liable any errors, omissions or representations. The copyright of this content material belongs to the creator(s) and any legal responsibility almost about infringement of mental property rights stays with the creator(s).
by Gina Parlovecchio, Hiral Mehta, Arun Rao and Xiamora Damour
Left to Proper: Gina Parlovecchio, Hiral Mehta, Arun Rao and Xiamora Damour (images courtesy of Mayer Brown).
On November 17, 2025, the US Lawyer’s Workplace within the District of New Jersey filed a prison criticism alleging that Indonesian jewellery firm UBS Gold, its Indonesian co-owner Michael Yahya, and two firm workers engaged in a five-year-long conspiracy to evade duties and tariffs owed for shipments of knickknack to america. The criticism alleges that defendants prevented over $86 million in duties and tariffs on greater than $1.2 billion in jewellery shipments. That is the second high-profile prison tariff evasion case introduced because the Division of Justice (DOJ) introduced commerce and customs fraud as certainly one of its areas of focus in its white collar Enforcement Steerage earlier this yr[1]—an space that doubtless will stay a precedence, whatever the final result of ongoing litigation difficult President Donald Trump’s imposition of tariffs. Importers ought to monitor their present tariff applications and, if wanted, develop compliant tariff methods.
On Might 12, 2025, the Felony Division of the DOJ issued a memorandum protecting new steering on white-collar enforcement priorities—certainly one of which is commerce and customs fraud, together with tariff evasion. By prioritizing commerce and customs fraud, the Felony Division is tackling “threats to the US economic system, American competitiveness, and our nationwide safety.”[2] Such threats “search to avoid the principles and laws that defend American customers and undermine the Administration’s efforts to create jobs and improve funding in america.”[3]
The UBS Gold case is the product of a joint investigation by Homeland Safety Investigations, Inner Income Service-Felony Investigation, and US Customs and Border Safety. On the finish of 2020, the duty-free remedy Indonesia had with america ended, and america imposed duties on merchandise imported from Indonesia originally of 2021. Thereafter, the criticism alleges that defendants and their co-conspirators engaged in a scheme to evade duties by delivery their jewellery via Jordan as a trans-shipment level, which had a Free Commerce Settlement with america, after which importing the merchandise duty-free into america, underneath the guise that they had been made in Jordan and thus not topic to any obligation.
The criticism additionally alleges that defendants and their co-conspirators developed a second tariff evasion scheme involving sending scrap gold from america to Jordan, switching the scrap gold out for UBS Gold jewellery made in Indonesia, delivery the product again to prospects in america, after which representing to Customs and Border Safety that the jewellery was manufactured in america.
The UBS Gold prison criticism demonstrates this administration’s continued dedication to cut back shopper hurt via fraud and to guard US financial pursuits, particularly when the alleged misconduct includes non-US based mostly people and entities, and makes clear that enforcement actions associated to commerce and customs fraud won’t be restricted to the usage of the False Claims Act alone. This matter additionally illustrates the shut coordination between the DOJ and the Division of Homeland Safety on this space, in step with the latest announcement of the DOJ’s cross-agency Commerce Fraud Activity Pressure in August 2025. The press launch saying the creation of the duty power particularly famous that prison prosecutions, penalties, and seizures can be pursued the place acceptable. As DOJ continues to sharpen its deal with situations of commerce and customs fraud, extra instances like UBS Gold will doubtless emerge—introduced underneath varied prison statutes, comparable to these protecting wire fraud and smuggling.
Given the targeted priorities of the present Administration on commerce, firms ought to intently supervise compliance with customs and tariff frameworks. Specifically, firms ought to contemplate partaking outdoors counsel to conduct (1) audits of import practices to establish potential areas of concern, overview of and enhancements to compliance applications (together with, within the case of importers, to insurance policies and procedures associated to classification, nation of origin, and valuation), and (2) well timed and thorough inner investigations of potential violations to mitigate each the chance of qui tam actions, in addition to prison enforcement for obligation and tariff evasion.
[1] On Might 28, 2025, two executives of a freight forwarding firm had been arrested for his or her position in an alleged scheme to keep away from customs duties funds. See Press Launch, US Dept. of Justice, Freight Forwarding Firm Govt Arrested on Federal Indictment Alleging Large Scheme to Keep away from Customs Duties Funds (Might 28, 2025). For extra details about the DOJ’s new Enforcement Steerage, please see our Authorized Replace, DOJ Pronounces White-Collar Enforcement Priorities and Revised Insurance policies.
[2] Matthew R. Galeotti, Focus, Equity, and Effectivity within the Battle In opposition to White Collar Crime, US Dept. of Justice 1, 3 (2025).
[3] Id.
Gina Parlovecchio, Hiral Mehta, Arun Rao are Companions and Xiamora Damour is an Affiliate at Mayer Brown. This submit first appeared as a shopper replace for the agency.
The views, opinions and positions expressed inside all posts are these of the creator(s) alone and don’t signify these of the Program on Company Compliance and Enforcement (PCCE) or of the New York College Faculty of Legislation. PCCE makes no representations as to the accuracy, completeness and validity or any statements made on this website and won’t be liable any errors, omissions or representations. The copyright of this content material belongs to the creator(s) and any legal responsibility almost about infringement of mental property rights stays with the creator(s).
