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Author: T. Augustine Lo

Augustine is a Partner in Dorsey’s National Security Law Practice Group. He advises clients on U.S. customs and international trade law, economic sanctions, export controls, and U.S. Government review of foreign investments. With experience in state and federal court litigation in New York and Seattle, Augustine protects clients’ interests in government enforcement actions and international trade proceedings. Proficient in Mandarin Chinese, he also counsels clients on matters relating to East Asia.

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Import Duty Evasion / Reverse False Claims / Trade

21 Apr, 2025

The Trump Administration’s Sweeping New Tariffs Heighten False Claims Act Risks for U.S. Importers

As the business community adjusts to the reality of the Trump Administration’s sweeping new tariff regime, importers and other organizations that rely on imports should be mindful that with the expansion and sharp increases to import tariffs come increased risks under the False Claims Act (FCA).  Given the administration’s public commitment to “aggressive” FCA enforcement, organizations should assess their risks now to get ahead of...

Import Duty Evasion / Settlements

22 Apr, 2020

Importer and Its Executives Pay $5.2 Million Under FCA for Evading U.S. Tariffs

An importer recently agreed to pay $5.2 million to settle a False Claims Act (“FCA”) case alleging evasion of antidumping duties (“AD”) on wooden bedroom furniture from China. The importer, Blue Furniture Solutions, LLC (now doing business through its successor, XMillenium LLC), allegedly imported merchandise into the United States using false descriptions and invoices that claimed the merchandise was outside the scope of the China...

Data Security / Settlements

21 Jun, 2019

Alleged Violations of Government Data Security Requirements Yield FCA Settlement

On May 31, 2019, U.S. Attorney Stephen McAllister of the District of Kansas announced a $250,000 settlement with Coffey Health System to resolve a False Claims Act case.  The case arose from allegations that the hospital’s patient data security was insufficient to justify an incentive payment from the federal government.  The two whistleblowers each will receive $50,000 from the settlement. In 2016, two whistleblowers filed...

False Statement / Persons subject to FCA

26 Sep, 2015

Judge Dismisses FCA Claim Against City of Chicago; Concludes that “Subsequent Nonperformance of a Future Commitment” Was Not a Falsehood Under FCA

On September 16, 2015, the U.S. District Court for the Northern District of Chicago dismissed a False Claims Act (FCA) case against the City of Chicago, because the qui tam complaint did not satisfy the relevant pleading standard.   In an opinion issued by District Judge Andrea Wood, the court found that the complaint failed to allege facts with particularity as required under Federal Rule of...