Voluntary Disclosure of Unpaid Customs Duties Results in $6.8 Million False Claims Act Settlement

In yet another False Claims Act (FCA) settlement involving avoidance of customs duties, on July 23, 2025, the Department of Justice (DOJ) announced that New Hampshire-based Global Plastics and Marco Polo International — both subsidiaries of MGI International — had agreed to pay $6.8 million to resolve allegations that they violated the FCA by knowingly failing to pay customs duties on certain plastic resin imported from China.

Importantly, this case was triggered after the companies voluntarily disclosed the issue to the United States Attorney’s Office in New Hampshire. The DOJ acknowledged that the defendants took “a number of significant steps entitling them to credit for cooperating with the government.” This included making a timely self-disclosure, performing “a thorough and independent internal investigation; preserving, collecting, and disclosing facts not known to the government but relevant to its investigation; conducting an analysis of potential damages that was shared with the government; and implementing appropriate remedial actions, including disciplining personnel and making improvements to compliance procedure.” As a result of this cooperation, the defendants received credit pursuant to the DOJ’s guidelines for taking such cooperation into account in FCA settlements. The U.S. Attorney stated that the settlement “demonstrates that when companies self-disclose misconduct, cooperate fully with the government’s investigation, and take meaningful corrective action, they can receive credit for those admissions.”

This settlement is the latest in a flurry of FCA activity involving allegations customs fraud. The DOJ has made clear that this is a top FCA enforcement priority, and this settlement demonstrates just how seriously the DOJ takes these matters.