On October 14, 2025, the U.S. Trade Representative imposed substantial fees on Chinese-built, otherwise Chinese-connected vessels, and most foreign-built vehicle carriers whether built in China or not. On the same day, the Chinese Ministry of Transport imposed retaliatory fees on “US vessels.” 

Part two of Cari’s Legal Exchange covers the shift from civil forfeiture to criminal prosecution, the impact of U.S. sanctions on Mexican cartels, and the expanding risk for companies in various industries.

On September 11, 2025, the U.S. Department of Health and Human Services Office of Inspector General (the OIG) issued a favorable advisory opinion (AO 25-10 or the Opinion) regarding an arrangement between a healthcare services company (the Company) and a charitable foundation (the Foundation), whereby the Company makes financial contributions to the Foundation, which then provides grants to families of children receiving a particular type of therapy (the Arrangement). Pursuant to AO 25-10, the OIG will not impose sanctions with respect to the Arrangement, despite the Arrangement potentially generating prohibited remuneration under the federal Anti-Kickback Statute (the AKS) and implicating the civil monetary penalty provision prohibiting inducements to beneficiaries (the Beneficiary Inducements CMP).