Partner Mike Coursey
authored The Metropolitan Corporate Counsel
article, "Honeygate II Highlights Supply Chain Risks For U.S. Buyers Of Imported Goods." The article discusses the case of Groeb Farms, Inc., America's largest supplier of processed honey, which recently accepted criminal responsibility for evading $79 million in dumping duties by purchasing Chinese honey that was fraudulently imported into the U.S. by other parties.
Groeb was not directly involved in the honey's importation, but this did not protect them - a downstream buyer - from criminal liability for that fraud. Mike explains that the government now expects that all U.S. users and distributors of imports have already implemented and are maintaining rigorous supply chain procedures, and companies that haven't done so face a heightened risk.