The recent tariff changes implemented by the United States, currently under Donald Trump’s second term, have had a major impact on international markets. On April 2, 2025, a sweeping trade policy was announced, introducing a universal 10% duty on all imports — excluding Canada and Mexico — and raising total tariffs on Chinese goods to 54%. This marks a protectionist shift with direct consequences for global supply chains and strategic trade flows.

This evolving scenario demands that business leaders adopt a proactive and strategic posture. Amid economic volatility and regulatory uncertainty, hasty decisions may lead to consequences that extend beyond financial exposure and into the realm of criminal liability. Companies engaged in international trade face pressure to restructure logistics, renegotiate contracts, and identify new suppliers — actions which, if not handled with due diligence, may open the door to unlawful conduct.

From a corporate criminal law perspective, such instability heightens the risk of offenses such as accounting fraud, market manipulation, and especially insider trading, as asset prices respond sharply to policy shifts. In the effort to minimize losses or retain profits, business actors may inadvertently cross legal boundaries, sometimes unaware of the criminal implications of their decisions.

Moreover, the escalation of tariffs may drive multinational companies to relocate operations to jurisdictions with weaker institutional oversight, increasing exposure to illicit practices — such as bribery – to expedite logistics or obtain unfair advantages.

Additionally, the growing regulatory complexity resulting from protectionist measures may lead to unintentional noncompliance, false statements in import/export documentation, or simulated transactions — all of which can spark cross-border criminal investigations.

Today, every strategic move must consider not only financial outcomes but also potential criminal consequences.