ENFORCEMENT
eop_ipec_jointstrategicplan_hi-res
eop_ipec_jointstrategicplan_hi-res
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Office of the Intellectual Property Enforcement Coordinator<br />
items into the United States, to which domestic workers<br />
then affix branded labels, hangtags, logos, stamps,<br />
hardware, embroidery, or other identifying details<br />
(collectively referred to as “labels and tags”) to the<br />
finished counterfeit product.<br />
FIG. 47: Illustration of Domestic Assembly and Finishing<br />
Operation: Individual Components Come in, Counterfeit<br />
Products Goes Out.<br />
illicit trader will merely send a second parcel (filled with<br />
labels) to replace the first, and the game of cat-andmouse<br />
continues.<br />
Between FY 2012 and FY 2015, DHS seized over<br />
2,500 shipments containing millions of individual labels<br />
and tags intended for domestic finishing, with an affixed<br />
value of more than $115 million, had the finished goods<br />
been genuine. The dollar value of seized labels and<br />
tags increased by 46.9 percent in FY 2015 over FY 2014,<br />
and 37 percent in FY 2013 over FY 2012. 4 Domestic<br />
assembly is reportedly a widespread practice across<br />
different parts of the world. 5<br />
These tactics merit further attention and a<br />
comprehensive assessment, as little information is<br />
publicly available. Moving forward, it is important to<br />
evaluate the impact of seizures on the illicit domestic<br />
production industry, including resulting disruptions<br />
to criminal networks and an overall assessment of the<br />
effectiveness of law enforcement programs. Relatedly,<br />
the Federal Government can optimize its response to<br />
illicit domestic finishing through an evaluation of the<br />
scope and nature of domestic criminal production and<br />
finishing operations.<br />
ACTION NO. 3.2: Identify and evaluate trends<br />
in domestic production and finishing operations<br />
for counterfeit goods. Within 18 months of the<br />
issuance of this Plan, ICE will identify and evaluate<br />
trends in domestic production and finishing<br />
operations.<br />
Source: U.S. Customs and Border Protection<br />
Domestic assembly is a common tactic to try to<br />
circumvent Customs interdiction. 3 As illustrated above<br />
(FIG 47), a common practice is to reduce a product<br />
to its smallest form—blank or unbranded products in<br />
one or more packages, with identifying labels, hang<br />
tags, and packaging in other packages—with the parts<br />
imported independently in the hope that, separately,<br />
each of the individual components may clear Customs.<br />
If Customs seizes one shipment, it may likely be the<br />
one of least monetary value: the un-affixed labels<br />
featuring the famous brand. Should that occur, the<br />
ACTION NO. 3.3: Enhance interdiction<br />
efforts and the identification, investigation,<br />
and prosecution of illicit domestic finishing<br />
operations. Based on its identification and<br />
evaluation of trends in domestic production<br />
and finishing operations, ICE will work, as<br />
appropriate, with CBP and other Federal,<br />
State, and local law enforcement partners to<br />
enhance interdiction efforts and other activities<br />
for combating such operations. This may<br />
include identifying opportunities for increased<br />
collaboration with and among Federal, State<br />
and local law enforcement entities–to further the<br />
identification, investigation, and prosecution of<br />
illicit domestic finishing operations.<br />
SECTION 3<br />
95