On August 25, 2025, the U.S. Department of Justice (DOJ) launched the Trade Fraud Task Force (Task Force) in collaboration with the U.S. Department of Homeland Security (DHS) and the U.S. Customs and Border Protection (CBP). The cross-agency Task Force is a crucial part of the Administration’s enforcement agenda against tariff evasion, Customs fraud, and smuggling schemes under the Tariff Act of 1930, the False Claims Act (FCA), and Title 18’s trade fraud and conspiracy provisions. 

The Task Force’s enforcement activity has already produced substantial financial consequences for companies and individuals involved in alleged unlawful import practices. On July 14, 2026, DOJ announced that the Task Force recovered more than $1 billion in civil and criminal recoveries, penalties, forfeitures, and publicly charged losses in less than one year. 

For importers, manufacturers, customs brokers, and other participants in the global supply chain, the Task Force signals that this Administration no longer treats Customs noncompliance with administrative penalties but instead now classifies it as a matter of potential civil and criminal liability. For example, Perfectus Aluminum agreed to pay a $549.5 million in an FCA settlement for allegedly evading antidumping and countervailing duties on aluminum extrusions imported from China; Ceratizit USA LLC agreed to pay $54.4M for allegedly failing to pay duties owed on tungsten carbide products imported from China; and Redi-Bag USA agreed to pay $7.3 million to resolve allegations involving the misrepresentation of country of origin for imported polyethylene retail carrier bags and the resulting evasion of antidumping duties. 

Some of the Task Force’s areas of focus include:

• Evasion of tariffs, including Section 301 duties;
• Evasion of antidumping and countervailing duties;
• Misrepresentation of country of origin;
• Fraud involving shell companies, customs brokers, drawbacks, FTA;
• Transshipment schemes;
• False declarations concerning the classification, value, or nature of imported merchandise;
• Smuggling and other unlawful importation activities;
• Forced-labor-related trade violations; and
• Imported goods that present public-health or safety concerns.

Many of the Task Force’s investigations have been initiated or supported by whistleblower allegations. Under the FCA, private individuals, known as relators, can bring an action on behalf of the United States when they have information concerning alleged fraud against the government. If the action results in a recovery for the government, the relator may be entitled to a portion of that recovery. In the trade context, this mechanism gives employees and other individuals with knowledge of import practices a potential avenue to report alleged tariff evasion, undervaluation, misclassification, or other Customs violations.

Notably, DOJ recently announced the creation of the Global Trade & Commerce Enforcement Section (GTCES) within the National Fraud Enforcement Division to “investigate and prosecute criminal import, trade, and other fraud offenses that undermine American industries, evade external revenue collection, threaten consumers’ health and safety, finance foreign adversaries, promote forced labor through illegal trade practices, and violate United States laws and regulations governing domestic and foreign commerce.” The creation of GTCES further emphasizes the current enforcement framework and the importance of maintaining customs compliance. Importers should consider having their supply chains undergo a third-party audit and taking a close look at their compliance programs, including tariff classification, valuation, country-of-origin determinations, trade remedies, government investigations, and voluntary disclosures. Identifying and addressing potential compliance issues early can help companies better manage enforcement risks, minimize the risk of unwanted involvement with the Task Force, and support a smoother process.