With DOJ’s Latest Announcements, Trade Fraud Enforcement Is Here to Stay

A series of recent DOJ actions—including the announcement of the trade fraud task force $1 billion milestone, publication of a new resource guide on trade fraud enforcement, and creation of a dedicated enforcement section—signal trade fraud as a clear permanent enforcement priority of the department.

On July 14, 2026, the US Department of Justice announced that its Trade Fraud Task Force has surpassed $1 billion in civil and criminal penalties, forfeitures, and publicly charged losses since its creation less than a year ago. While the milestone reflects the pace and scale of the task force’s enforcement efforts, the accompanying announcements may be even more significant for companies engaged in international trade.

Collectively, they confirm that what began as a new enforcement initiative has evolved into a more permanent and coordinated trade enforcement program, while providing DOJ’s clearest public roadmap to date of how it intends to pursue future investigations.

In addition to announcing the $1 billion milestone, DOJ has

• published a 27-page Resource Guide to Trade Fraud Enforcement providing its most comprehensive public explanation of its enforcement priorities and investigative approach as of yet;
• announced the creation of a new Global Trade & Commerce Enforcement Section within the National Fraud Enforcement Division;
• highlighted new criminal prosecutions involving alleged customs duty evasion through false country-of-origin declarations; and
• proclaimed that US Customs and Border Protection (CBP) has assessed more than $2.1 billion in commercial trade penalties during the current fiscal year.

Taken together, these developments demonstrate that trade fraud enforcement has progressed beyond the launch of a task force and is becoming increasingly embedded within DOJ’s long-term enforcement priorities.

These actions are also reflective of the government’s broad emphasis on combatting tariff evasion and trade fraud. In June, the president issued the Strengthening Customs Enforcement executive order imposing heightened requirements on US importers and directing the Department of Homeland Security and CBP to expand customs enforcement measures.

CBP’s administrative actions and DOJ’s civil and criminal investigations are not limited to importers of record. These agencies are targeting the broader trade ecosystem, including customs brokers, freight forwarders, and other supply chain participants.

RECENT CASES ILLUSTRATE DOJ’S EXPANDING ENFORCEMENT APPROACH

The enforcement actions highlighted in DOJ’s announcement demonstrate the department’s continued willingness to pursue both criminal and civil remedies against alleged customs fraud. They also reflect DOJ’s focus on country-of-origin misrepresentations and its willingness to use multiple enforcement tools, including criminal prosecutions, civil False Claims Act actions, and whistleblower litigation.

Alleged False Country-of-Origin Declarations

DOJ announced criminal charges against the operators of California-based Surya International, Inc., alleging they had falsely declared gold jewelry imported from India and the UAE as originating in Singapore to evade approximately $38 million in customs duties on roughly $693 million in imports.

DOJ announced similar charges against the owner and operator of Illinois-based Barkha Wholesale, alleging that gold jewelry was falsely declared as originating in Oman or Singapore, resulting in the alleged avoidance of more than $13.6 million in customs duties.

Civil FCA Enforcement Continues

On July 15, DOJ announced a $7.3 million settlement with New York Packaging II LLC (Redi-Bag USA) and its chief executive officer to resolve allegations that they violated the False Claims Act by falsely identifying Hong Kong, rather than China, as the country of origin for imported polyethylene retail carrier bags to evade antidumping duties.

According to DOJ, the defendants concealed the products’ Chinese origin by directing employees to cover “Made in China” markings, instructing the manufacturer to remove origin markings, and canceling orders scheduled for customs inspection. The settlement also resolved a qui tam action brought by a former sales representative, who will receive approximately $1.3 million as the relator’s share.

DOJ RESOURCE GUIDE OFFERS CLEAREST WINDOW INTO FUTURE ENFORCEMENT

Perhaps the most significant aspect of DOJ’s announcement was the publication of its Resource Guide to Trade Fraud Enforcement, which provides the department’s most comprehensive public explanation to date of how it intends to investigate and prosecute trade fraud.

The guide describes trade fraud enforcement as advancing three principal objectives: protecting the nation’s fiscal interests, promoting public safety, and safeguarding human dignity. More importantly for companies, however, it identifies the conduct DOJ expects to prioritize and provides a roadmap for evaluating trade compliance risk.

The Resource Guide identifies 16 common trade fraud typologies that DOJ views as significant enforcement risks:

1. Manifest fraud
2. False country-of-origin declarations and markings
3. False Harmonized Tariff Schedule classification
4. Undervaluation
5. Anti-dumping/countervailing duty evasion
6. Shell company fraud
7. Customs broker fraud
8. Drawback fraud (false export claims)
9. Free trade agreement fraud
10. Port shopping
11. “Prior notice” and import alerts evasion for regulated food
12. Forged product safety or environmental certifications (e.g., CPSC/EPA certifications)
13. Failure to report dangerous or defective products or adverse events
14. False declaration of regulated commodities
15. Illegal timber and wildlife laundering (including Lacey Act and Endangered Species Act violations)
16. Importing adulterated drugs and devices

For companies that have been following the evolution of the Trade Fraud Task Force, the Resource Guide confirms many of the themes DOJ has emphasized over the last year: aggressive use of criminal and civil authorities, increased interagency coordination, supply chain–wide investigations, and expanded scrutiny beyond traditional customs fraud.

At the same time, it is the department’s first effort to consolidate those priorities into a single public framework, providing companies with a useful benchmark for assessing trade compliance programs and identifying potential enforcement risk.

The guide also reinforces DOJ’s intention to pursue misconduct throughout the supply chain, not merely at the point of importation. Echoing prior statements by the task force, DOJ warns that federal law reaches “deep into the domestic stream of commerce” and investigations may extend to downstream companies whose conduct facilitates or benefits from trade fraud. The accompanying announcement similarly cautions that the port of entry is “only the starting point” for many investigations.

DOJ CREATES DEDICATED GLOBAL TRADE & COMMERCE ENFORCEMENT SECTION

DOJ also announced the creation of the Global Trade & Commerce Enforcement Section (GTCES) within the recently established National Fraud Enforcement Division. GTCES will investigate and prosecute criminal customs, import, trade, sanctions, and related fraud offenses, further centralizing DOJ’s trade enforcement capabilities.

The establishment of a dedicated enforcement section—particularly within a division created only months earlier—further demonstrates that trade fraud enforcement is becoming embedded within DOJ’s permanent organizational structure rather than remaining a temporary task force initiative.

TRADE FRAUD ENFORCEMENT: NO LONGER AN EMERGING INITIATIVE

DOJ’s July 14 announcement reflects more than a significant enforcement milestone. Through dedicated organizational resources, published enforcement guidance, coordinated interagency efforts, and a growing body of criminal and civil cases, DOJ has demonstrated that trade fraud enforcement is no longer an emerging initiative—it is a long-term enforcement priority.

Companies engaged in cross-border trade should view the Resource Guide as an important compliance document. Together with DOJ’s recent enforcement actions, it provides valuable insights into the department’s investigative priorities and underscores the importance of robust controls surrounding country-of-origin determinations, tariff classifications, valuation, customs declarations, supplier diligence, broker communications, and documentation supporting imported merchandise.

In anticipation of these increased enforcement efforts, importers and brokers are likely to seek enhanced diligence and documentation from suppliers and other supply chain participants to comply with new CBP requirements and buttress their internal compliance records.

DOJ also continues to demonstrate its willingness to deploy both criminal authorities and the False Claims Act—including whistleblower actions—to pursue alleged customs fraud. Its emphasis on downstream enforcement likewise suggests that manufacturers, distributors, importers, purchasers, and other participants throughout the supply chain may face scrutiny, even where they are not the importer of record.