The Justice Department’s recent docket on customs enforcement reflects a policy choice to treat trade fraud as a priority enforcement area. For this purpose, Trade Fraud Task Force was launched by DOJ and DHS in August 2025. It brings together DOJ’s Civil and Criminal Divisions, U.S. Customs and Border Protection (CBP), and Homeland Security Investigations (HSI) with the stated mission to pursue parties that evade tariffs and other duties, as well as smugglers who bring prohibited goods into the United States. DOJ has said it will use duty- and penalty-collection actions under the Tariff Act, False Claims Act (FCA) cases, and, where appropriate, criminal prosecutions, penalties, and seizures as its principle enforcement mechanisms.

In June 2026, Executive Order 14411, Strengthening Customs Enforcement directed the Secretary of Homeland Security and the Attorney General to prioritize enforcement involving forced-labor imports, misclassification, undervaluation, and illegal transshipment. The EO called for increased audits, strengthened importer-of-record requirements and bond coverage, enhanced importer disclosures, and greater enforcement against noncompliant parties. Shortly later, on July 14, the DOJ announced that the Trade Fraud Task Force had exceeded $1 billion in civil and criminal recoveries, penalties, forfeitures, and publicly charged losses in less than a year. That figure includes the government’s coordinated use of civil, criminal, customs, and border-enforcement tools. Through August 6, DOJ had announced five significant customs-related FCA resolutions in 2026 totaling $583.05 million. The cases concern alleged evasion of antidumping and countervailing duties (AD/CVD), inaccurate origin declarations, and undervaluation. Several arose from qui tam suits, reinforcing that customs FCA exposure often begins with a report from someone with knowledge of the supply chain.

The 2026 customs FCA resolutions

  • Perfectus Aluminum and related companies (May 12, 2026) — $549.5 million. Alleged evasion of AD/CVD on Chinese aluminum extrusions by representing more than 2.2 million extrusions as finished pallets outside the scope of applicable orders.

  • Farjess Inc., Royal Canadian Steel Inc., and owner (May 20, 2026) — $19 million. Alleged false origin declarations for flat-rolled steel, including declarations of Canadian or U.S. origin rather than the alleged actual countries of production.

  • Redi-Bag USA and its CEO (July 16, 2026) — $7.3 million. Alleged false origin declarations for Chinese retail carrier bags to avoid antidumping duties.

  • Everlight Electronics and Everlight Americas (August 5, 2026) — $5.15 million. Alleged evasion of duties on LED products imported from China, resolving FCA, common-law, and Tariff Act allegations.

  • Echelon Fitness Multimedia (April 24, 2026) — $2.1 million. Alleged undervaluation of imported fitness equipment, including the alleged failure to declare the value of tablets incorporated into the equipment.

The Perfectus settlement is the outlier in size, accounting for nearly 94 percent of the total. But the remaining cases are more revealing of the government’s current approach. They involve different products, different alleged conduct, and different duty consequences. The common thread is that DOJ is treating customs declarations as representations that can support civil fraud liability when the government alleges knowing falsity and a material underpayment of duties.

Origin, AD/CVD, and value remain the pressure points

The steel and Redi-Bag settlements place country of origin at the center of the enforcement story. In each, DOJ alleged that merchandise was declared to originate in a country other than its actual country of production, avoiding duties that would otherwise have applied. Origin determinations are particularly sensitive where goods undergo processing, assembly, or finishing in more than one country, or where a supply chain includes a third-country intermediary.

AD/CVD risk remains the most consequential category. The Perfectus case illustrates why. DOJ alleged that Chinese aluminum extrusions were spot-welded to resemble pallets and entered as finished merchandise not subject to the applicable orders. The government further alleged that there were no customers for the pallets and that none were sold. Whether a product falls inside an AD/CVD scope is a legal and factual question. It cannot be solved by a convenient invoice description.

Echelon shows that valuation controls deserve the same attention. DOJ alleged that the declared value of fitness equipment failed to include the value of incorporated tablets. Importers should assess whether their customs values correctly address assists, royalties, components, packing, selling commissions, and other additions required by the valuation rules.

The Task Force is using more than FCA cases

The FCA settlements are only one part of the enforcement program. DOJ’s July announcement made clear that the Task Force is also pursuing criminal cases, product-safety violations, and conduct involving downstream supply-chain participants.

Boise Cascade: purchaser risk

In April, Boise Cascade pleaded guilty to a felony Lacey Act violation and was sentenced to pay a $6.382 million criminal fine in connection with Chinese birch plywood that DOJ alleged had been imported illegally through a duty-evasion scheme. DOJ alleged that, beginning in approximately 2019, Boise Cascade purchased, received, sold, and transported hardwood plywood from Horizon Plywood while knowing, or through actions manifesting willful blindness, that the plywood had been illegally imported from China, in violation of the Lacey Act, 16 U.S.C. §§ 3372(a)(1), 3373(d)(1)(B). The underlying importation was illegal because Horizon smuggled the wood and falsified import declarations regarding the species and country of origin of the hardwood and softwood plywood, which allowed evasion of antidumping and countervailing duties on Chinese hardwood plywood (22.98 percent countervailing and 183.36 percent antidumping) that applied from December 2017 through April 2021.

The case did not involve an FCA settlement. Its importance lies elsewhere. It shows that the government may look beyond the importer of record where a purchaser, distributor, or other supply-chain participant allegedly knew of (or deliberately disregarded) an unlawful import scheme.

Gold jewelry: criminal origin-fraud charges

DOJ also brought criminal cases involving alleged origin fraud in the gold-jewelry trade. In July, it charged the operators of South San Francisco-based Surya International, alleging that they falsely declared jewelry as originating in Singapore rather than India and the United Arab Emirates. DOJ alleges that the conduct involved 563 entries with a declared value exceeding $693 million and more than $38 million in avoided duties.

The government separately charged the owner of Barkha Wholesale, an Illinois gold-jewelry importer. It alleges that the importer falsely declared jewelry as originating in Oman or Singapore, resulting in more than $13.6 million in avoided duties. These are charges, not adjudicated findings. They nonetheless show that DOJ is prepared to use criminal statutes when it alleges intentional origin fraud.

Royal Sovereign: imported-product safety

In April, Royal Sovereign International was sentenced to pay an $8 million criminal fine and approximately $395,786 in restitution for failing to report dangerously defective imported air conditioners to the Consumer Product Safety Commission. DOJ stated that the company imported and sold more than 33,000 Chinese-manufactured air conditioners connected to more than 40 fires and one death.

Royal Sovereign is not a customs-duty case. It belongs in the larger picture because the Task Force’s work is not confined to revenue collection. Import compliance may also create exposure under product-safety, forced-labor, intellectual-property, environmental, and criminal laws.

The settlements and resolutions discussed above resolve allegations and do not necessarily constitute adjudications of liability. The criminal matters described above involve allegations that have not necessarily been proven up in court. This article is for general informational purposes and is not legal advice.

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AuthorMatt Nakachi