Two recent government publications underscore how quickly trade fraud enforcement is intensifying, drawing on CBP's record EAPA duty-evasion milestone and DOJ's expanding trade-fraud enforcement architecture.
CBP's EAPA release describes a record-breaking $1 billion milestone in AD/CVD duty-evasion findings, roughly triple the program's typical annual recoveries. The agency highlights 14 notices of determination in 2026 covering solar cells, lawn groomers, lumber, pipes, xanthan gum, metal lockers, and wooden furniture imported from multiple countries, and notes that investigators traveled to Mexico, Thailand, India, New Zealand, and the United Kingdom to conduct in-person inspections. CBP emphasizes the program's one-year statutory deadline, its transparent and efficient investigation process, and its reliance on allegations from small businesses and other entities that may have limited legal support, all framed within an America First Trade Policy focused on protecting domestic industries subject to AD/CVD orders. That architecture turns EAPA into a fast-moving, allegation-driven enforcement mechanism in which competitors and other market participants can trigger significant duty exposure.
DOJ's Resource Guide to Trade Fraud Enforcement broadens the picture by cataloguing the full range of trade-fraud typologies DOJ is now prioritizing. The Guide covers classic customs fraud—false origin and HTSUS declarations, undervaluation, use of shell importers and broker collusion, drawback abuse, and misuses of free trade agreement preferences—alongside schemes involving counterfeit safety and environmental certifications, illegal logging and wildlife trafficking, and adulterated drugs and devices. DOJ explains how it combines the Tariff Act of 1930, the False Claims Act, criminal conspiracy and wire-fraud statutes, and forfeiture authorities to pursue duty-evasion cases, and highlights its reliance on whistleblowers, data analytics, and inter-agency information-sharing to identify and build matters. In doing so, DOJ positions trade fraud not only as an economic-integrity issue, but also as a national-security and consumer-protection concern.
Against that backdrop, DOJ's new enforcement policy under President Trump is best understood as an institutional commitment to keep trade fraud at the center of DOJ's fraud portfolio. The creation of the National Fraud Enforcement Division and the Global Trade & Commerce Enforcement Section, as well as the launch of the Trade Fraud Task Force, embeds trade-related cases within DOJ's permanent organizational chart and breaks down silos between civil and criminal enforcement components. DOJ has publicly described trade fraud—including customs violations, forced-labor issues, and tariff evasion—as a front-line threat, and has articulated goals such as eliminating two-tier pricing structures that reward non-compliance, leveraging venue statutes to bring cases wherever goods transit, and prioritizing vertically integrated companies that have the ability to police their own supply chains. Taken together, these policy choices reflect a deliberate effort to move trade fraud out of the shadows and into the mainstream of federal enforcement.
For the trade community, the linkage between CBP's EAPA milestone, DOJ's Resource Guide, and DOJ's Trump-era enforcement posture has concrete implications. CBP's reliance on tips and its willingness to deploy investigators overseas means that origin, classification, and valuation decisions are more likely to be revisited after the fact, particularly in AD/CVD-sensitive sectors. DOJ's use of civil False Claims Act theories and its embrace of whistleblower suits increase the odds that routine customs-compliance issues can evolve into high-stakes civil and criminal cases. In this environment, importers, brokers, and logistics providers should view robust origin documentation, auditable classification and valuation methodologies, and mature internal reporting and investigation protocols not as aspirational best practices but as core elements of an enforcement-defense strategy.