The DOJ Trade Fraud Task Force Has Recovered Over $1B. Here’s What It Means.

Key Takeaways: 

• The DOJ and DHS Trade Fraud Task Force, launched in August 2025, surpassed $1 billion in civil and criminal recoveries, penalties, forfeitures, and charged losses in under one year.
• The 31-page DOJ-DHS Resource Guide to Trade Fraud Enforcement identifies 16 customs fraud typologies, including transshipment, false country-of-origin declarations, antidumping duty evasion, and forced labor violations across 12 expanded priority sectors under the Uyghur Forced Labor Prevention Act.
• Trade fraud liability under Section 545 of Title 18 now extends beyond importers of record to wholesalers, distributors, and retailers; companies that demonstrate willful blindness to supply chain violations face up to 20 years of criminal exposure.

The Department of Justice (DOJ) and Department of Homeland Security (DHS) launched the Trade Fraud Task Force (TFTF) in August 2025. Less than a year later, the agencies crossed $1 billion in combined recoveries, penalties, forfeitures, and publicly charged losses. The same day, they released a 31-page Resource Guide to Trade Fraud Enforcement, the first joint DOJ-DHS enforcement framework of its kind.

What Does the $1 Billion Trade Fraud Task Force Tally Actually Represent?

The figure requires context. It aggregates past settlements, active criminal charges, and administrative penalties into a single number. Perfectus Aluminum’s $549.5 million False Claims Act settlement, announced in May 2026 and the largest civil customs FCA settlement in U.S. history, accounts for more than half the total. Related criminal convictions in that matter date to 2021, before the task force existed.

The active cases tell the real enforcement story. In July 2026, federal prosecutors in Chicago charged gold jewelry importers Surya International and Barkha Wholesale with evading more than $51.6 million in duties across $933 million in imported goods. CBP separately assessed $2.1 billion in commercial trade penalties this fiscal year, with 35 parties debarred from federal contracting.

“For too long, fraud actors have viewed customs violations as a mere surcharge or cost of doing business,” said Assistant Attorney General Colin McDonald of the Justice Department’s National Fraud Enforcement Division. “By utilizing the Department’s full weight, we are making it clear that trade fraud is a serious economic crime. This billion-dollar milestone demonstrates that the United States and the National Fraud Enforcement Division will no longer allow the integrity of our country’s borders and markets to be compromised for illicit profit. This message should be heard loud and clear by all supply-chain actors.”

Which 16 Fraud Typologies Does the DOJ’s Resource Guide Now Target?

The Resource Guide catalogs 16 distinct fraud patterns. The most prosecuted involve false country-of-origin declarations, transshipment through third countries, mislabeling of product classifications, undervaluation, and evasion of antidumping and countervailing duties. A single import entry can face ordinary duties, Section 301 tariffs, antidumping or countervailing duties, and Section 232 measures simultaneously, which makes those categories a predictable enforcement priority.

Forced labor receives its own dedicated chapter. The Forced Labor Enforcement Task Force expanded its high-priority sector list from four to 12, adding aluminum, polyvinyl chloride, seafood, steel, copper, lithium, caustic soda, and jujubes to its original four: apparel, cotton, silica-based products, and tomatoes. The Uyghur Forced Labor Prevention Act establishes a rebuttable presumption that goods originating in or connected to the Xinjiang region are barred from entry.

How Far Does Customs Fraud Liability Reach Beyond the Importer of Record?

Further than most compliance teams expect. Under the second paragraph of Section 545 of Title 18, anyone who receives, conceals, buys, or sells goods known to have been imported contrary to law faces the same 20-year criminal exposure as the original importer.

“Those involved in importing goods into the United States have always had a duty of care and candor to ensure they are abiding by trade laws,” states the guide. “Corporations must continually adjust their compliance measures to reflect the complexities of the regulatory climate and their evolving supply chains. The era when a company can claim ignorance of its upstream partners’ activities is over.”

Boise Cascade’s April 2026 guilty plea makes the precedent concrete. Boise Cascade received a $6.3 million criminal fine for Lacey Act violations involving illegally imported birch plywood as a downstream buyer, not as the importer of record. Willful blindness, not direct participation, was the standard prosecutors applied.

What Should Companies Do Right Now to Reduce Trade Fraud Exposure?

Start with records. Entry filings, broker communications, origin certificates, and purchase invoices are the evidentiary backbone of every customs fraud investigation. The five-year minimum retention requirement must be followed. Legal teams should verify that broker oversight stays documented and that classification decisions hold up against real standards, not just supplier certificates.

Companies that discover any potential issues should consult counsel promptly about voluntary self-disclosure. DOJ credited timely disclosure when plastic resin importers resolved False Claims Act liability for $6.8 million, a fraction of what a contested matter would have cost. Public companies carry an additional layer of exposure: trade fraud that distorts financial reporting can trigger books-and-records violations under federal securities law.