DOJ and CBP Intensify Customs Fraud Enforcement

False Claims Act exposure and practical compliance considerations for U.S. importers

The Regulatory Development

The U.S. Department of Justice (DOJ), in coordination with the Department of Homeland Security (DHS), established a Trade Fraud Task Force in August 2025 to strengthen enforcement against customs fraud and tariff evasion.

In July 2026, DOJ announced significant enforcement results involving customs-related violations, reinforcing the government’s increased focus on civil and criminal accountability throughout the international supply chain.

Why This Matters

Importers and other parties that knowingly make material false statements or knowingly and improperly avoid customs duty obligations may face civil liability under the False Claims Act, including potential treble damages and statutory penalties.

Not every Customs error constitutes fraud. Liability depends on the specific facts and applicable legal standards.

Key Compliance Priorities

ECHB encourages importers to review:

• Country-of-origin determinations and supporting supplier documentation.
• HTS classifications and declared customs values.
• Applicability of Section 301 tariffs and antidumping/countervailing duties.
• Duty payments, recordkeeping, and internal compliance controls.

Recommended Action

Importers should periodically review Customs declarations and supporting records, promptly investigate discrepancies, and evaluate appropriate corrective measures, including CBP prior disclosures when warranted.

How ECHB Can Assist

Express Customhouse Broker, Inc. assists importers with tariff classification, entry compliance, trade remedy requirements, and related Customs procedures.

Clients seeking assistance in reviewing their import compliance practices are encouraged to contact our office.

Official Sources

• DOJ/DHS — Trade Fraud Task Force Announcement (August 29, 2025)
• DOJ — Trade Fraud Task Force Enforcement Update (July 14, 2026)
• False Claims Act — 31 U.S.C. § 3729 (GPO)

EXPRESS CUSTOMHOUSE BROKER, INC.
advisory@expresschb.com | www.expresschb.com

This advisory is provided for general informational purposes and does not constitute legal advice. Regulatory requirements and appropriate corrective measures depend on the circumstances of each transaction.