On July 14, 2026, the Trade Fraud Task Force (“TFTF”) announced that, in less than a year, it had generated more than $1 billion in civil and criminal recoveries, penalties, forfeitures and publicly charged losses. Accompanying the milestone, the Department of Justice (“DOJ”) announced two significant new criminal cases, established a dedicated litigating section devoted to customs and trade enforcement, and—together with the Department of Homeland Security (“DHS”), including its component agencies, Homeland Security Investigations (“HSI”) and U.S. Customs and Border Protection (“CBP”)—released a first-of-its-kind resource guide for the private sector. The announcement and resource guide follow President Trump’s June 3rd Executive Order on Strengthening Customs Enforcement, which also called for robust criminal and civil enforcement of the customs laws.

The diverse range of industries featured in the TFTF’s enforcement actions is particularly noteworthy, and it reinforces that customs and trade fraud includes material misrepresentations to CBP and the partner government agencies (“PGAs”) whose laws CBP has long enforced at U.S. borders, such as those governing product safety and external revenue collection, e.g., the Food and Drug Administration (“FDA”), Department of Commerce (“DOC”), the United States Trade Representative (“USTR”), Internal Revenue Service (“IRS”), Environmental Protection Agency (“EPA”) and Consumer Product Safety Commission (“CPSC”). DOJ and CBP are leveraging robust cooperation among PGAs and U.S. Attorneys’ Offices. The initial announcement of the Task Force launch in August 2025 mentioned the planned partnership among DOJ, CBP and HSI. This latest announcement features an expanded “masthead” of Federal partners, including 35 U.S. Attorneys’ Offices, and law enforcement personnel from various PGAs, among others. Together, these developments confirm that customs and trade fraud enforcement is a durable, institutionalized priority for the United States government and the Trump Administration.

DOJ’s New Dedicated Litigating Component: The Global Trade & Commerce Enforcement Section

Among the most significant developments announced by DOJ was the creation of the Global Trade & Commerce Enforcement Section (“GTCES”) within the National Fraud Enforcement Division. According to DOJ, the GTCES’s mission is to investigate and prosecute criminal customs fraud, other trade fraud offenses that undermine American industries and competitiveness, evade external revenue collection, threaten consumers’ health and safety, finance foreign adversaries, promote forced labor through illegal trade practices and violate U.S. laws governing unfair trade practices harming U.S. industries, such as antidumping and countervailing duty fraud (“AD/CVD”).

The formation of a permanent, dedicated litigating section is significant. Whereas a task force can be understood as a coordinating mechanism, the establishment of a new section within the National Fraud Enforcement Division institutionalizes customs and trade fraud enforcement as an enduring component of DOJ’s organizational structure and resourcing, signaling that this is not a short-term initiative tied to a single policy cycle. That level of institutional coordination, with the full support of President Trump, suggests that trade-fraud investigations will increasingly draw upon specialized expertise from across the federal government and may extend well beyond traditional customs-enforcement issues. The breadth of the GTCES’s stated mission, spanning revenue evasion, consumer safety, national security and forced labor, also indicates that companies should expect trade enforcement to be pursued alongside, and in coordination with a widening array of collateral concerns rather than as a narrow customs-duty matter. DOJ underscored that the success of both the GTCES and the TFTF rests on unprecedented cooperation among Main Justice, U.S. Attorneys’ Offices and law enforcement partners, including CBP, HSI, IRS Criminal Investigation (“IRS-CI”), the EPA’s Criminal Investigation Division (“EPA-CID”), the U.S. Fish and Wildlife Service, the CPSC and the FDA.

Recent Country of Origin Prosecutions Contribute to the $1 Billion Milestone

Two new cases brought by the U.S. Attorney’s Office for the Northern District of Illinois (NDIL)—which the TFTF has designated as its lead prosecutorial partner—contributed to the TFTF surpassing the $1 billion milestone. Both cases, which the DOJ announced along with the news of the $1 billion milestone, criminally charge customs duty evasion schemes involving the false declaration of countries of origin for gold jewelry to avoid duties of between 5.5% and 5.8% of declared value. These cases highlight how rigorously CBP is now focusing on country-of-origin investigations and requests for information and alleged duty evasion, as many importers around the country can now attest.

In the first case, Raj Kohli and Veena Kohli, operators of a gold jewelry importer and wholesaler based in California, were charged with avoiding more than $38 million in customs duties on gold jewelry between August 2020 and May 2024. The government alleges that the defendants falsely represented that gold jewelry originated in Singapore to obscure its true origins from India and the United Arab Emirates. This case underscores the TFTF’s nationwide reach: according to DOJ, “the port of entry is only the starting point,” and the government will consider prosecuting offenses in any judicial district from, through which or into which imported objects move.

The second case charged Narain Gulabani, a gold jewelry importer and wholesaler in Illinois, with falsely declaring that gold jewelry originated in Oman or Singapore. The government alleges that this scheme occurred between May 2016 and October 2021 and allowed the defendant to evade approximately $13.6 million in customs duties.

These cases also highlight the impact of cross-government collaboration on investigating and prosecuting trade fraud cases.

A New “Resource Guide” for the Private Sector

Alongside these enforcement developments, DOJ and DHS jointly released A Resource Guide to Trade Fraud Enforcement (the “Guide”), which DOJ described as the first joint comprehensive framework of its kind that provides the private sector with a “transparent, comprehensive manual on trade fraud enforcement.”

The language of the Guide further underscores that combating trade fraud through criminal prosecutions and civil enforcement actions under the False Claims Act (“FCA”) remains a key priority for DOJ and DHS. The Guide notes that “[t]he stakes extend well beyond the ledger of a single company or the collection of a specific duty or tariff,” explaining that enforcement actions against trade fraud serve to protect “the integrity of our borders and national security and the economic stability” of the nation.

The Guide is designed to help private sector actors understand enforcement priorities and common forms of trade, customs and related fraud. It outlines the relevant legal definitions and statutory requirements for each enforcement area and provides practical insight into DOJ and DHS enforcement approaches through real-world examples of prior enforcement actions. In particular, in discussing the importance of compliance with external revenue authorities, the Guide focuses on special tariffs enforced by CBP and administered by DOC, USTR and the President (e.g., Sections 232, 201 and 301 tariffs, and AD/CVD).

Customs-Related Trade Fraud

Consistent with the administration’s prior announcements, customs-related enforcement occupies a large portion of the Guide. The Guide covers the customs entry process and the legal obligations of the parties involved, as well as providing descriptions and practical examples of common forms of trade fraud, including false country-of-origin declarations and markings, false Harmonized Tariff Schedule (“HTS”) classification, undervaluation, and forced labor, among others. The Guide also devotes substantial attention to forced labor enforcement, describing the regulatory landscape under Section 307 of the Tariff Act of 1930 and the Uyghur Forced Labor Prevention Act.

DOJ emphasized that CBP has stepped up enforcement of trade violations, complementing parallel efforts by DOJ and DHS. To date in Fiscal Year 2026, CBP has assessed more than $2.1 billion in commercial trade penalties and debarred 35 entities from conducting business with the federal government.

No Changes to Voluntary Self-Disclosure Policy

Notably, the Guide makes no mention of voluntary self-disclosure. The Department has signaled that it does not intend to issue further component-specific disclosure policies during this administration and that the DOJ-wide Corporate Enforcement Policy, which applies across criminal matters, is the operative framework (see our prior alert here).

The Guide is nonetheless heavy on customs law and references Section 592 of the Tariff Act of 1930, under which the voluntary self-disclosure mechanism is statutory. The prior-disclosure provisions of Section 592(c) are not a matter of prosecutorial policy, but a civil statutory right that remains available. CBP has long encouraged prior disclosures, and timely prior disclosure may reduce the likelihood of a criminal investigation by Homeland Security Investigations.

Key Takeaways

• DOJ is building the infrastructure necessary to pursue customs and trade fraud more aggressively, and trade fraud is now an institutionalized enforcement priority. The billion-dollar milestone, the creation of the GTCES within the National Fraud Enforcement Division and the release of a joint DOJ–DHS resource guide together signal a durable commitment that will outlast any single case or news cycle. The Guide also describes other potent criminal and civil sanctions that DOJ could use increasingly, such as money laundering involving the proceeds of smuggling and entry of goods by means of false statements, as well as criminal/civil forfeitures.
• Country-of-origin, classification accuracy and duty evasion are front-and-center. The latest criminal cases filed in Chicago target false country-of-origin declarations, and the Guide highlights undervaluation, false country-of-origin reporting and false HTSUS classifications as core enforcement topics, all of which can result in duty evasion. Importers should validate origin, classification determinations and duty payments—and retain supporting documentation demonstrating admissibility.
• Expect cross-agency and parallel scrutiny. The TFTF leverages specialized expertise from CBP, HSI, IRS-CI, EPA-CID, Fish and Wildlife, CPSC, and FDA, and forced labor is a stated priority. A single customs entry can trigger collateral inquiries across multiple regulatory regimes.

• False Claims Act whistleblowers are driving enforcement. According to DOJ press releases over the past year, the Department has recovered approximately $640 million in FCA actions involving alleged duty evasion, making up the lion’s share of the more than $1 billion DOJ has recovered since the launch of the TFTF.¹ These results reflect the statute’s versatility and ability to reach conduct up and down the supply chain, from foreign suppliers, to importers, brokers and domestic commercial end-users.
• CBP administrative enforcement is escalating in parallel. In the current fiscal year, CBP has assessed more than $2.1 billion in commercial trade penalties and debarred 35 parties from doing business with the federal government, actions that complement DOJ’s criminal and civil tools.

How Akin Can Help

These developments underscore the substantial civil, criminal and regulatory risks now facing companies that import goods subject to complex tariff, country-of-origin, valuation and classification requirements. Akin’s Customs/International Trade Practice, White Collar Defense & Government Investigations, and False Claims Act/Qui Tam Defense practices advise importers, manufacturers, distributors and their boards on customs compliance, internal investigations, whistleblower complaints, government inquiries, disclosure strategies and trade-fraud enforcement matters. Our integrated team pairs customs and trade attorneys who understand the technical regulatory framework with defense counsel experienced in handling civil and criminal investigations and litigation, and includes former senior officials from CBP, DOJ (including the Civil and Criminal Fraud Sections), DHS, the Department of Commerce and the Office of the U.S. Trade Representative. As the Trade Fraud Task Force, the new Global Trade & Commerce Enforcement Section and CBP’s administrative enforcement continue to converge, we are well positioned to help clients assess exposure, strengthen compliance programs and navigate government enforcement actions across every stage of the global supply chain.

¹ See Press Release, U.S. Dep't of Just., Perfectus Aluminum Inc. and Related Companies Agree to Pay $549.5M to Settle False Claims Act Allegations (May 12, 2026); Press Release, U.S. Dep't of Just., Ceratizit USA LLC Agrees to Pay $54.4M to Settle False Claims Act Allegations Relating to Evaded Customs Duties (Dec. 18, 2025); Press Release, U.S. Dep't of Just., Importers Agree to Pay $6.8M to Resolve False Claims Act Liability Relating to Voluntary Self-Disclosed Customs Violations (July 23, 2025); Press Release, U.S. Att'y's Off. for the E. Dist. of Tenn., Echelon Fitness Multimedia, LLC Agrees to Settle False Claims Act Allegations for $2.1 Million (April 24, 2026); Press Release, U.S. Dep't of Just., Allied Stone Inc. and Company Official Agree to Pay $12.4M to Settle False Claims Act Allegations (Aug. 19, 2026); Press Release, U.S. Att'y's Off. for the E. Dist. of Mich., International Audio Electronics Company Harman Pays $11.8 Million to Settle Fraud Allegations (Nov. 26, 2025); Press Release, U.S. Dep't of Just., Redi-Bag USA and CEO Agree to Pay $7.3M to Settle False Claims Act Allegations Relating to Evaded Customs Duties (July 15, 2026).