On July 14, 2026, the U.S. Department of Justice and the Department of Homeland Security jointly published “A Resource Guide to Trade Fraud Enforcement,” outlining the government’s enforcement approach to customs and trade violations for companies operating across the supply chain.
DOJ and DHS published the Resource Guide alongside a press release announcing that the interagency Trade Fraud Task Force (TFTF) surpassed $1 billion in civil and criminal recoveries, penalties, and forfeitures since its launch in August 2025 — a milestone DOJ described as “emphasizing rigorous criminal prosecution and civil enforcement under the False Claims Act.” The announcement offers several key takeaways for companies with operations touching the global supply chain.
Trade fraud is a key enforcement priority. DOJ and DHS have emphasized that trade fraud is a key enforcement priority. Throughout its 27 pages, the Resource Guide describes DOJ and DHS’s “shared enforcement approach and priorities; refers to their trade fraud enforcement agenda as a “coordinated priority;” and characterizes the preparation of the guide as “an unprecedent joint undertaking.” DOJ also announced the creation of a new enforcement arm, the Global Trade & Commerce Enforcement Section (GTCES) within the National Fraud Enforcement Division (NFED), indicating that DOJ is institutionalizing its commitment to trade fraud enforcement. GTCES’s mission focuses on investigating and prosecuting “criminal import, trade, and other fraud offenses that undermine American industries, evade external revenue collection, threaten consumers’ health and safety, finance foreign adversaries, promote forced labor through illegal trade practices, and violate United States laws and regulations governing domestic and foreign commerce.”
Prior enforcement actions have focused on the following types of fraud:
- Manifest fraud
- False country of origin (COO) declarations and markings
- False HTS classification
- Intentional undervaluation of imported goods
- Anti-dumping / Countervailing duty (AD / CVD) evasion
- Shell company fraud
- Customs broker fraud
- Drawback fraud (false export claims)
- Free Trade Agreement (FTA) fraud
- Port shopping
- “Prior notice” and improper alerts evasion for regulated food
- Forged product safety or environmental certification (e.g., CPSC / EPA fraud)
- Failure to report dangerous or defective products or adverse events
- False declaration of regulated commodities
- Illegal timber and wildlife laundering (Lacey Act, Endangered Species Act, etc.)
- Importing adulterated drugs and devices
The government is examining the entire supply chain — not just point of entry. DOJ’s trade fraud enforcement agenda extends beyond importers to customs brokers, wholesalers, transporters, purchasers, and others. The Resource Guide makes clear that companies may not escape liability by claiming ignorance of their supply chain partners’ trade fraud violations. Companies should therefore assess their supply chain partners’ businesses to avoid unwittingly facilitating trade fraud violations.
Compliance should become a core component of supply chain businesses’ risk management strategies. To reduce exposure to criminal, civil, and administrative penalties associated with trade fraud violations, DOJ encourages supply chain businesses to invest in robust, evolving compliance measures. Responsibility for compliance should rise to the C-suite and boardroom.
The Resource Guide lists some recommended compliance steps:
- Actively auditing supply chains for compliance risks;
- Verifying representations made by supply chain partners;
- Avoiding willful blindness to economic realities, market conditions, or supply sources; and
- Ensuring a compliance culture adhering to customs laws that extends from the front-line operations to the boardroom.
Candor with enforcement authorities is required. Trade compliance relies heavily on truthful disclosure on government forms enabling the import of goods (e.g., Form 3461 and Form 7501). The Resource Guide states that “candor is not just the best practice; it is a legal requirement.” When investigating false statements on these forms, DOJ will assess whether any false statement was attributable to negligence, recklessness, deliberate ignorance of fraud, or intentional criminality. The scope of penalties or fines imposed may depend on the degree of a company’s culpability. Companies that discover potential trade fraud violations should consider avenues for voluntary self-disclosure to the government, which may mitigate otherwise more stringent fines, penalties, or enforcement dispositions.
Companies may see increased whistleblower activity. DOJ’s press release encourages whistleblowers to report credible allegations of trade fraud through either DOJ’s corporate whistleblower awards pilot program (launched in 2024) or the False Claims Act. Given the availability of financial incentives for qualifying whistleblowers who report fraud, the guide signals that companies operating across the supply chain may face increased whistleblower reporting, as well as scrutiny of their compliance and employment practices related to individuals asserting whistleblower status.