A series of recent government actions suggest that U.S. trade enforcement efforts are intensifying, with further escalation likely in 2026. For importers, this trend underscores the growing importance of robust compliance programs as federal agencies increase scrutiny of tariff evasion, misclassification, and country-of-origin violations. Failure to comply carries not only financial penalties, but also significant reputational and operational risk.
In early 2025, the Department of Justice announced that its Criminal Division would prioritize the prosecution of trade and customs fraud as part of its broader focus on corporate and white-collar crime. This shift formally elevated tariff evasion and customs fraud to enforcement priorities and expanded the DOJ’s corporate whistleblower awards pilot program to include trade-related misconduct.
Renewed Focus on Trade Fraud Enforcement
The DOJ reinforced this approach by launching a revitalized Trade Fraud Task Force aimed at identifying and prosecuting schemes designed to evade tariffs, duties, and import restrictions. The task force is pursuing enforcement through multiple channels, including:
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Duty and penalty recovery actions under the Tariff Act of 1930
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Civil actions under the False Claims Act
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Criminal prosecutions, penalties, and seizures under federal trade fraud and conspiracy statutes
The initiative brings together both civil and criminal enforcement resources, working closely with U.S. Customs and Border Protection and Homeland Security Investigations. Authorities have also encouraged referrals and cooperation from domestic industries impacted by unfair trade practices and customs fraud.
Recent Enforcement Actions Highlight the Risks
In December 2025, the DOJ announced several cases demonstrating that these enhanced enforcement efforts are producing tangible results:
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A U.S.-based company agreed to pay $54.4 million to resolve allegations that it misrepresented the country of origin of imported goods to avoid Section 301 tariffs, misclassified products to reduce duties, and failed to comply with country-of-origin marking requirements.
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A licensed customs broker was sentenced to more than four years in federal prison and ordered to pay $7.6 million in restitution for submitting falsified customs documentation and defrauding clients by misappropriating funds intended for duty payments.
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A domestic importer affiliated with a multinational company agreed to pay more than $53 million, including substantial civil penalties, to settle claims that it avoided antidumping duties over a multi-year period through false classification and nondisclosure.
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In another case, a global company under criminal investigation avoided prosecution due to timely voluntary disclosure, corrective actions, compliance program enhancements, and repayment of evaded tariffs. However, a senior executive involved in the misconduct pleaded guilty to conspiracy charges and faces potential prison time.
Compliance Preparation Becomes Essential
Many industry observers expect similar enforcement actions to increase in frequency and scope throughout 2026. In response, companies are being urged to proactively strengthen compliance frameworks rather than rely on reactive measures.
Best practices include conducting internal risk assessments, reviewing tariff classifications and country-of-origin determinations, evaluating broker oversight procedures, and updating compliance policies to reflect current enforcement priorities. Early identification of vulnerabilities can reduce exposure and improve outcomes if regulatory scrutiny arises.
As trade enforcement continues to intensify, companies that invest in compliance, documentation accuracy, and internal controls will be better positioned to navigate the evolving regulatory landscape while minimizing legal, financial, and reputational risk.
