On July 14, 2026, the government announced it had recovered over $1 billion in trade fraud penalties in under a year — and published a 16-priority enforcement playbook telling you exactly what they're looking for next. If your compliance program hasn't changed since 2024, you're operating on borrowed time.
On May 12, 2026, Perfectus Aluminum and its network of affiliated companies agreed to pay $549.5 million to settle False Claims Act allegations. Their scheme was straightforward: import Chinese aluminum, lie on customs forms to present it as finished merchandise not subject to antidumping duties, and pocket the difference. The company had already been criminally convicted five years earlier — the settlement just finalized the financial reckoning.
Two months later, the Department of Justice stood at a podium and announced that its Trade Fraud Task Force had crossed $1 billion in combined civil and criminal recoveries, penalties, forfeitures, and charged losses — all in less than twelve months of operation.
That's not a typo. One billion dollars. In one year. From a task force that didn't exist before August 2025.
And they're just getting started.
The Trade Fraud Task Force: What Changed in 2026
The Trade Fraud Task Force (TFTF) launched in August 2025 as a joint effort between the Department of Justice and Department of Homeland Security. Its mandate was simple: treat customs and tariff evasion like the serious federal crime it already is on the books — not the administrative nuisance it was treated as for decades.
The results speak for themselves. In Fiscal Year 2026 alone, CBP has assessed more than $2.1 billion in commercial trade penalties and debarred 35 entities from conducting business with the federal government. The EAPA program — CBP's dedicated anti-evasion mechanism — issued 14 evasion notices in 2026, a record number that's 300% above its annual average. It's the first time in EAPA's 10-year history that recoveries crossed the billion-dollar mark.
This isn't incremental escalation. This is a regime change in how the federal government treats trade fraud.
The GTCES: A Permanent Prosecution Machine
On July 14, 2026, DOJ announced the creation of the Global Trade & Commerce Enforcement Section (GTCES) within its National Fraud Enforcement Division. This is the institutional signal that matters most: trade fraud enforcement is no longer a campaign. It's a permanent, staffed, specialized prosecution unit.
GTCES trial attorneys lead complex, transnational investigations and prosecutions in federal district courts across the country. Their mission statement explicitly targets criminal import fraud, external revenue evasion, supply chain forced labor offenses, and "related trade crimes." They coordinate interagency enforcement operations — meaning CBP findings feed directly into criminal prosecution pipelines.
Think of GTCES as the trade equivalent of the DOJ's National Security Division or its Fraud Section. When the government creates a dedicated section, it means they're building careers around putting people in prison for this specific conduct.
The 16-Priority Resource Guide: Your Compliance Checklist
Perhaps the most operationally significant development is the joint DOJ-DHS Resource Guide to Trade Fraud Enforcement, released July 2026. This is the first comprehensive statement of DOJ's enforcement approach to customs and trade fraud — ever. It identifies 16 active enforcement priorities:
| Priority | What It Means for Importers |
|---|---|
| Manifest fraud | False cargo descriptions on shipping documents |
| False country of origin | Misdeclaring where goods were manufactured |
| False HTS classification | Declaring wrong tariff codes to reduce duties |
| Undervaluation | Reporting artificially low transaction values |
| AD/CVD evasion | Circumventing antidumping/countervailing duty orders |
| Shell company fraud | Using entity structures to obscure beneficial ownership |
| Customs broker fraud | Brokers facilitating or turning blind eye to violations |
| Drawback fraud | Filing false claims for duty refunds on exports |
| FTC fraud | Deceptive trade practices tied to imports |
| Port shopping | Routing entries through ports with perceived lax enforcement |
| Evading FDA protections | Importing without required FDA clearances |
| Forged certifications | Fake certificates of origin, conformity, or compliance |
| Failure to report defects | Importing known-defective consumer products |
| False declaration of regulated commodities | Misdeclaring controlled substances or materials |
| Illegal timber/wildlife trafficking | Lacey Act and CITES violations |
| Adulterated drugs/devices | Importing substandard pharmaceuticals or medical devices |
If your company touches any of these 16 areas — and if you're importing, you almost certainly touch at least three — this document is now your adversary's playbook. Read it.
"Candor Is a Legal Requirement": The New DOJ Posture
Here's the line from the Resource Guide that should keep compliance officers up at night: candor toward the government is now framed as a legal requirement, not merely a best practice.
This is a notable shift. Previously, DOJ incentivized voluntary self-disclosure through reduced penalties. The new posture goes further — it frames the failure to be forthcoming as itself a compliance failure that can escalate administrative violations into criminal exposure.
The practical implication: if you discover a classification error, a country-of-origin discrepancy, or a valuation problem in your historical entries, the window to self-disclose without criminal exposure is narrowing. DOJ's voluntary self-disclosure policy still exists and still provides credit — but the Resource Guide makes clear that the government views concealment of known violations as an independent basis for prosecution.
Liability Now Reaches Beyond the Importer of Record
Perhaps the most alarming expansion in the new enforcement framework is the reach of liability. The Resource Guide states that responsibility extends to anyone who knowingly receives, conceals, buys, sells, or facilitates the movement of illegally imported goods.
This isn't theoretical. In April 2026, Boise Cascade Company pleaded guilty and paid a $6.3 million criminal fine for a Lacey Act violation involving timber trafficking to evade AD/CVD duties. The critical detail: Boise Cascade was not the importer of record. They were a downstream buyer who knew — or should have known — that the lumber they purchased had been illegally imported.
The message is unambiguous: if you're a distributor, retailer, or end-user purchasing goods at prices that seem too good to be true, you now face potential criminal exposure. "I didn't file the entry" is no longer a defense.
For customs brokers, the stakes are equally high. Customs broker fraud is explicitly listed as one of the 16 enforcement priorities. Brokers who facilitate violations — even through willful blindness rather than active participation — are squarely in the crosshairs.
The Anatomy of a Modern EAPA Case
To understand what enforcement looks like in practice, consider EAPA Consolidated Case No. 8163, decided June 23, 2026. CBP found substantial evidence that a major solar-module importer evaded AD/CVD orders on crystalline silicon photovoltaic cells (HTS heading 8541.40) from China.
The finding covered the Vietnam Circumvention Determination and the Malaysia and Vietnam AD/CVD Orders. The importer's strategy — sourcing cells nominally manufactured in Southeast Asia but incorporating Chinese-origin silicon — failed despite a critical fact: the importer fully cooperated with CBP's investigation.
Full cooperation. Responsive to every document request. Still found liable for evasion.
The lesson isn't that cooperation doesn't matter (it does — it can reduce penalties). The lesson is that cooperation is not a defense against an evasion finding. If the goods are covered merchandise transshipped through a third country, the duty attaches regardless of the importer's subjective intent or cooperative posture.
What $549 Million in Aluminum Fraud Looks Like
The Perfectus Aluminum case deserves closer examination because it illustrates the scale DOJ is now pursuing. Perfectus and its related entities — including Scuderia Development LLC, 1001 Doubleday LLC, and other companies affiliated with Chinese businessman Zhongtian Liu and China Zhongwang Holdings Ltd. — operated a network of aluminum importation, warehousing, and distribution designed to evade AD/CVD orders on aluminum extrusions from China.
The scheme involved:
- Importing Chinese aluminum extrusions
- Declaring them as finished merchandise exempt from AD/CVD orders
- Distributing through affiliated warehouse companies to obscure the supply chain
- False statements on customs entry forms regarding the nature and classification of the merchandise
The criminal conviction came first, years ago. The $549.5 million civil settlement under the False Claims Act came in May 2026. Combined with the criminal penalties, forfeitures, and restitution, this single case represents a substantial portion of the Task Force's billion-dollar milestone.
Executive Order 14411: The Policy Foundation
Underpinning all of this enforcement activity is Executive Order 14411, "Strengthening Customs Enforcement," signed June 3, 2026. The EO directs CBP to enhance its enforcement posture and provides the policy basis for the expanded interagency cooperation that produced the TFTF's results.
The White House also released "The Great Transshipment Scam" — an August 2026 report specifically calling out the use of third-country routing to avoid AD/CVD orders. The report identifies aluminum, solar components, machinery inputs, industrial parts, and household appliances as product categories where transshipment schemes are most common.
When the White House publishes a named report about your product category's evasion tactics, expect enforcement attention to follow.
What You Need to Do Right Now
1. Audit your supply chain for country-of-origin risk. If any of your suppliers are in countries commonly used as transshipment points (Vietnam, Thailand, Cambodia, Malaysia) for products subject to Chinese AD/CVD orders, verify substantial transformation with documented production records. Don't rely on certificates of origin alone.
2. Review your HTS classifications against all active AD/CVD orders. Use Commerce's ACCESS system to check whether your product's HTS subheadings appear in any active order. Remember: the written scope description is legally controlling, not the HTS codes listed for "convenience and customs purposes."
3. Run a valuation audit on your last 12 months of entries. Compare declared values against market benchmarks. If any transaction values are more than 20% below market, document the legitimate business reason. Undervaluation is one of the 16 enforcement priorities — and it's the easiest to detect algorithmically.
4. Evaluate whether voluntary self-disclosure is appropriate. If your audit reveals potential violations, consult trade counsel immediately about CBP's prior disclosure process (19 CFR § 162.74) or DOJ's voluntary self-disclosure policy. The calculus has shifted: the penalty reduction for self-disclosure is now measured against the criminal exposure of concealment.
5. Update your broker communications. Ensure your customs broker has complete, accurate information about your goods — especially country of origin, manufacturer identity, and product composition. Brokers facing their own criminal exposure will become more demanding about documentation. Get ahead of those requests.
6. Brief your downstream customers. If you distribute imported goods, your customers now face potential liability for purchasing merchandise that evaded duties. Transparency about sourcing and compliance protects the entire supply chain.
What's Coming Next
The enforcement trajectory is clear: more EAPA cases, larger FCA settlements, and expanded criminal prosecution of trade fraud. Several indicators point to where enforcement will intensify in the second half of 2026:
- More circumvention findings for solar, aluminum, and steel products routed through Southeast Asia
- Increased scrutiny of de minimis shipments under Section 321 (the $800 threshold), particularly for Chinese e-commerce platforms
- Criminal prosecution of customs brokers who facilitated evasion — the Resource Guide's explicit inclusion of broker fraud as a priority signals imminent action
- False Claims Act qui tam suits — private whistleblowers can now file FCA actions alleging customs fraud, creating a financial incentive for disgruntled employees and competitors to report suspected evasion
The GTCES is hiring. The TFTF is expanding. CBP's EAPA unit is processing cases at triple its historical rate. This is not a spike — it's a new baseline.
The Compliance Imperative
Trade fraud enforcement just crossed a threshold that won't be un-crossed. The combination of a dedicated prosecution section, a published enforcement playbook, billion-dollar recoveries, and executive-level policy support means that the compliance programs built for 2020's enforcement environment are dangerously outdated.
The good news: the Resource Guide tells you exactly what they're looking for. The 16 priorities are your audit checklist. The case studies are your cautionary tales. And tools like TariffLens can help you monitor your HTS classifications against active AD/CVD orders in real time — catching the misalignment before it becomes a $549 million problem.
The era of treating customs violations as paperwork errors is over. The government is treating them as fraud. Your compliance program should reflect that reality.
This article is for informational purposes only and does not constitute legal, tax, or customs advice. Consult a licensed customs broker or trade attorney for guidance specific to your situation.