The first quarter of 2026 ended without news of new lawsuits or settlements for reverse false claim acts. However, this does not mean importers should become complacent in their management of tariff payments. At the end of August 2025, the Department of Justice (DOJ) created a Trade Fraud Task Force, citing Executive Order 14243, aimed at enhancing the Government's ability to detect overpayments and fraud.

In January, the DOJ announced that settlements and judgments under the False Claims Act (FCA) exceeded $6.8 billion—the highest in a single year—in the federal fiscal year ending September 30, 2025. In the same press release, the DOJ also noted that whistleblowers filed 1,297 qui tam lawsuits during the same period, which is also the highest number on record.

While DOJ enforcement activity is down significantly in 2026, the timing of the Trade Fraud Task Force is notable, as it came in the last month of a fiscal year that posted record qui tam filings and record monetary recoveries. This will serve to embolden qui tam filers, who are increasingly utilizing artificial intelligence (AI) tools to mine data, without corporate insider information, in search of FCA actions.

Companies involved in importing goods should assume that data-driven enforcement and whistleblower activity will continue to grow.

Potential Risk Scenarios

Companies should consider proactive steps in several common situations:

• If internal compliance reviews reveal discrepancies in tariff classifications,...

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