Four recent False Claim Act (FCA) cases arising out of customs fraud allegations illustrate the announced enforcement priorities of the Department of Justice (DOJ), including prosecuting trade and customs fraud and tariff evasion under a variety of laws. The U.S. government capped this recent run of trade fraud enforcement proceedings with the announcement of a DOJ and Department of Homeland Security (DHS) trade fraud task force.
On August 19, July 23, and July 24, 2025, the DOJ announced the resolution of three FCA cases that highlight its focus on “[t]rade and customs fraud.” Additionally, on July 15, 2025, the DOJ intervened in an FCA case in South Carolina arising out of allegedly falsified valuations of imported goods to evade tariffs. In connection with one of the settlements, Assistant Attorney General Brett A. Shumate observed, “The Department will pursue those who gain an unfair trade advantage in U.S. markets, including those who knowingly evade or underpay duties owed on foreign imports.”
On August 29, 2025, the DOJ announced a DOJ-DHS task force focused on “identify[ing] and combat[ting] trade fraud that threatens [U.S.] economic and national security interests.” In the announcement, Deputy Assistant Attorney General Brenna Jenny highlighted the recent enforcement cases. “Since March of this year, the Commercial Litigation Branch has reached civil settlements to resolve allegations of improperly evaded customs duties across a wide range of products…. We look...
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