Highlights

• The $549.5 million Perfectus Aluminum settlement is more than ten times larger than the previous record for a customs-related False Claims Act (FCA) resolution and the latest in a string of major cases involving Chinese imports.
• The U.S. Department of Justice (DOJ)'s new Corporate Enforcement Policy creates a 120-day clock. Once a whistleblower reports internally, the company has 120 days to self-disclose or lose eligibility for a presumptive declination of prosecution.
• A single customs fraud scheme can simultaneously trigger criminal prosecution, civil FCA treble damages, Tariff Act penalties, and Customs and Border Protection (CBP) administrative enforcement — all coordinated through the Trade Fraud Task Force.

On May 12, 2026, the DOJ announced that Perfectus Aluminum Inc. and affiliated companies agreed to pay $549.5 million to resolve False Claims Act (FCA) allegations arising from a scheme to evade customs duties on aluminum imports from China. This settlement (more than ten times larger than the previous customs-related FCA record) signals that DOJ is now deploying the FCA’s treble-damages framework as a primary weapon against tariff evasion. For companies that import goods subject to anti-dumping and countervailing duties (AD/CVD), Section 301 tariffs, or other special tariffs, the Perfectus resolution is a clear call to action.

The Perfectus Aluminum Scheme

The Perfectus case arose from a scheme to evade antidumping and countervailing duties owed on...

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