The U.S. Department of Justice (DOJ) and the Department of Homeland Security (DHS) have sent a clear message that the era of treating customs fraud as a manageable cost of doing business is over, and there will be a significant escalation of U.S. trade fraud enforcement policy moving forward.

The message was delivered in two ways: the July 14 release of A Resource Guide to Trade Fraud Enforcement, the first comprehensive, publicly available playbook explaining how the government detects, investigates, and prosecutes trade fraud, and the announcement that the Trade Fraud Task Force (TFTF) has surpassed $1 billion in recoveries, penalties, forfeitures, and publicly charged losses in less than a year.

DOJ also established the Global Trade & Commerce Enforcement Section (GTCES) within the National Fraud Enforcement Division, which exists specifically to investigate and prosecute criminal import, trade, and related fraud offenses.

The guidance makes clear that importers, customs brokers, distributors, and downstream supply chain participants face increased civil and criminal exposure for customs violations, tariff evasion, false country-of-origin declarations, and other trade fraud schemes.

To learn more about the government’s evolving enforcement priorities and what they mean for companies with global supply chains, read the full legal alert. Please reach out to a member of Husch Blackwell’s International Trade & Supply Chain team if you have questions or need assistance.