Key Takeaways
- • The Trade Fraud Task Force surpassed $1 billion in civil and criminal recoveries, penalties, forfeitures, and publicly charged losses in less than one year, signaling an institutionalized enforcement priority that extends across 35 U.S. Attorneys' Offices and multiple federal agencies.
- • The Department of Justice established the Global Trade & Commerce Enforcement Section (GTCES) within the National Fraud Enforcement Division, creating a permanent, dedicated unit that institutionalizes customs and trade fraud enforcement beyond short-term policy cycles and coordinates investigations spanning revenue evasion, consumer safety, national security, forced labor, and unfair trade practices.
- • False Claims Act whistleblower actions account for approximately $640 million of the $1 billion recovered, representing the dominant enforcement mechanism and demonstrating DOJ's capacity to pursue conduct across global supply chains from foreign suppliers through importers, brokers, and domestic end-users.
- • Two new criminal cases in the Northern District of Illinois charged country-of-origin fraud involving gold jewelry importers—Raj Kohli and Veena Kohli facing $38 million in evaded duties, and Narain Gulabani facing $13.6 million—highlighting CBP's intensified focus on tariff classification accuracy and duty evasion.
- • U.S. Customs and Border Protection assessed $2.1 billion in commercial trade penalties and debarred 35 entities in Fiscal Year 2026, while DOJ and DHS released a first-of-its-kind joint Resource Guide to Trade Fraud Enforcement designed to provide private sector actors transparent guidance on enforcement priorities and compliance obligations.
Summary
On July 14, 2026, the Trade Fraud Task Force announced that it had generated more than $1 billion in civil and criminal recoveries, penalties, forfeitures, and charged losses in less than one year of operation. The milestone announcement accompanied two significant developments: the Department of Justice's creation of the Global Trade & Commerce Enforcement Section (GTCES) within the National Fraud Enforcement Division, and the joint release by DOJ and the Department of Homeland Security of a comprehensive Resource Guide to Trade Fraud Enforcement. The announcement follows President Trump's June 3 Executive Order on Strengthening Customs Enforcement and reflects an institutionalized federal commitment to trade enforcement spanning multiple regulatory domains.
The establishment of the GTCES represents a structural shift in enforcement infrastructure. Unlike task forces that serve as coordinating mechanisms, a dedicated litigating section within DOJ's National Fraud Enforcement Division signals that trade fraud enforcement is now a permanent organizational priority with dedicated resources and specialized expertise. The GTCES's stated mission encompasses investigation and prosecution of criminal customs fraud, trade offenses undermining American competitiveness, external revenue evasion, consumer safety threats, national security risks, forced labor facilitation, and unfair trade practices including antidumping and countervailing duty fraud. This breadth indicates that companies facing trade enforcement scrutiny should anticipate collateral inquiries across multiple regulatory regimes—including those administered by the FDA, Department of Commerce, IRS, EPA, and Consumer Product Safety Commission—rather than narrow customs-duty matters. The task force now involves 35 U.S. Attorneys' Offices, with the Northern District of Illinois designated as its lead prosecutorial partner.
False Claims Act enforcement has driven the majority of the $1 billion recovery, with approximately $640 million recovered through FCA whistleblower actions according to DOJ press releases. These recoveries reflect the statute's capacity to reach conduct across supply chains involving foreign suppliers, importers, brokers, and domestic commercial end-users. Recent settlements have included Perfectus Aluminum ($549.5 million, May 2026), Ceratizit USA ($54.4 million, December 2025), and Harman ($11.8 million, November 2025). Two new criminal cases announced alongside the milestone announcement charged gold jewelry importers with country-of-origin fraud. Raj Kohli and Veena Kohli, operators of a California-based importer and wholesaler, were charged with evading more than $38 million in customs duties between August 2020 and May 2024 by falsely representing that gold jewelry originated in Singapore when it actually originated from India and the United Arab Emirates. Narain Gulabani, a jewelry importer and wholesaler in Illinois, was separately charged with evading approximately $13.6 million in duties between May 2016 and October 2021 by falsely declaring origins as Oman or Singapore.
The Resource Guide released jointly by DOJ and DHS provides the private sector with what DOJ characterized as the first comprehensive joint framework on trade fraud enforcement. The Guide emphasizes that enforcement stakes "extend well beyond the ledger of a single company" to include protection of border integrity, national security, and economic stability. The Guide covers the customs entry process, legal obligations of parties involved, and common forms of trade fraud including false country-of-origin declarations, false tariff classification, undervaluation, and forced labor violations under Section 307 of the Tariff Act of 1930 and the Uyghur Forced Labor Prevention Act. The Guide does not modify voluntary self-disclosure policy, indicating DOJ will not issue component-specific disclosure policies during this administration; the DOJ-wide Corporate Enforcement Policy remains the operative framework, though statutory prior-disclosure rights under Section 592 of the Tariff Act remain available and CBP continues to encourage timely prior disclosure to mitigate criminal investigation risk.
Parallel to DOJ's enforcement activities, U.S. Customs and Border Protection has escalated administrative enforcement, assessing more than $2.1 billion in commercial trade penalties in Fiscal Year 2026 and debarring 35 entities from conducting business with the federal government. These administrative actions complement DOJ's criminal and civil enforcement tools, creating a comprehensive enforcement environment that targets country-of-origin accuracy, tariff classification, valuation compliance, and duty payment verification across importers nationwide.
The establishment of the GTCES represents a structural shift in enforcement infrastructure. Unlike task forces that serve as coordinating mechanisms, a dedicated litigating section within DOJ's National Fraud Enforcement Division signals that trade fraud enforcement is now a permanent organizational priority with dedicated resources and specialized expertise. The GTCES's stated mission encompasses investigation and prosecution of criminal customs fraud, trade offenses undermining American competitiveness, external revenue evasion, consumer safety threats, national security risks, forced labor facilitation, and unfair trade practices including antidumping and countervailing duty fraud. This breadth indicates that companies facing trade enforcement scrutiny should anticipate collateral inquiries across multiple regulatory regimes—including those administered by the FDA, Department of Commerce, IRS, EPA, and Consumer Product Safety Commission—rather than narrow customs-duty matters. The task force now involves 35 U.S. Attorneys' Offices, with the Northern District of Illinois designated as its lead prosecutorial partner.
False Claims Act enforcement has driven the majority of the $1 billion recovery, with approximately $640 million recovered through FCA whistleblower actions according to DOJ press releases. These recoveries reflect the statute's capacity to reach conduct across supply chains involving foreign suppliers, importers, brokers, and domestic commercial end-users. Recent settlements have included Perfectus Aluminum ($549.5 million, May 2026), Ceratizit USA ($54.4 million, December 2025), and Harman ($11.8 million, November 2025). Two new criminal cases announced alongside the milestone announcement charged gold jewelry importers with country-of-origin fraud. Raj Kohli and Veena Kohli, operators of a California-based importer and wholesaler, were charged with evading more than $38 million in customs duties between August 2020 and May 2024 by falsely representing that gold jewelry originated in Singapore when it actually originated from India and the United Arab Emirates. Narain Gulabani, a jewelry importer and wholesaler in Illinois, was separately charged with evading approximately $13.6 million in duties between May 2016 and October 2021 by falsely declaring origins as Oman or Singapore.
The Resource Guide released jointly by DOJ and DHS provides the private sector with what DOJ characterized as the first comprehensive joint framework on trade fraud enforcement. The Guide emphasizes that enforcement stakes "extend well beyond the ledger of a single company" to include protection of border integrity, national security, and economic stability. The Guide covers the customs entry process, legal obligations of parties involved, and common forms of trade fraud including false country-of-origin declarations, false tariff classification, undervaluation, and forced labor violations under Section 307 of the Tariff Act of 1930 and the Uyghur Forced Labor Prevention Act. The Guide does not modify voluntary self-disclosure policy, indicating DOJ will not issue component-specific disclosure policies during this administration; the DOJ-wide Corporate Enforcement Policy remains the operative framework, though statutory prior-disclosure rights under Section 592 of the Tariff Act remain available and CBP continues to encourage timely prior disclosure to mitigate criminal investigation risk.
Parallel to DOJ's enforcement activities, U.S. Customs and Border Protection has escalated administrative enforcement, assessing more than $2.1 billion in commercial trade penalties in Fiscal Year 2026 and debarring 35 entities from conducting business with the federal government. These administrative actions complement DOJ's criminal and civil enforcement tools, creating a comprehensive enforcement environment that targets country-of-origin accuracy, tariff classification, valuation compliance, and duty payment verification across importers nationwide.
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