Cooley·INTERNATIONAL TRADE / TARIFFS

White House launches AI-driven crackdown on trade fraud transshipment

DOJ's National Fraud Enforcement Division names global trade and customs evasion a top priority alongside an AI-enabled CBP enforcement platform targeting China-linked transshipment.

On August 13, 2026, the White House Office of Trade and Manufacturing Policy released 'The Great Transshipment Scam,' estimating $10 billion to $100+ billion in annual tariff revenue losses from goods routed through Vietnam, Malaysia, Thailand, Mexico, and Cambodia to evade Section 301 tariffs. The same day, DOJ's National Fraud Enforcement Division issued a memorandum identifying global trade and commerce as a primary enforcement focus, covering illicit transshipment, country-of-origin fraud, undervaluation, sanctions evasion, and foreign forced labor schemes. CBP is building an AI 'detective border' that fuses anomaly detection, link analysis, capacity validation, and physical-to-digital verification to flag suspicious routing, bills of lading, origin claims, and container imaging. NFED plans to reach roughly 500 attorneys and staff by late August and continue expanding for two years, deploying sophisticated data analytics. The memo signals that civil customs exposure can escalate to criminal prosecution, with potential coordination across CBP, DOJ, and Commerce. Sophisticated counsel should advise import-intensive clients to audit supply chains, stress-test origin documentation, tighten compliance and voluntary self-disclosure protocols, and pre-stage rapid response procedures for CBP information requests, DOJ subpoenas, Civil Investigative Demands, and detention or seizure notices.

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Read the original firm alert → Friday, September 4, 2026

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