DOJ-DHS Trade Fraud Guide Elevates Enforcement Risks for Importers
Importers and customs brokers must immediately evaluate their compliance programs against the new DOJ-DHS trade fraud enforcement guide, which signals a sustained priority on supply-chain and tariff-related fraud.
The Department of Justice and Department of Homeland Security have released a joint enforcement guide that elevates trade fraud—particularly misclassification, undervaluation, and origin fraud—as a sustained priority. The guide effectively applies False Claims Act standards to import-related conduct, meaning that supply-chain diligence must be documented with the underlying analysis, not just conclusions. Importers and brokers should test their existing compliance frameworks against this guidance, strengthen internal reporting channels, and assess disclosure decisions early to mitigate exposure to government investigations and civil penalties.