U.S. Department of Justice Announces Creation of Global Trade & Commerce Enforcement Section and Stricter Civil and Criminal Trade Law Enforcement
In less than one year of operation, the Trade Fraud Task Force (TFTF)- a joint initiative launched in August 2025 by the Department of Justice (DOJ) and the Department of Homeland Security (DHS)- has officially crossed the $1 billion threshold in recoveries, penalties, forfeitures, and charged losses. This landmark milestone reflects a fundamental and permanent shift in federal customs enforcement. The era of treating trade non-compliance as a simple administrative hurdle or an acceptable cost of doing business is over. Federal authorities are actively deploying the full weight of criminal prosecutions and civil False Claims Act (FCA) litigation to hold international supply chain participants strictly accountable.
The geographic reach of this enforcement initiative is broad and aggressive. Under federal law, trade fraud offenses can be prosecuted in any judicial district through which imported goods travel or where the downstream financial impact is felt. Consequently, port-of-entry checks are merely the starting point for federal investigations. Recent enforcement actions highlight the task force’s extensive focus, including a $549.5 million False Claims Act settlement regarding aluminum extrusion duties in California, multi-million dollar penalties for Lacey Act timber violations in Florida, and criminal fines in New Jersey tied to hazardous, non-compliant consumer appliances. Additionally, federal prosecutors in Chicago recently unsealed major indictments involving hundreds of millions of dollars in imported gold jewelry from foreign markets that were improperly declared under false origins to evade baseline customs duties.
To institutionalize these efforts for the long term, the Justice Department has formally announced the establishment of a brand-new permanent unit: the Global Trade & Commerce Enforcement Section (GTCES). Housed within the National Fraud Enforcement Division, the GTCES is designed to investigate and prosecute criminal trade offenses across the entire commercial chain. The section’s prosecutorial priorities specifically target Section 301 tariff evasion, anti-dumping and countervailing duty avoidance, supply chain forced labor violations, falsified country-of-origin declarations, and product entries that endanger public health and safety. Furthermore, its authority extends beyond nominal Importers of Record to encompass customs brokers, foreign manufacturers, freight forwarders, and downstream domestic distributors who knowingly facilitate or benefit from unlawful importations.
Alongside the formalization of the GTCES, federal regulators have jointly released “A Resource Guide to Trade Fraud Enforcement.” This comprehensive roadmap outlines civil and criminal enforcement frameworks, detailing how statutory requirements will be applied to commercial cross-border operations. For businesses operating in international trade, maintaining proactive compliance programs, thoroughly auditing supplier chains, and strictly verifying classification and origin declarations are now vital necessities. Importers and supply chain actors are strongly urged to review their compliance procedures immediately to identify potential exposure under these expanded federal enforcement standards.
In the face of this aggressive enforcement push, non-compliant importers and supply chain actors risk immediate administrative and judicial action, including severe CBP commercial penalties, complete asset forfeitures, federal debarment, multi-million-dollar False Claims Act lawsuits, and grand jury criminal indictments carrying up to 20 years of imprisonment. If your business is navigating a customs audit, receives a CBP Form 28 (Request for Information) or Form 29 (Notice of Action), or faces an active DOJ inquiry, proactive legal representation is vital. Contact our customs and international trade law team today to defend your business against federal enforcement actions.