The increasing focus on trade compliance and enforcement continues. In July 2026, the Department of Justice (DOJ) and Department of Homeland Security (DHS) released A Resource Guide to Trade Fraud Enforcement. Together with the recent Executive Order on Strengthening Customs Enforcement and the creation of a new Global Trade & Commerce Enforcement Section within DOJ, these actions signal that trade fraud enforcement is becoming a permanent, coordinated priority across the federal government.
What is the Trade Fraud Task Force?
The Trade Fraud Task Force was established in August 2025 as a joint initiative between DOJ and DHS to investigate and prosecute customs and trade fraud. The Task Force brings together DOJ’s Civil and Criminal Divisions, as well as U.S. Customs and Border Protection (CBP), and Homeland Security Investigations (HSI).
According to DOJ, the Task Force targets key revenue and enforcement priorities, including:
- Tariff evasion
- Antidumping and countervailing duty (AD/CVD) evasion
- Forced labor violations
- Criminal violations concerning imported goods that threaten public health and safety
Importantly, the Task Force’s mandate extends beyond importers of record. DOJ has stated that it covers customs brokers, distributors, downstream purchasers, end-users, and other supply chain actors that knowingly profit from merchandise imported contrary to law.
Along with the Guide, DOJ announced that the joint Trade Fraud Task Force (TFTF) had exceeded $1 billion in recoveries, penalties, forfeitures, and publicly charged losses less than a year after its creation, demonstrating the scale of the government’s commitment to treating trade fraud as “a serious economic crime.”
What is the new Trade Enforcement Guide?
The newly released Resource Guide to Trade Fraud Enforcement is a public-facing document developed by the Trade Fraud Task Force to explain the laws, enforcement authorities, and investigative approaches used in trade fraud cases.
The Guide identifies several categories of trade fraud that federal agencies consider priorities, including:
- False origin declarations and transshipment
- Duty evasion and undervaluation
- Misclassification of imported products
- Misuse of free trade agreement claims
- AD/CVD evasion
- Smuggling
- Forced labor violations
- False certifications relating to product safety and regulatory compliance
A central theme throughout the Guide is that trade fraud creates unfair competitive advantages for non-compliant businesses, deprives the government of lawful revenue, and may enable unsafe, prohibited, or forced labor-produced goods to enter U.S. commerce. The Guide also underscores the increasing coordination among CBP, HSI, DOJ, and other federal agencies in identifying and pursuing trade violations.
What are the key takeaways for the trade community?
1. Trade Fraud Enforcement Is a Long-Term Priority
The release of the Guide, the creation of DOJ’s Global Trade & Commerce Enforcement Section, and the EO on customs enforcement all indicate that trade fraud enforcement is becoming institutionalized within the federal government. Companies should view the current enforcement environment as a long-term shift rather than a temporary initiative.
2. Supply Chain Accountability Extends Beyond the Importer
One of the Guide’s most significant messages is that enforcement risk may extend across the supply chain. The government is increasingly focused on whether companies knew, or should have known, about unlawful conduct occurring upstream or downstream in their commercial relationships. Supply chain visibility, due diligence, and oversight are therefore becoming increasingly important.
3. Forced Labor Remains a Major Enforcement Focus
The Guide highlights forced labor enforcement under Section 307 and the Uyghur Forced Labor Prevention Act (UFLPA). Thus far in 2026, CBP has issued Withhold Release Order against a company in Mexico, one in Serbia, and two in Jordan, demonstrating that forced labor scrutiny is not limited to a single country or region and may affect suppliers operating under preferential trade arrangements.
4. Documentation Matters More Than Ever
Many of the enforcement actions discussed in the Guide involve questions of origin, valuation, classification, admissibility, and supplier conduct. Companies should expect greater attention to supporting documentation, certifications, records, and internal controls that substantiate customs declarations and supply chain claims.
5. Customs Compliance and Risk Management Are Becoming More Integrated
Recent customs enforcement initiatives, including the Administration’s broader customs enforcement reforms, point toward increased importer accountability, enhanced transparency requirements, and greater scrutiny of supply chain practices. Companies that integrate customs compliance, trade compliance, supplier due diligence, and risk management programs will be better positioned to respond to this evolving environment.
Final Thoughts
The DOJ-DHS Resource Guide to Trade Fraud Enforcement provides industry with greater insight into how federal agencies intend to pursue trade fraud investigations going forward. While the Guide does not create new legal obligations, it communicates the government’s enforcement priorities and expectations.
The combination of intensified customs enforcement, heightened forced labor scrutiny, expanded interagency coordination, and establishment of DOJ trade fraud infrastructure signals that supply chain transparency, due diligence, and compliance governance are quickly becoming business imperatives rather than competitive differentiators.
