The Department of Justice is rapidly expanding its role in trade enforcement, creating serious new compliance risks for multinational importers operating across global supply chains.
In May, the DOJ announced a $549.5 million settlement with aluminum importers to resolve civil False Claims Act allegations tied to the evasion of antidumping and countervailing duties on aluminum extrusions from China.
According to the DOJ, the importers falsely described imported merchandise on Customs entry documentation in order to avoid antidumping and countervailing duty liability, declaring products as finished aluminum pallets.
In reality, the government alleged that the goods were aluminum extrusions superficially modified to appear outside applicable trade remedy orders, intended to be broken apart and resold for downstream uses.
The settlement is a significant marker that customs enforcement risk no longer resides only with U.S. Customs and Border Protection, with the DOJ now positioning itself as an active enforcement player.
This enforcement posture did not emerge suddenly, as the DOJ has been building its internal architecture for trade fraud prosecution over the past year.
In August 2025, the DOJ created its Market, Government, and Consumer Fraud Unit within the Criminal Division, widely viewed as building enforcement capacity around customs fraud, misclassification, undervaluation, and transshipment schemes.
The DOJ subsequently launched a cross-agency Trade Task Force drawing personnel from both civil and criminal components as well as the Department of Homeland Security, focused specifically on customs violations.
Then in April 2026, the DOJ announced the creation of a National Fraud Enforcement Division, with analysts now reading this as a sign the department intends to pursue trade fraud through multiple channels simultaneously.
The False Claims Act’s use in this context is particularly consequential, as it enables treble damages, statutory penalties, broader investigatory tools, and significant reputational exposure for importers.
Importers should be aware that the government appears particularly focused on misclassification, undervaluation, false country-of-origin claims, transshipment and relabeling schemes, and evasion of antidumping and countervailing duty orders.
Forced labor enforcement is also becoming more closely linked to trade fraud risk, with importers responding to Uyghur Forced Labor Prevention Act scrutiny required to provide detailed certifications and supply chain tracing information to CBP.
Where those submissions are inaccurate, inconsistent, or unsupported, they may create the evidentiary record needed to support broader fraud allegations against the importing company.
Whistleblower risk is also rising, as the False Claims Act allows private parties to bring allegations on behalf of the government and share in any financial recovery from a successful case.
Companies competing against importers with suspiciously low pricing, implausible origin claims, or apparent duty avoidance now have more incentive to raise well-supported allegations with a more receptive government audience.
Importers should review tariff classification, customs valuation, country of origin, and antidumping and countervailing duty compliance controls as immediate priorities given the shifting enforcement landscape.
Entry summaries, commercial invoices, packing lists, and certifications submitted to CBP can all become the basis for fraud allegations if found to be materially inaccurate or inconsistent with commercial reality.
Internal audit findings, broker questions, employee complaints, and invoice inconsistencies should be escalated and investigated promptly rather than treated as routine operational matters in this environment.
The DOJ’s aluminum settlement is a clear signal that trade fraud enforcement is becoming more active, more coordinated, and more consequential for companies engaged in cross-border trade.