Trade Among Priorities of New DOJ Fraud Enforcement Division

Recent developments within the Department of Justice further highlight a strengthening, and increasingly institutionalized, federal focus on trade and customs enforcement efforts.

In early 2025 the DOJ announced that its Criminal Division’s enforcement priorities for prosecuting corporate and white-collar crimes would include “trade and customs fraudsters, including those who commit tariff evasion.” The DOJ subsequently put teeth into that effort by launching a revitalized interagency Trade Fraud Task Force with “a nationwide mandate to investigate and prosecute trade fraud and related cases.”

The DOJ then announced in April 2026 (and formally established as of Aug. 24) the National Fraud Enforcement Division, which will consolidate and prioritize efforts to prosecute fraud involving public trust and financial integrity, health care, internal revenue, global trade and commerce, and corporate misconduct. An Aug. 13 DOJ memo said this division would have about 500 attorneys as of Aug. 24 and “will continue to rapidly grow for the next two years.”

With respect to trade, the memo said the Fraud Division “will lead the Department’s coordinated criminal enforcement strategy, targeting trade and customs violations and supply chains polluted by forced labor.” Prosecutors will focus on “systemic, high-impact noncompliance that threatens our economic and national security,” including by “prioritizing the investigation and prosecution of illicit transshipment schemes (click here for STR’s analysis of a related White House report), country-of-origin fraud, the undervaluation of imported goods designed to evade duties, sanctions evasion, and foreign forced labor schemes.”

This work is expected to be conducted through the Global Trade and Commerce Enforcement Section within the Fraud Division. The DOJ previously said the mission of the GTCES is to investigate and prosecute criminal import, trade, and other fraud offenses that undermine U.S. industries, evade external revenue collection, threaten consumers’ health and safety, finance foreign adversaries, promote forced labor through illegal trade practices, and violate U.S. laws and regulations governing domestic and foreign commerce.

What Importers Should Do

Taken together, these efforts indicate that importers should expect more – and more in-depth and sophisticated – federal investigations of trade and customs fraud. Importers are therefore well-advised to ensure they have strong compliance measures in place to withstand this increased scrutiny and avoid the financial and reputational costs that violations and resulting penalties could incur.

As part of their efforts importers should consult “A Resource Guide to Trade Fraud Enforcement,” issued by the DOJ and the Department of Homeland Security, which addresses topics such as who and what is covered by customs regulations and laws against trade fraud as well as the different types of civil and criminal resolutions available in trade fraud enforcement. STR’s analysis of the contents and impact of this guide can be found here.

For more information on how increased federal scrutiny may affect your business and how STR can assist with your compliance efforts, please contact messages@strtrade.com or your STR professional.