On July 14, 2026, the U.S. Department of Justice announced the creation of a new Global Trade & Commerce Enforcement Section (GTCES) within its National Fraud Enforcement Division, alongside news that its Trade Fraud Task Force (TFTF) has surpassed $1 billion in civil and criminal recoveries, penalties, forfeitures, and publicly charged losses in less than a year.
DOJ and the Department of Homeland Security also jointly released a first-of-its-kind Resource Guide to Trade Fraud Enforcement. Together, these announcements provide a clear signal that customs and trade fraud will remain a sustained federal enforcement priority.
Background: An Escalating Focus on Trade Fraud
DOJ named trade and customs fraud, including tariff evasion, as a top enforcement priority in its May 2025 White Collar Enforcement Plan. That was followed by a July 2025 reorganization creating a dedicated Market, Government, and Consumer Fraud Unit and the August 2025 launch of the Trade Fraud Task Force as a joint DOJ-DHS initiative.
The July 2026 developments build directly on that foundation, adding dedicated resources and coordination to federal trade enforcement efforts.
What GTCES Does
The new Global Trade & Commerce Enforcement Section will serve as a specialized litigating component responsible for investigating and prosecuting criminal customs fraud, evasion of external revenue, international supply-chain forced labor offenses, and related trade crimes.
This includes enforcement involving Section 301 duties, Section 232 duties, Section 201 safeguards, and antidumping and countervailing duty orders.
GTCES trial attorneys are directed to lead transnational investigations nationwide, and the section will act as DOJ’s central coordinator for interagency trade enforcement.
Importantly, enforcement exposure is not necessarily limited to the importer of record. DOJ’s guidance identifies circumstances in which customs brokers, downstream distributors, commercial end users, and other parties involved in the supply chain may face civil or criminal scrutiny based on their conduct and knowledge.
Potential criminal statutes include 18 U.S.C. § 545, which addresses smuggling goods into the United States and can carry significant criminal penalties and forfeiture.
Key Takeaways from the Resource Guide
• DOJ has identified a broad range of trade fraud schemes. These include manifest fraud, false country-of-origin declarations, false tariff classification, undervaluation, AD/CVD evasion, shell company and customs broker fraud, drawback fraud, free trade agreement fraud, and port shopping.
• Forced labor enforcement is expanding. The forced labor high-priority sector list has grown from four to 12 categories, adding aluminum, PVC, seafood, steel, copper, lithium, caustic soda, and jujubes to apparel, cotton, silica-based products and polysilicon, and tomatoes.
• Knowledge and intent matter. DOJ may examine whether compliance failures stem from negligence, gross negligence, willful blindness, or intentional conduct. Companies should not assume that a lack of direct knowledge will eliminate risk where warning signs are present.
• Voluntary disclosure remains an option. Voluntary self-disclosure, cooperation, and remediation under DOJ’s Corporate Enforcement Policy may help reduce potential exposure in appropriate circumstances.
What Importers Should Do
• Review classification, valuation, and country-of-origin practices. Pay particular attention to products where significant duty rates may create greater enforcement risk around misclassification, undervaluation, or transshipment.
• Strengthen supply-chain due diligence. Review the practices of brokers, suppliers, distributors, and other parties involved in transactions, particularly where there are potential red flags involving origin, valuation, or admissibility.
• Watch sourcing exposure in newly prioritized forced labor sectors. Companies working with aluminum, copper, steel, PVC, seafood, lithium, caustic soda, and jujubes should pay close attention to supply-chain documentation and sourcing practices.
• Consider potential disclosure obligations early. Companies that identify possible violations should evaluate their options with appropriate legal and trade compliance counsel, particularly given the growing role of whistleblower reporting and False Claims Act enforcement.
These developments also pair directly with CBP’s August 6 rollout of the OFO Strategy 2026-2030, which similarly emphasizes economic security and stronger trade enforcement at U.S. ports of entry.
Read together, the DOJ and CBP initiatives point toward a more coordinated enforcement environment spanning both the port of entry and federal investigations and prosecutions.
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ASK Alba™ — Alba’s trade compliance team is here to help you review classification, valuation, and country-of-origin practices before an inquiry starts.
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