The Trump Administration intends to leave a strong enforcement mark on fraud and trade enforcement.  DOJ is linking together trade enforcement and False Claims Act cases in an unprecedented manner that will open up new opportunities and risks for companies involved in international trade.  DOJ’s intent is clear and companies should be aware of this growing risk area.

In May 2025, DOJ designated “trade and customs fraud, including tariff evasion” as one of the top ten national priorities.  To implement this directive, it is critical to “follow the resources” (like “follow the bouncing ball” for us older folks) to evaluate DOJ’s commitment. 

DOJ has reallocated staff from DOJ’s Fraud Section and Consumer Protection Branch to prioritize investigations of import misclassification, undervaluation or misrepresenting the origin to evade duties.