DOJ and DHS Launch Cross-Agency Trade Fraud Task Force

1. Announcement

On August 29, 2025, the U.S. Department of Justice (“DOJ”) announced the formation of a cross-agency Trade Fraud Task Force (the “Task Force”) to enhance enforcement against importers and other entities that engage in trade fraud. The Task Force will coordinate efforts across DOJ’s Civil and Criminal Divisions and partner with U.S. Customs and Border Protection (“CBP”) and Homeland Security Investigations (“HSI”) within the Department of Homeland Security.

Consistent with the Trump Administration’s America First Trade Policy, as well as Executive Order 14243, which aims to “enhance the Government’s ability to detect overpayments and fraud,” the Task Force will work closely with law enforcement to identify and combat trade fraud that threatens U.S. economic and national security interests. DOJ stated in its press release that these enhanced cooperative efforts will result in “a more efficient government for taxpayers and improved enforcement and deterrent outcomes.”

2. Enforcement Priorities Consistent with America First Trade Policy

The Task Force reflects the administration’s broader commitment to protecting American industries and workers through the enforcement of U.S. trade laws. In its press release, DOJ emphasized that violators of trade laws “have harmed American manufacturers and contributed to the loss of American jobs, often with financial backing from America’s adversaries who benefit from the fraud.” The Task Force will accordingly prioritize actions against tariff evasion and the importation of prohibited goods that violate intellectual property rights.

The Task Force will utilize a range of enforcement tools, including duty and penalty collection under the Tariff Act of 1930, civil actions under the False Claims Act (“FCA”), and “where appropriate,” criminal prosecutions under Title 18’s trade fraud and conspiracy provisions.

3. Engagement with Domestic Industries

Assistant Director Ivan Arvelo of HSI’s Global Trade Division stated the enhanced efforts between agencies will “add immense value to the task force and yield positive results in support of domestic industry and businesses engaging in legal international commerce.”

DOJ noted that the Task Force encourages referrals and cooperation from domestic industries most affected by unfair trade practices and fraud. Referrals can be submitted to the DOJ Criminal Division’s Corporate Whistleblower Program; whistleblowers may also utilize the qui tam provisions of the FCA to report credible allegations of fraud. Additionally, importers and their agents are encouraged by DOJ to audit their practices and voluntarily disclose and remediate unlawful conduct.

If Blank Rome can help you navigate the trade enforcement landscape and what it means for the operation of your company, please reach out to Anthony Rapa, Jennifer A. Short, Bradley L. Henry, Layla S. Najjar, or another member of Blank Rome’s Trade Enforcement Team.