Entries by Ted Murphy

24 07 '26

DOJ Expands Trade Fraud Enforcement After $1 Billion Milestone

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The U.S. Department of Justice and the Department of Homeland Security announced on July 14, 2026, that the Trade Fraud Task Force had surpassed $1 billion in criminal and civil recoveries, penalties, forfeitures, and publicly charged losses less than one year after its launch. The announcement confirms a fundamental shift in the federal government’s approach to customs and trade enforcement, reflecting increased emphasis on rigorous criminal prosecution and civil enforcement under the False Claims Act.

09 06 '26

President Trump Issues Executive Order to Enhance Customs Enforcement

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President Trump’s June 3, 2026 Executive Order on customs enforcement signals a significant expansion of the Administration’s America First Trade Policy beyond tariffs and trade remedies. The order directs the Department of Homeland Security and U.S. Customs and Border Protection (CBP) to undertake a broad range of reforms aimed at strengthening customs enforcement, including heightened importer vetting, increased bond requirements, expanded supply-chain disclosure obligations, and stricter penalties for noncompliance. The order also focuses on nonresident importers of record, imposing new restrictions that could affect foreign companies that have long relied on established import structures and procedures to access the U.S. market. Because many of the contemplated changes can be implemented through CBP rulemaking and guidance rather than legislation, importers should expect significant regulatory developments over the coming months. Companies that import goods into the United States should begin assessing the potential impact on their customs compliance programs, supply chains, and import operations.

18 05 '26

Tariff Enforcement at the Forefront: Importer Agrees to Pay $549.5 million in Largest-Ever Trade-Related False Claims Act Settlement

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On May 12, 2026, the Department of Justice (“DOJ”) announced a $549.5 million settlement with Perfectus Aluminum Acquisitions LLC and four affiliated companies to resolve allegations that they violated the False Claims Act (“FCA”) by evading customs duties. This settlement is the largest trade-related settlement under the FCA.

The action was initiated by qui tam cases brought by individuals who worked for U.S.-based competitors and the Aluminum Extrusion Counsel and ultimately coordinated through the DOJ’s Trade Fraud Task Force, which involved cooperation between DOJ and the Department of Homeland Security. This case highlights the increasing use of the FCA to hold importers liable for the underpayment of customs duties, the Administration’s commitment to enforcing U.S. customs laws, and the potential for competitors and former employees to harness the FCA to motivate federal investigations into allegations of trade fraud.

This post examines the settlement and discusses its implications for importers, manufacturers, and other companies facing customs and trade enforcement risk.