DOJ Targets Trade Fraud: Importers Now on Notice as Criminal Division Ramps Up Enforcement | Customs & International Trade Law Blog

On Could 12, 2025, Matthew Galeotti, the Head of the U.S. Division of Justice’s Legal Division, despatched a memo to all felony division personnel highlighting the main focus areas of the division for white-collar crime.

The memo included a listing of “high-impact areas” that the division will prioritize investigating and prosecuting. Commerce and customs fraud, together with tariff evasion, was second on the record.

The DOJ additionally revised its Company Whistleblower Awards Pilot Program and added “commerce, tariff, and customs fraud by companies” to the precedence record.

Galeotti famous that unchecked fraud in U.S. markets robs hardworking Individuals, harms the general public, and that environment friendly enforcement promotes American financial and nationwide safety pursuits.

This memo indicators a big shift within the priorities of the DOJ’s felony division. Traditionally, commerce violations weren’t a high felony precedence and have been as a substitute dealt with by CBP and the DOJ’s Civil Division. Comparatively few commerce legislation violation instances have risen to the extent of felony prosecution.

What Importers Ought to Do

Now greater than ever it’s crucial for importers to look at their import compliance packages and be certain that enough procedures are in place to accurately enter items into the US.

Put money into Compliance

CBP expects importers to make use of “affordable care” in reporting HTS, worth, nation of origin, free commerce settlement choice, and so forth. It is a subjective commonplace; nonetheless, CBP offers plentiful assets to information importers. Working with a customs lawyer, importers ought to develop strong compliance packages that decrease the chance of commerce legislation violations and reveal affordable care.  

Due Diligence

Importers ought to proactively conduct in depth due diligence of their provide chains to make sure they can detect, report, and treatment any noncompliance with customs necessities. Counting on the phrase of a provider or the due diligence of a dealer will not be sufficient.

Develop or Revisit Voluntary Prior Disclosure (PD) Insurance policies

When an importer voluntarily discloses a customs violation, they will profit considerably from decreased penalties. PD insurance policies create a transparent plan of motion if an importer discovers a violation. Well timed disclosure could make the distinction between benefiting from a mitigated penalty or not. It is usually crucial to work with a customs lawyer when submitting a PD to make sure the right info is supplied and to maximise the mitigation profit.

Diaz Commerce Regulation can help importers in creating compliance plans and information importers within the occasion of a customs investigation. Contact us at 305-456-3830 or data@diaztradelaw.com.

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