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ARTICLE · 06 AUGUST 2025

DOJ Identifies Tariff Fraud As Enforcement Priority

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The Trump administration's announcement of a panoply of steep tariffs on April 2, 2025, and the associated tariff negotiations that followed, has been met with extensive media coverage and analysis.

United StatesCriminal Law

The Trump administration's announcement of a panoply of steep tariffs on April 2, 2025, and the associated tariff negotiations that followed, has been met with extensive media coverage and analysis. To emphasize the seriousness of the new tariff regime, the Department of Justice ("DOJ") — in its May 12 Memorandum on White Collar Crime1 — announced that it will prioritize for investigation and prosecution cases involving "trade and customs fraud, including tariff evasion." Nonetheless, schemes to evade the tariffs have been on the rise. These illegal practices have included:

  • Underreporting the value of imported goods to U.S. Customs and Border Protection ("CBP") to pay a reduced tariff. This scheme may involve selling the imported goods to a related entity at an artificially low price. The difference in price between the actual value and the value reported to CBP is made up out of the government regulator's sight.

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