DOJ Formalizes Its Global Trade Fraud Enforcement Strategy

On July 14, 2026, the U.S. Department of Justice (DOJ) issued a press release announcing the creation of the new, permanent Global Trade & Commerce Enforcement Section (GTCES) within its National Fraud Enforcement Division (NFED). Alongside the creation of the GTCES, the Trade Fraud Task Force — a joint initiative between the DOJ and the U.S. Department of Homeland Security (DHS) — released “A Resource Guide to Trade Fraud Enforcement” (the “Guide”) to provide insight into DOJ and DHS enforcement priorities and tools. Since announcing its focus on fraud in January 2026, DOJ enforcement has resulted in $1 billion “in civil and criminal recoveries, penalties, forfeitures, and publicly charged losses.” The GTCES and the Guide are the latest developments in the DOJ’s evolving fraud enforcement strategies.

The GTCES

Working within the NFED, the GTCES is a permanent and specialized section tasked with “investigat[ing] and prosecut[ing] criminal import, trade, and [related] fraud offenses,” targeting conduct that undermines US “industries, evade[s] external revenue collection, threaten[s] consumers’ health and safety, finance[s] foreign adversaries, [and] promote[s] forced labor.”

The Guide

The DOJ describes the Guide as “the first joint comprehensive framework of its kind.” It outlines the civil, criminal, and administrative authorities the federal government can use to investigate and prosecute customs and trade fraud, including the False Claims Act (FCA). The Guide emphasizes the importance of corporate oversight and controls, directing companies to actively audit supply chains, verify partner representations, and build a culture of compliance. In addition, the DOJ continues to encourage companies that identify potential violations to consider the benefits of voluntary disclosure, cooperation, and remediation under its Corporate Enforcement and Voluntary Self-Disclosure Policy (as detailed in our March 16, 2026, alert, “DOJ Expands Corporate Enforcement and Voluntary Self-Disclosure Policy Nationwide”).

Underscored throughout the Guide is the significance of the FCA, including its “reverse false claim” provision, as a mechanism to pursue customs fraud, tariff evasion, duty underpayment, and other conduct that knowingly conceals, avoids, or decreases an obligation to pay money to the government. Notably, “the FCA imposes treble damages” and civil penalties and increased enforcement risk through qui tam actions.

Key Takeaways

The GTCES and the Guide highlight the DOJ’s ongoing commitment to fraud enforcement. Companies should continue to consider the department’s priorities, especially those outlined in the Guide, and develop internal compliance policies to prevent, detect, and remedy any issues as they arise.

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The Goodwin Healthcare team will continue to monitor government enforcement developments, such as those previously described, and their potential implications. For more information on the issues discussed in this alert, please contact the authors, reach out to Goodwin’s Government Investigations, Enforcement & White Collar Defense or False Claims Act teams, or contact the Goodwin lawyer with whom you typically consult.

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