DOJ’s New FCA Settlements Underscore Trump Administration’s Focus on Tariff and Customs Compliance

Two recent settlements involving imports from the People’s Republic of China (“PRC”) illustrate the U.S. Department of Justice’s (“DOJ”) commitment to rapidly stepping up enforcement against tariff evasion and customs fraud through the False Claims Act (“FCA”). As we covered here, tariffs have been central to the administration’s trade strategy, and DOJ’s growing use of the FCA as an enforcement tool in this space is expected to drive a significant rise in both whistleblower allegations and recoveries.

On July 23, 2025, DOJ announced a $6.8 million FCA settlement with two subsidiaries of a multinational manufacturer operating in the plastics and industrial packaging sector. In 2024, the companies voluntarily disclosed to the government that they had failed to accurately report the country of origin and value of resin imports from the PRC, resulting in the underpayment of customs duties. DOJ credited the companies’ cooperation, independent internal investigation, and remedial compliance measures, but emphasized that voluntary disclosure does not shield companies from financial consequences when customs violations occur. The resolution, reached within roughly a year of the disclosure, reflects DOJ’s increasing speed in pursuing and resolving such matters.

One day later, DOJ announced a $4.9 million FCA settlement with a U.S. furniture company for evading antidumping and countervailing duties (“AD/CVD”). Antidumping duties are intended to prevent foreign companies from selling goods in the U.S. at unfairly low prices, and countervailing duties are imposed to offset the impact of subsidies provided by foreign governments. The settlement resolved a former employee’s allegations that the company misrepresented the duty status of aluminum components imported from the PRC and knowingly failed to correct the customs forms it had previously submitted. The FCA incentivizes whistleblowers (and relators’ counsel) to file these lawsuits by allowing them to share in the recovery; in this settlement, the former employee who made the allegations received almost $1 million.

These back-to-back settlements reinforce DOJ’s high prioritization of customs enforcement, which has been emphasized by leaders of DOJ’s Civil and Criminal Divisions. Companies across sectors such as manufacturing, healthcare, retail, energy, and electronics may face heightened exposure. Accordingly, companies should evaluate their trade and customs practices and ensure that their compliance programs are equipped to manage the heightened enforcement risks. Relatedly, companies should ensure they offer adequate internal reporting mechanisms. In addition to the incentives in the FCA, DOJ recently expanded its Criminal Division’s Corporate Whistleblower Awards Pilot Program to solicit tips on trade fraud and tariff evasion, including tips that may duplicate FCA claims. As a result, whistleblowers now have multiple avenues for reporting potential violations.

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