Alerts1.8.26
New Year, Renewed Enforcement: Tariffs, Trade Compliance, and DOJ Actions to Watch in 2026
Highlights
- Department of Justice (DOJ) enforcement of tariff and customs compliance is accelerating. Recent criminal charges, corporate resolutions, and False Claims Act (FCA) settlements show coordinated civil and criminal scrutiny of tariff evasion, false country of origin claims, and transshipment practices.
- Financial and personal exposure is significant. Companies face large civil penalties and settlements, while executives and employees may be subject to individual criminal liability. Whistleblower driven cases continue to play a major role in enforcement.
- Strong compliance and early action matter. Accurate origin determinations, defensible tariff classifications, and effective internal controls are essential. Voluntary self-disclosure and timely remediation can materially affect enforcement outcomes.
As we enter 2026, recent developments in U.S. trade enforcement confirm that civil and criminal enforcement of tariff, duty, and customs compliance remains a top priority for the DOJ, U.S. Customs and Border Protection and other agencies. Companies engaged in importing, sourcing and supply chain activities continue to face meaningful risk of enforcement action when tariff and duty obligations are not met.
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