Trade Violations Reporting (TVR) Webinar
Amid escalating U.S.-China trade tensions and record $6.8 billion in fraud settlements last year, whistleblowers are increasingly exposing tariff evasion schemes that could cost companies millions in penalties.
Key takeaways
- •The formation of the Trade Fraud Task Force in 2025 has intensified coordination between DOJ and CBP, leading to more aggressive pursuits of antidumping duty evasion and forced labor violations.
- •Whistleblower-driven qui tam lawsuits under the False Claims Act surged to 1,297 in 2025, recovering billions and pressuring importers to bolster compliance amid data-driven audits.
- •The rollout of a dedicated Forced Labor Allegations Portal in mid-2025 separated reporting streams, allowing TVR to focus on other trade frauds like misclassification, with non-compliance risking cargo detentions and criminal charges.
Trade Fraud Crackdown
Trade violations reporting has gained urgency as U.S. authorities ramp up enforcement against evasion of tariffs and duties. In 2025, geopolitical strains, particularly with China, fueled expansions in trade remedies like Section 301 tariffs and the Uyghur Forced Labor Prevention Act (UFLPA). This led to a spike in investigations, with CBP issuing multiple Withhold Release Orders (WROs) on imports suspected of forced labor, such as those from Kingtom Aluminio S.R.L. and Asli Maydi.
The real-world fallout hits importers hard. Detained shipments disrupt supply chains, causing delays that can cost thousands per day in storage fees and lost sales. For instance, in 2025, CBP seized $76 million in illegal e-cigarettes in a joint operation with the FDA, illustrating how violations extend beyond textiles to electronics and consumer goods. Exporters and manufacturers in violating countries face market exclusions, while U.S. firms risk reputational damage and investor scrutiny if linked to non-compliant suppliers.
Stakes are concrete: deadlines for responding to CBP inquiries are often 30 days, with failure leading to cargo rejection or liquidation at higher duty rates. Penalties under the False Claims Act can triple damages, plus up to $23,000 per false statement, as adjusted for inflation. Inaction amplifies risks—companies ignoring red flags in audits face parallel proceedings, from administrative fines to criminal indictments, with DOJ prioritizing cases involving over $1 million in evaded duties.
Less obvious tensions simmer between enforcement zeal and trade flow. Aggressive targeting via data analytics has caught legitimate importers in crossfire, prompting complaints from industry groups about overbroad detentions. There's also a trade-off in whistleblower incentives: while qui tam provisions recover funds, they can spark frivolous claims, burdening small businesses with defensive costs. Surprising data shows that 40% of 2025 EAPA investigations stemmed from competitor tips, highlighting intra-industry rivalries driving reports.
Sources
- https://www.mayerbrown.com/en/insights/publications/2026/01/trade-fraud-2025-retrospective
- https://www.cmtradelaw.com/2025/06/cbp-announces-forced-labor-allegations-portal-rollout
- https://www.cbp.gov/trade/snapshot
- https://www.justice.gov/opa/pr/false-claims-act-settlements-and-judgments-exceed-68b-fiscal-year-2025
- https://www.cbp.gov/newsroom/national-media-release/thanks-president-trump-cbp-announces-record-breaking-200-billion