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U.S. Department of Justice (DOJ)

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U.S. Government Continues to Signal Sanctions Enforcement as a Priority: Three Recent Cases  

The U.S. government continues to demonstrate its commitment to enforcing sanctions and export control laws, with three recent announcements from the Department of Justice (DOJ) and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) highlighting the risks businesses and individuals face when compliance obligations are overlooked. 

Between October 9 and October 14, 2026, federal authorities announced a five-year prison sentence involving North Korean sanctions violations, a settlement with an international freight forwarding company, and an $11.6 million settlement with one of the nation’s largest banks. 

Although the cases involve different industries and circumstances, they reinforce a common message: sanctions enforcement extends across the global supply chain. 

DOJ: Five-Year Prison Sentence for North Korean Sanctions Violations 

On October 14, 2026, DOJ announced that Sasa Micev, a Bosnian national and international arms dealer, was sentenced to 60 months in federal prison after pleading guilty to violations of the International Emergency Economic Powers Act (IEEPA) and North Korean Sanctions Regulations. 

According to DOJ, Micev conspired with others to broker the purchase of North Korean SA-18 Igla portable surface-to-air missiles without the required authorization from OFAC. The scheme involved discussions about pricing, efforts to obtain the weapons using falsified documentation, and a meeting in Turkey to complete the transaction. The proposed sale ultimately fell through following a pricing dispute. 

OFAC: Freight Forwarder Agrees to $175,015 Settlement 

On October 9, 2026, OFAC announced a $175,015 settlement […]

By |2026-10-15T17:10:37-04:00October 15, 2026|U.S. Department of Justice (DOJ), U.S. Office of Foreign Assets Control (OFAC)|0 Comments
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DOJ Sues Tile Importer and CEO for $67.9 Million in Duties Over Alleged Transshipment and Shell Importers of Record

On September 28, 2026, the Department of Justice filed a civil complaint in the U.S. Court of International Trade against Uni-Tile & Marble, Inc. and its CEO, Xin Mian Pan, seeking $67,922,260.09 in unpaid duties and a $222,537,664.95 fraud penalty under 19 U.S.C. § 1592. The complaint alleges that Chinese ceramic tile, wooden cabinets and vanities, and quartz surface products subject to antidumping, countervailing, and Section 301 duties were transshipped through Malaysia, undervalued, misdescribed, and later entered under shell importers of record. In our view, the case is a roadmap for importers of AD/CVD-covered goods, their executives, and their sureties on how one set of entries can move from an EAPA determination to criminal charges and a civil penalty suit. 

Key Takeaways 

  • DOJ filed a civil complaint at the U.S. Court of International Trade on September 28, 2026, against Uni-Tile & Marble, Inc. and its CEO, Xin Mian Pan, under 19 U.S.C. § 1592. 
  • The fraud counts seek $67,922,260.09 in unpaid duties and a $222,537,664.95 penalty, with gross negligence and negligence pleaded in the alternative. 
  • The complaint alleges transshipment through Malaysia, undervaluation, misdescription, and entries under shell importers of record covering approximately 503 entries. 
  • The civil suit follows an EAPA evasion determination, CBP penalty proceedings, and a separate criminal indictment that also […]
By |2026-10-14T10:22:09-04:00October 13, 2026|U.S. Department of Justice (DOJ)|0 Comments
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A Warning for Importers: A CBP Prior Disclosure Does Not Count for DOJ

On October 1, 2026, DOJ’s National Fraud Enforcement Division issued Directive 26-12, which makes trade fraud a corporate enforcement priority and lists ten factors prosecutors must weigh in deciding whether to charge a company. In recent remarks, a government official added a point every importer should hear: a prior disclosure filed with CBP does not count as a voluntary self-disclosure for DOJ purposes. Importers, their executives, and the companies that buy from them, now face a dedicated DOJ trade fraud section, data-driven lead generation, and a sharp focus on country of origin. 

KEY TAKEAWAYS 

  • DOJ’s National Fraud Enforcement Division issued Directive 26-12 on October 1, 2026, listing customs-related fraud as one of four corporate investigation priorities and naming ten factors prosecutors must place great weight on when deciding whether to charge a company. 
  • A CBP prior disclosure is not a voluntary self-disclosure to DOJ. DOJ’s Corporate Enforcement Policy states that disclosures made only to regulatory agencies generally do not qualify. 
  • Country of origin fraud is the leading pattern. The government official said more than half of the trade fraud cases over the past year involved country of origin. 
  • Never filing an entry with CBP is not a defense. Earlier this year, a company pleaded guilty and paid a $6,382,000 fine for buying imported plywood it knew(or was willfully blind to the fact […]
By |2026-10-08T12:17:59-04:00October 8, 2026|U.S. Department of Justice (DOJ)|0 Comments
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DOJ and DHS Publish Comprehensive Trade Fraud Enforcement Guide: What Importers Need to Know 

Short summary: The DOJ and DHS have jointly published a new Resource Guide to Trade Fraud Enforcement, highlighting the government’s coordinated approach to combating customs fraud and strengthening import compliance. The guide explains key enforcement authorities, common trade fraud schemes, and the government’s expectations for importers, customs brokers, and others participating in global supply chains.

The U.S. Department of Justice (DOJ) and Department of Homeland Security (DHS) have released a new 31-page Resource Guide to Trade Fraud Enforcement, providing one of the clearest public statements yet on how the federal government views customs fraud, enforcement priorities, and importer compliance obligations. The guide was developed by the Trade Fraud Task Force, a partnership that includes DOJ’s National Fraud Enforcement Division, Homeland Security Investigations (HSI), U.S. Customs and Border Protection (CBP), and other federal agencies. 

While much of the guide summarizes existing laws and enforcement authorities, its significance lies in the government’s messaging. It makes clear that customs violations are no longer viewed as merely technical or administrative issues. Instead, DOJ and DHS repeatedly characterize trade fraud as a threat to economic security, national security, public safety, and human rights, signaling that aggressive enforcement will continue across multiple agencies. 

Combatting Trade Fraud Is a Priority for the Federal Government 

One of the report’s primary themes is that trade fraud extends far beyond the underpayment of duties. According to the guide, fraudulent import practices undermine domestic manufacturers, deprive the government of […]

By |2026-07-21T12:47:52-04:00July 21, 2026|Import, U.S Department of Homeland Security (DHS), U.S. Customs and Border Protection (CBP), U.S. Department of Justice (DOJ)|0 Comments
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The Largest Customs Fraud Settlement from the DOJ Trade Fraud Task Force: $549.5 Million and What This Means for Importers 

On May 12, 2026, the Department of Justice announced one of the largest customs fraud settlements in U.S. history. Perfectus Aluminum Inc., Perfectus Aluminum Acquisitions LLC, and four affiliated warehousing companies (“the Defendants”) agreed to pay $549.5 million to resolve False Claims Act (“FCA”) allegations that they knowingly evaded antidumping and countervailing duties on aluminum extrusions imported from China. 

The Scheme: Pallets That Weren’t Pallets 

The underlying conduct was relatively simple. According to the Settlement Agreement, between July 2011 and June 2014, the Defendants knowingly made false statements on CBP Form 7501 Entry Summaries, misrepresenting more than 2.2 million aluminum extrusions as finished merchandise not subject to antidumping and countervailing duties. The mechanism? The extrusions were spot-welded together to make them appear to be functional pallets — and there were no actual customers for these “pallets.” So, no merchandise was ever actually sold. 

Criminal Conviction Came First 

This civil settlement did not arise in a vacuum. In August 2021, a jury in the Central District of California convicted the Defendants of conspiracy to defraud the United States, wire fraud, and passing false or fraudulent documents through a customs house. Following sentencing, the defendants were ordered to pay restitution of approximately $1.83 billion to CBP. The May 2026 FCA settlement resolves the parallel civil litigation arising from the same conduct. Importantly, this civil resolution does not absolve the defendants from any criminal liability outlined in […]

By |2026-05-22T15:16:34-04:00May 22, 2026|AD/CVD, Enforcement, Import, International Trade, U.S. Customs and Border Protection (CBP), U.S. Department of Justice (DOJ), Uncategorized|0 Comments
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