Official announcements, executive actions, research, and in-depth reports

CSIS commentary arguing that the White House's August report, The Great Transshipment Scam, attributes too much of the U.S.-China trade imbalance to transshipment by counting substantive manufacturing in third countries. It cites a 2026 Federal Reserve study finding that Chinese production in Mexico accounted for about 14 points of Mexico's export gains after the 2018-19 tariffs, against less than 1 point for direct transshipment, and recommends rules-of-origin reform, customs data sharing and changes to China's export tax rebates.

DOJ’s October 7, 2026 directive turns stated priorities into instructions for prosecutors: pursue every responsible participant, add charges where warranted, seize assets before proceeds move, and use forfeiture and civil remedies together. The operational document behind the rhetoric.

CBP’s October 2, 2026 consolidated determination that Chinese seamless steel pipe was routed through Thailand to evade antidumping and countervailing duties. A finding of evasion is not a collection; the notice says nothing about recovered money.

Alliance letter to Speaker Johnson and Leader Jeffries asking that the House Select Committee on the CCP continue into the 120th Congress. Signed by all six founding members, it credits the Committee with pressing CBP, HSI and DOJ on enforcement gaps and moving the PAIL Act through the House.

CBP’s September 28, 2026 determination that XCMG North America evaded duties on Chinese mobile access equipment shipped through Mexico, with combined duties of 69.31% on affected entries. The Mexico route, in CBP’s own words, with no recovery figure attached.

Rep. Ashley Hinson’s announcement of House passage of the Trade Crimes Act, H.R. 1869, which would create a dedicated federal framework for prosecuting trade crimes. House action is done; the Senate has not moved.

Federal Register notice implementing Executive Order 14411: from September 18, 2026, CBP applies stronger identity verification to importers of record. Aimed at the shell and nominee importers that let a scheme continue after its first importer is caught.

Assistant Attorney General Colin McDonald’s August 13, 2026 memorandum reaffirming trade and customs fraud as Criminal Division priorities: transshipment, origin fraud, undervaluation, sanctions evasion and forced labor. The baseline against which DOJ’s output can be judged.

The White House report assembling five estimates of transshipment exposure, from $40 billion to $303 billion a year. The methods differ and none proves fraud, which the report concedes; the order of magnitude is the point.

DOJ and DHS’s July 2026 guide to how the government investigates and prosecutes customs fraud, covering statutes, penalties, whistleblower mechanisms and the interagency framework. The most useful single document for understanding which tools exist and which agency holds each one.

June 2026 executive order mandating importer-of-record reforms, a 50% minimum penalty with no mitigation for repeat offenders, heightened disclosure and certification, and annual enforcement transparency reports. The transparency reports are the part worth holding the agencies to.

House Appropriations Committee report on the FY2027 Commerce, Justice, Science bill proposing a tenfold increase in DOJ trade-fraud enforcement funding. A committee recommendation, not an appropriation; it has to survive conference and a floor vote.

ITIF’s formal comments on revoking China’s Permanent Normal Trade Relations, estimating costs of up to $7 billion a year for national-power industries and identifying 930 import-dependent product categories. Useful for the realistic trade-offs behind any sharp change in China policy.
Senator Bill Cassidy’s SAFE Act, introduced March 2026, aimed at the accountability gap for foreign importers of record who evade duties and vanish. Introduced, not enacted; one of several bills targeting the same hole.

Mayer Brown’s analysis of Cody Herche’s first remarks as Task Force head: a stated shift toward criminal prosecution and individual accountability, with $140 million recovered by the Task Force to date. Read it for the four initiatives he laid out, then check them against results.

USITC working paper proposing a method for flagging possible transshipment by measuring trade that falls outside expected patterns. It is explicit that the result is a risk indicator, not proof, which is exactly what makes it usable for targeting.

Letter led by Rep. Dan Goldman and Senators Warren and Blumenthal seeking an accounting of how reassigning federal investigators, including HSI agents, to immigration operations has affected complex investigations. Trade fraud cases run through HSI; nobody has published the capacity loss.

Representatives Krishnamoorthi and DeLauro’s statement backing a strengthened Trade Fraud Prevention Task Force, calling for interagency coordination, dedicated funding and stricter penalties. Bipartisan support for enforcement capacity, stated on the record.

USCC assessment of how far China’s state-directed industrial plan has advanced in advanced manufacturing and emerging technologies, and at what cost to fair competition. Context for why the products in our case tracker so often originate in subsidized Chinese industries.

Catena-X’s automotive standard for tracing parts and materials across multi-tier supply chains, with interoperable data models and APIs. Included because the same infrastructure built for quality alerts could verify origin claims; it is a model of what provable origin looks like.
The launch announcement of the Alliance for Trade EnforcementNOW: manufacturers from different sectors, each harmed by tariff evasion, pooling documentation and intelligence to demand measurable enforcement outcomes. Our starting point.
The Coalition for a Prosperous America’s response to the DOJ–DHS Trade Fraud Task Force, welcoming coordination between prosecutors and investigators that had previously let cases fall between agencies. Its call for adequate staffing is the one to track.

CBP reports more than $400 million in unpaid duties found through EAPA investigations between January 20 and August 8, 2025, including its largest case ever: 23 importers and a network of Chinese shell companies routing through Indonesia, South Korea and Vietnam. Every importer examined was in violation.

ING’s data-driven look at how Chinese exporters shifted volumes to alternative markets in the first phase of higher tariffs. The patterns of diversion it identifies are the same patterns enforcement agencies need to anticipate.
America Renewing’s foundational primer on the main evasion techniques, transshipment, undervaluation, misclassification and false origin certification, and the sectors they hit hardest. A good first document for a staffer or reporter new to the subject.

DHS OIG and GAO tracking of which oversight recommendations to DHS components, including CBP, have been implemented and which remain open. A plain record of where accountability gaps in customs enforcement persist, written by the auditors rather than the agency.

Washington Center for Equitable Growth review of what the China trade shock did to manufacturing regions: factory closures, lost jobs and lasting effects on wages and labor-force participation. The human ledger behind the enforcement debate.

Analysis of how commercial technology imports can carry embedded software, hardware backdoors and surveillance capability into critical systems, with case studies and screening recommendations. Trade fraud and national security overlap here more than most enforcement discussions acknowledge.
The Alliance’s own study of seven years of Section 301 evasion through transshipment, misclassification, undervaluation and de minimis abuse. Built on enforcement data and member testimony, it is the baseline against which we measure whether enforcement is improving.

Dr. Vikram Nehru’s USCC testimony on Southeast Asia’s role as China’s manufacturing hinterland and the strain the current China shock places on the region. Relevant because the same economies are the transshipment hubs that recur throughout our case tracker.

Caroline Freund’s product-level method for estimating transshipment of Chinese goods through third countries. Vietnam peaked above 7 percent of imports in 2020, Mexico never passed 1.5 percent, and closing one route pushed evasion toward Singapore and Thailand.

Harvard Kennedy School research finding that workers displaced by Chinese import competition never recovered their earlier earnings paths, and that adjustment assistance did little to change that. Evidence that enforcement failures impose costs that compound rather than fade.

Munk School research on trade enforcement mechanisms and how well current regulatory approaches work across jurisdictions. Its emphasis on cross-border information sharing among customs authorities points to a gap that domestic enforcement alone cannot close.

The House Select Committee on the CCP’s three-pillar strategy for economic competition with China, with specific legislative recommendations for closing enforcement gaps and measuring reduced dependency. Several of the Committee’s proposals have since moved toward law.

Bloomberg’s interactive account of how subsidies, below-cost pricing and technology transfer dismantled American solar manufacturing and left the supply chain under Chinese control. Solar panels also top the list of transshipped products in the China Wash study.

DHS Inspector General audit of how CBP assesses penalties, tracks collections and closes cases. Its finding that penalty administration is inconsistent and poorly tracked is the clearest official evidence that assessed penalties and collected penalties are different numbers.

Treasury Inspector General review finding inadequate staffing, inconsistent processes across ports and persistent difficulty recovering revenue from importers who undervalue or misclassify goods. A 2024 snapshot of the capacity problem that later enforcement initiatives were built to address.

The former U.S. Trade Representative’s testimony on why trade enforcement against China has failed and what reforms would fix it, drawn from his own negotiations and implementation experience. A concise statement of the problem from the official who ran the policy.

Federal Reserve Board research showing that, once trade routed through Vietnam, Mexico and Taiwan is accounted for, the bilateral deficit with China barely moved during the 2018–2020 trade conflict. The empirical case that tariffs without enforcement do not change outcomes.

The Autor, Dorn and Hanson paper that established how large and lasting the labor-market damage from Chinese import competition was, far beyond what trade theory predicted. The academic foundation for treating trade enforcement as an economic-security issue.
Department of Justice enforcement actions, settlements, and case outcomes

DOJ’s civil action seeking $67.9 million in duties and $222.5 million in penalties over Chinese cabinets, quartz and tile transshipped through Malaysia, after CBP’s demands went unpaid. Civil and criminal cases running in parallel; neither is resolved and the allegations are unproven.

DOJ announces the Trade Fraud Task Force passed $1 billion in recoveries and charged losses in under a year, through a partnership of the Criminal, Civil and ENRD divisions with HSI and CBP. The figure combines money recovered with losses merely charged; the split is not given.

Two Canadian steel companies and their president agreed to pay $19 million to resolve False Claims Act allegations that flat-rolled steel from China, Indonesia, Italy, Turkey and Vietnam was declared Canadian or American from 2019 to 2025. A whistleblower brought the case; the relator receives about $3.6 million.

Perfectus Aluminum and affiliates agreed to pay $549.5 million for evading duties on Chinese aluminum extrusions imported from 2011 to 2014, following corporate criminal convictions in 2021. Twelve years from first entry to civil settlement, and an agreement to pay is not a collection.

DOJ’s announcement of the $549.5 million False Claims Act settlement with Perfectus Aluminum for disguising Chinese extrusions as “pallets.” The scheme ran 2011–2014, convictions came in 2021, money moved in 2026: fifteen years from the first false entry.

Boise Cascade pleaded guilty under the Lacey Act and was sentenced to pay $6.38 million for buying Chinese hardwood plywood it knew had been transshipped through Malaysia to evade duties above 200%. It kept ordering after a search warrant hit its supplier.

DOJ names the Northern District of Illinois a lead prosecutorial partner on the Trade Fraud Task Force, citing the office’s “Honeygate” prosecution as groundwork. A signal that criminal trade cases will be built in the districts, not only in Washington.

Echelon Fitness agreed to pay $2.1 million to settle allegations it underreported the cost of Chinese-made equipment and left bundled tablets off customs invoices from 2019 to 2023. Another whistleblower-initiated case; the pattern in these settlements is who brings them.

MGI International, a global plastic resin distributor, agreed to pay $6.8 million and its former COO agreed to plead guilty to conspiracy to smuggle, facing up to five years, for falsifying country of origin to avoid Section 301 duties. An executive, not just a company, on the hook.

An automotive parts importer settled False Claims Act allegations that it used incorrect tariff classifications to pay lower duties on Chinese components. A reminder that misclassification, not only transshipment, moves money in the auto supply chain.

Indictment of Bay Area businessmen, a Chinese national and three companies for conspiring to evade duties on cabinets, quartz and tile, with exposure up to $331 million and 20 years. The criminal half of the Uni-Tile matter; the civil suit followed in October 2026.

Ceratizit USA agreed to pay $54.4 million to resolve allegations it evaded antidumping and countervailing duties on Chinese tungsten carbide by misrepresenting origin and classification. One of the larger settlements of 2025, in a product most people have never heard of.

Harman International agreed to pay $11.8 million to settle allegations it failed to pay antidumping and countervailing duties on products containing Chinese aluminum extrusions. The aluminum extrusion orders keep producing cases a decade after they were issued.

Able Groupe, operator of LittleBundle.com, pleaded guilty to smuggling 76,000 units of European infant formula using false commodity descriptions, with $2.3 million at issue. Customs fraud is not only about tariffs; false descriptions defeat safety screening too.

An Indonesian jewelry company, its co-owner and two employees were charged with evading more than $86 million in duties on $1.2 billion of jewelry imports. The scale of the alleged evasion relative to declared value is the number to watch.

Si Oh Rhew and Yong Hee Rhew were sentenced to federal prison for undervaluing imported goods and laundering the proceeds, with more than $19 million in restitution ordered. Prison time, not only a settlement, for a customs-valuation scheme.

Endless Sales and Octane Forklifts and their executives were indicted for importing Chinese forklifts, disguising their origin, selling them to federal agencies as U.S.-made and undervaluing them to avoid more than $1 million in duties. The buyer was the government itself.

Azruddin Mohamed and Nazar Mohamed were charged in a $50 million tax evasion and gold smuggling scheme, with $5.3 million sought in forfeiture. Included because the Task Force counts smuggling cases in its totals.

Grosfillex agreed to pay $4.9 million to resolve allegations it declared Chinese aluminum extrusions as duty-free furniture parts and packaged them as sham “kits,” then failed to correct the forms after learning they were false. The kit trick is a known evasion method, documented here by DOJ.

Global Plastics and Marco Polo International agreed to pay $6.8 million for misdeclaring origin and value on Chinese plastic resin from 2019, with credit for voluntary disclosure, an internal investigation and remediation. The reference case for what self-reporting buys.

DOJ’s complaint against Global Office Furniture and its owner alleging more than $2 million in duties evaded through false origin and value declarations. A complaint, not a resolution; filed July 2025 and worth tracking to outcome.

DOJ’s complaint against Barco Uniforms and its suppliers alleging underpaid duties through undervaluation and misclassification. Filed June 2025; the government is suing the importer and the suppliers together.

Two individuals pleaded guilty to bringing unapproved adulterated animal drugs, including xylazine, into Puerto Rico from Colombia, Mexico and Argentina, in a case coordinated through the Trade Fraud Task Force. The Task Force’s remit includes product safety, not just duties.

A Texas couple pleaded guilty to running a website selling smuggled Mexican pesticides and misbranded veterinary drugs, importing $2.4 million through Calexico from 2018 to 2022. Four years of imports before the plea.

DOJ sued Repwire LLC for transshipping Chinese aluminum extrusions to evade antidumping and countervailing duties, seeking more than $11 million in duties and penalties up to $62 million. A suit, not a settlement; the penalty multiple shows what the False Claims Act allows.

A laminate flooring importer agreed to pay $8.1 million to resolve allegations it evaded duties on Chinese wood flooring through misclassification and false origin declarations. Flooring is one of the most-evaded product lines in the case record.

Allied Stone and its president agreed to pay $12.4 million to settle allegations they misclassified Chinese quartz surfaces to evade antidumping and countervailing duties from 2018 to 2023. Five years of entries, resolved civilly, with the president named.

Eight defendants, including logistics executives, warehouse owners and truck drivers, were arrested on an indictment alleging a conspiracy to smuggle more than $200 million in counterfeit goods from China through Los Angeles-area ports. The logistics layer, not the importer, as the target.

A jeweler operating in India and New Jersey was sentenced to 30 months in prison for a multimillion-dollar customs fraud built on false declarations. Prison for customs fraud remains rare enough to note each instance.

A Miami importer pleaded guilty to conspiring to evade U.S. tariffs on Chinese truck tires, facing up to five years. Truck tires carry some of the highest AD/CVD rates on the books, which is why they attract schemes.

Noel and Kelsy Hernandez Quintana were each sentenced to 57 months for transshipping $25–65 million of Chinese hardwood plywood through Malaysia, evading about $44 million in duties. The supplier side of the Boise Cascade case.

Alexis, a womenswear company, paid $7.6 million to resolve False Claims Act allegations of systematically underpaying duties on imported apparel. Apparel undervaluation is common; a seven-figure settlement for it is not.

Two Brookfield, Wisconsin companies and their owners paid more than $10 million to resolve allegations they evaded duties on imported cable assemblies. Owners named alongside the companies.

Akua Mosaics and its president pleaded guilty to conspiracy to smuggle goods into the United States. A guilty plea by a named executive in a household-goods case.

The owner of a New Jersey company admitted to evading duties by mislabeling hazardous chemicals imported from China, resolved with a guilty plea and a $3.1 million civil settlement. Criminal and civil tracks closed together, the model DOJ now says it wants.

The owner of Penta International admitted to evading duties through false statements, with the company agreeing to pay $3.1 million. An individual admission paired with a corporate payment.

Ford agreed to pay $365 million to settle allegations under the Tariff Act of 1930 that it misclassified Transit Connect vans to pay a lower duty rate. The largest customs penalty on this list came from classification, not smuggling, and from a domestic manufacturer.

Yakima Products, an Oregon auto-accessory company, agreed to pay about $3 million to resolve allegations it failed to pay antidumping duties on imported products. A U.S. brand caught by orders written for foreign producers.

An importer agreed to pay $798,334 to resolve False Claims Act allegations of underpaid duties. The same dollar figure appears in the Homestar North America settlement below; the two entries may describe one case.

A Dallas importer of industrial products and two Chinese companies agreed to pay $2.5 million to resolve allegations of underpaid duties. The Chinese suppliers were parties to the settlement, which is unusual.

International Vitamins Corporation agreed to pay $22.8 million to settle a civil fraud suit over misclassified supplement imports. One of the larger misclassification recoveries on record.

King Kong Tools agreed to pay $1.9 million to settle claims it falsely labeled cutting tools “Made in Germany.” Origin fraud that targets the consumer as much as the Treasury.

Homestar North America agreed to pay $798,334 to resolve allegations it underpaid duties on imported furniture and household goods. See the note on the matching $798K entry above.

Yogibo agreed to pay $217,000 to resolve allegations it misrepresented the country of origin on bean bag imports. Small dollars, same mechanism as the nine-figure cases.

Samsung C&T America, a global trading company, settled for $1 million over underpaid duties on footwear. Trading houses, not only manufacturers, show up in the record.

High Life, a New York apparel company, agreed to pay $1.3 million to settle allegations it underreported the value of apparel shipments. Undervaluation, the most common scheme in the list.

Anyclo International, a South Korean clothing manufacturer, admitted to evading U.S. duties from 2012 to 2019 through false declarations, with a guilty plea and a civil settlement. Seven years of entries before resolution.

Six Southern California companies were ordered to pay $1.83 billion in restitution for schemes to avoid customs duties and tariffs, the aluminum case tied to China Zhongwang. A restitution order is a number on paper; what was collected is a separate question.