• DOJ is actively enforcing tariff laws against companies and executives, including criminally. Three recent corporate resolutions confirm that the Trade Fraud Task Force is aggressively pursuing both criminal and civil liability against companies and executives that evade customs duties.
• Supply chain liability is a growing risk, even for companies that aren’t the importer. The Boise Cascade case demonstrates that downstream purchasers can face criminal prosecution if they knowingly—or with willful blindness—buy goods that were illegally imported, even where another company made the false customs declarations.
• Whistleblowers and expanding enforcement resources are amplifying the risk of detection. Two of the three cases originated from whistleblower complaints, and DOJ has recently bolstered its enforcement infrastructure with interagency partnerships and the creation of the National Fraud Enforcement Division—making it more important than ever for companies with international supply chains to evaluate their internal reporting policies and procedures.

The Department of Justice (“DOJ”) recently announced three significant tariff-related corporate resolutions, demonstrating the ongoing focus of the interagency Trade Fraud Task Force, which was launched in August 2025 in an effort to bring greater coordination to enforcement against tariff evasion.

These resolutions reflect several notable trends: DOJ pursuing tariff evasion as a core component of its national security and economic security agenda; the Department seeking multimillion-dollar civil penalties under the False Claims Act (“FCA”); prosecutors bringing criminal charges in cases of serious misconduct; efforts to hold both companies and their executives accountable; and DOJ evaluating corporate responsibility across the supply chain. Below, we summarize these resolutions and key takeaways.

Farjess Inc. and Royal Canadian Steel Inc. On May 20, 2026, DOJ announced that Farjess Inc. and Royal Canadian Steel Inc., two affiliated Canadian steel companies, and their president agreed to pay $19 million to settle allegations that they violated the FCA. According to DOJ, between 2019 and 2025, the companies avoided duties on certain steel products by misrepresenting that the products originated in North America when in fact they were manufactured in Europe and Asia. The enforcement action originated from a qui tam lawsuit brought by a broker who worked with Farjess. The broker is entitled to a whistleblower award of approximately $3.6 million.

Perfectus Aluminum. On May 12, 2026, DOJ announced that Perfectus Aluminum Inc., Perfectus Aluminum Acquisitions LLC and four affiliated warehousing companies (collectively, “Perfectus”) agreed to pay $549.5 million to resolve allegations that they violated the FCA by evading customs duties. According to DOJ, between 2011 and 2014, Perfectus imported pieces of aluminum but falsely represented on customs forms that the materials were finished goods not subject to antidumping or countervailing duties. As a result of this misrepresentation, Perfectus allegedly evaded duties on 2.2 million aluminum products. This settlement also resolved consolidated qui tam lawsuits brought by whistleblowers who alerted DOJ to the evasion scheme. These relators are entitled to receive 17.5% of the settlement proceeds.

This civil FCA settlement follows a related criminal conviction based on the same conduct. In 2021, a federal jury in California convicted Perfectus of several offenses, including conspiracy to defraud the United States. Following the conviction, Perfectus was sentenced to five years’ probation and ordered to pay $1.83 billion in restitution.

Boise Cascade. On April 27, 2026, DOJ announced that Boise Cascade, an Idaho-based wood company, pled guilty to a felony violation of the Lacey Act, a federal law prohibiting the illegal trafficking of wildlife, fish and plants, for its role in a scheme to evade countervailing and antidumping duties on imported timber. The company paid a $6.4 million fine.

According to DOJ, in or around 2019, Boise Cascade began purchasing hardwood plywood from a supplier—Horizon Plywood (“Horizon”)—that imported Chinese timber in violation of the Lacey Act. Horizon allegedly took steps to conceal the origin of the imported wood, including falsifying customs documentation and routing the products through Malaysia, where the wood was moved into new containers. Three Horizon employees were criminally prosecuted in connection with the scheme.

Boise Cascade’s liability stemmed from its purchase of over $30 million worth of timber from Horizon despite allegedly knowing the wood had been illegally imported. In particular, DOJ pointed to the fact that Boise Cascade continued to purchase plywood from Horizon after learning that federal agents executed a search warrant at a Horizon warehouse.

KEY TAKEAWAYS

These actions reinforce several recent tariff enforcement trends.

Criminal Enforcement. When DOJ launched the interagency Trade Fraud Task Force in August 2025, it vowed to step up criminal enforcement of tariff evasion. The recent corporate resolutions confirm that DOJ is pursuing criminal penalties in addition to civil penalties. In the case of Perfectus, its $549.5 million civil settlement came after it was indicted, convicted at trial and ordered to pay $1.83 billion in restitution. And the Boise Cascade resolution was exclusively criminal (under the Lacey Act).

Supply Chain-Based Liability. Although DOJ is focused on importers that make false declarations to Customs and Border Protection (“CBP”), the Department is also looking more broadly at other companies in the supply chain. In the case of Boise Cascade, a different company (Horizon) allegedly imported Chinese timber in violation of the Lacey Act. Boise Cascade was held responsible because DOJ found that it “purchased, received, sold, and transported hardwood plywood from Horizon knowing (including actions manifesting willful blindness) that hardwood plywood was illegally imported from China.”

Additional Enforcement Resources. In February 2026, the Trade Fraud Task Force announced a partnership with environmental regulators to ensure that goods harmful to the environment are not imported in violation of trade rules designed to keep them out of the United States. This partnership appears to have played a role in the Boise Cascade resolution, as DOJ noted that attorneys from its Environment and Natural Resources Division (“ENRD”) helped prosecute the case. In April 2026, DOJ also formed the National Fraud Enforcement Division (“NFED”) to investigate fraud on the federal government, and it appears likely that NFED will play a role in trade fraud investigations going forward.

This publication is for general information purposes only. It is not intended to provide, nor is it to be used as, a substitute for legal advice. In some jurisdictions it may be considered attorney advertising.