False Claims Act  ·  Customs & Tariff Fraud

Tariff evasion is among the fastest-growing False Claims Act enforcement priorities. The Ninth Circuit has already shown it's serious.

When importers make false statements on customs forms to evade duties owed to the United States, the False Claims Act applies. Whistleblowers — including competitors — have recovered millions. This practice has Ninth Circuit appellate experience in exactly this case type.

Customs fraud is a "reverse" false claim — cheating the government by not paying what's owed.

Most False Claims Act cases involve someone taking money from the government they shouldn't have. Customs fraud works the opposite way: the defendant has an obligation to pay duties to the United States — and makes a false statement to avoid or reduce that payment. This is called a "reverse false claim" under 31 U.S.C. § 3729(a)(1)(G), and it carries the same treble damages and civil penalties as traditional FCA liability.

When an importer fills out CBP Form 7501 (Entry Summary) and makes a false statement — about the country of origin, the product classification, or the dutiable value — to reduce or eliminate the duties owed, that false statement may trigger FCA liability for three times the duties evaded, plus civil penalties per entry.

The enforcement environment has changed significantly. DOJ launched a cross-agency Trade Fraud Task Force in partnership with U.S. Customs and Border Protection in 2025. Tariff evasion is now a stated enforcement priority alongside healthcare fraud — and the stakes have risen substantially as tariff rates have increased.

$26M

Verdict affirmed by the Ninth Circuit Court of Appeals in a case where a domestic competitor blew the whistle on a pipefitting importer evading antidumping duties. The court confirmed competitor standing in customs fraud qui tam cases.

This Practice

Rob Milesnick is admitted in the Ninth Circuit Court of Appeals — the same court that decided this case and the appellate forum for any Oregon or Washington FCA matter. That appellate familiarity directly affects how cases are built from the outset.

Three primary patterns — each involving a false statement on a federal form.

The product was made in China. The paperwork says Taiwan.

Transshipment fraud involves routing goods manufactured in a high-tariff country through a third country, then falsely declaring that country as the origin. Goods subject to Section 301 tariffs because of their Chinese origin — often 25% or higher — become significantly cheaper if they can be falsely declared as manufactured in Vietnam, Taiwan, Malaysia, or elsewhere.

The fraud is in the CBP Form 7501 declaration. If the actual country of manufacture is China and the form says otherwise, that false statement may trigger treble damages on all evaded duties, plus civil penalties per shipment.

The Route
China (manufactured) → Taiwan or Vietnam (transshipped) → USA
Declaration: "Made in Taiwan"
Reality: Subject to Section 301

Key evidence: shipping records, certificates of origin, internal communications about routing decisions, country-of-origin marking on the goods themselves.

The product is a "welded outlet" subject to antidumping duties. The paperwork calls it something else.

Every imported product is classified under a Harmonized Tariff Schedule (HTS) code that determines the applicable duty rate. When importers deliberately classify goods under an incorrect code to obtain a lower rate — even when the product's actual characteristics clearly require the higher-duty classification — that misclassification may constitute a false statement on the entry form.

This pattern is common in antidumping duty cases, where imported products are subject to country-specific duty orders that make certain goods significantly more expensive unless they can be classified as something else. The "two sets of books" pattern — an internal invoice showing the true product description and an external commercial invoice showing the alternative classification — is among the strongest evidence in these cases.

Undervaluing the goods, or failing to mark country of origin, to reduce or eliminate duties.

Because many tariffs are assessed as a percentage of the declared value of the goods, undervaluing shipments on entry forms directly reduces the duty owed. Importers who declare a lower-than-actual transaction value — sometimes using a "first invoice" scheme where the real price is reflected in internal documents but a lower price is declared to customs — may be liable for the full duties evaded at treble damages.

Customs fraud whistleblowers come from inside companies and from outside them.

The Insider Employee

Logistics managers, compliance officers, customs brokers, trade compliance analysts, and shipping staff who directly handled entry documentation and observed the false declarations being made or directed by management.

The Competitor

A domestic manufacturer or legitimate importer who loses business because a competitor is illegally underpricing them by evading duties they themselves pay. The Ninth Circuit confirmed this standing in the Island Industries case. This is one of the most powerful relator postures in customs fraud — the competitor has both motive and industry knowledge.

The Former Employee

Former compliance, logistics, or finance employees who have detailed knowledge of the company's documentation practices, internal invoicing systems, and the gap between what was declared to customs and what was actually transacted.

"The smoking gun in customs fraud cases is usually the same: someone knew, and they said it anyway."

After Schutte v. SuperValu, FCA scienter focuses on the defendant's subjective knowledge and beliefs — not on post-hoc "objectively reasonable" interpretations. In customs cases, this means internal emails directing employees to use a particular country of origin, compliance flagging the issue and being overridden, or management explicitly directing classification decisions are among the most powerful evidence available. The question is whether the defendant knew — and did it anyway.

What customs and tariff fraud whistleblowers ask before coming forward.

I'm a competitor, not an employee. Can I really be a whistleblower?
Yes. The Ninth Circuit confirmed competitor standing in customs fraud qui tam cases in the Island Industries decision — where a domestic pipe fitting manufacturer successfully brought a case against importers evading antidumping duties. The key requirements are firsthand knowledge of the fraud (not just suspicion) and information that is not publicly disclosed. A competitor who can document specific shipments, specific duty orders being evaded, and the impact on their own business may have a strong relator position.
What is an antidumping duty order and how does it relate to FCA liability?
An antidumping duty order is issued by the Commerce Department when foreign goods are found to be sold in the U.S. at below-market prices in a way that harms domestic industry. These orders impose country-specific additional duties on the affected goods. When importers evade these duties by misrepresenting the country of origin or misclassifying the goods, the FCA's reverse false claims provision applies — treble damages on all evaded duties plus civil penalties per entry.
The company routed goods through a third country but I'm not sure that's actually fraud. How is this different from legitimate transshipment?
Legitimate transshipment occurs when goods are genuinely manufactured or substantially transformed in the declared country of origin. Fraud occurs when the routing is designed to misrepresent the actual country of manufacture on customs documentation, with the intent to evade applicable duties. The line between legitimate supply chain routing and fraudulent transshipment is a factual question — but the key indicators are whether the goods were actually manufactured or substantially transformed in the declared country, and whether internal documentation reflects a different understanding than what was declared to customs.
Is customs fraud really a priority for DOJ right now?
Yes — this is not theoretical. DOJ launched a cross-agency Trade Fraud Task Force with CBP in 2025, and tariff evasion has become a stated enforcement priority alongside healthcare fraud. The increase in tariff rates since 2025 has significantly raised the financial stakes of evasion — and correspondingly, the government's recovery interest in successful cases. The enforcement environment for customs fraud is more active now than at any point in the past decade.

If you know how the paperwork was prepared — and it doesn't match reality — that's worth a careful look.

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