Project 2025 Tracker / What’s done, what’s next

21. Department of Commerce · Notable

Pursue importers of record for unpaid duties with CBP, DOJ, and Treasury

Partially done

668 21. Department of Commerce

“Work with CBP , the Department of Justice, the Department of Treasury, and other relevant agencies to aggressively pursue importers of record and other beneficiaries for unpaid duties, and consider policy changes to reduce uncollected duties in the future.”

What has happened

  1. Partially done

    The Commerce end of the ask, missing until now, appeared — narrowly. Commerce submitted its first duty-evasion allegation to CBP under the Enforce and Protect Act in August 2025, and on 2026-07-30 CBP determined that fourteen importers of record were evading the antidumping duty order on carbon and alloy steel threaded rod from India; Commerce says it "worked with CBP to identify millions of uncollected duties to be recovered". That is Commerce pursuing importers of record for unpaid duties with CBP, which is what the Quote asks. It stays `partial` on two limbs the record still does not reach: Treasury is nowhere in it, and no policy change to reduce uncollected duties in the future has been proposed — #1827, the specific policy change this chapter asks for, is `not-started`.

  2. Partially done

    Harman paid $11.8 million to settle False Claims Act allegations that it evaded antidumping and countervailing duties on Chinese extruded aluminum — DOJ recovering unpaid AD/CVD duties from an importer of record, with CBP. The half of the ask that has moved is enforcement against individual importers; as at this date nothing recorded Commerce itself working the interagency effort with CBP, DOJ and Treasury, and no policy change to reduce uncollected duties in the future had been published. The Commerce limb arrives in the 2026-07-31 event below.

  3. Attempted

    The United States filed a civil customs-fraud complaint against a South Carolina office-furniture supplier and its owner for evading duties on imported goods — the first in-window instance of the Justice Department pursuing an importer of record for unpaid duties alongside CBP and Homeland Security Investigations.

  4. Attempted

    The Justice Department named the object of this ask an enforcement priority. The Criminal Division memorandum "Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime" tells all Criminal Division personnel that the Division "will prioritize investigating and prosecuting white-collar crimes in the following high-impact areas", and lists second, after program and procurement fraud: "Trade and customs fraud, including tariff evasion." The reasoning names the ask's harm directly — "Trade and customs fraudsters, including those who commit tariff evasion, seek to circumvent the rules and regulations that protect American consumers" — and "Trade, tariff, and customs fraud by corporations" is separately added to the subject areas of the Division's whistleblower awards pilot. `attempted`: a charging-priority memorandum directs, and on its own changes nothing. Note for the record that this is the Head of the Criminal Division's memorandum, not the Deputy Attorney General's, and that it does not mention the Department of Commerce or the Treasury.

Research log

What was searched, and what didn’t count as evidence

Research notes

The instrument here is not a Commerce instrument. The Justice Department’s press index (justice.gov/api/v1/press_releases.json, title= filter — the only route in, per source-apis.md) shows in-window customs-fraud and duty-evasion actions: the Myrtle Beach civil complaint (2025-07-16), the Harman False Claims Act settlement over evaded AD/CVD duties on Chinese extruded aluminum (2025-11-26), a forklift tariff-evasion indictment (2025-09-30), an Indonesian jewellery duty-evasion prosecution (2025-11-17) and a smuggling guilty plea (2026-01-22).

partial on §3’s “part of the ask achieved” test. What is missing is the Commerce end: no Commerce-led interagency arrangement with CBP, DOJ and Treasury, and no proposed policy change to reduce uncollected duties — which is what #1827 asks for in specific terms and is not started there.

Scan triage, 2026-10-01 (tenth run): one more instance, no rung. Perfectus Aluminum and five affiliates agreed on 2026-05-12 to pay $549.5 million to settle False Claims Act allegations that they evaded AD/CVD duties on Chinese aluminum extrusions. CBP worked the case, and the department’s Trade Fraud Task Force coordinated it (justice.gov/opa/pr/perfectus-aluminum-inc-and-related-companies-agree-pay-5495m-settle-false-claims-act). It is the same kind of action as the Harman settlement, at about fifty times the size. Neither of the limbs this item still lacks moves, Treasury’s part or a policy change to reduce uncollected duties, so it is recorded here and not as an event.

Read-queue ticket 07, 2026-09-06 — the memorandum was read, and the row’s description of it was wrong twice over. justice.gov/criminal/media/1400046/dl does not answer 200 with an HTML page: it returns application/pdf, 301,466 bytes, 377 lines of extracted text, to plain curl with a browser User-Agent. And it is not the Deputy Attorney General’s memorandum — it is signed by Matthew R. Galeotti, Head of the Criminal Division, and dated May 12, 2025, not simply “May 2025”. It does name trade and customs fraud a high-impact priority, which is why it is now Evidence on a 2025-05-12 attempted event; it does not name Commerce, so it does nothing for #1825, which moved on its own instrument instead.

Action
other
Object
unpaid AD/CVD duties owed by importers of record
ID
1826