Contents
Customs fraud statistics show billions in estimated lost duties and a much smaller recovery in individual customs fraud cases. Duty evasion cheats importers that pay their duties and lose sales to those that do not, the American industries the duty orders protect, and taxpayers.
For an importer losing business to an impossible price, or an employee watching the same goods acquire a different description, the useful question is closer to home: what did the company import, what did it tell U.S. Customs and Border Protection, and where did the duty go? The national totals cannot answer that. The people handling the shipments often can.
The White House’s The Great Transshipment Scam: Rise, Scope, and Costs puts the value of potentially rerouted goods in the tens to hundreds of billions. Published by the Office of Trade and Manufacturing Policy on August 13, 2026, the report compares five estimates:
| Estimator | Period | Estimated Value of Goods |
|---|---|---|
| Goldman Sachs | 2023 | Approximately $40 billion in rerouted goods |
| Council of Economic Advisers | Potential 2025 transshipment | $60 billion, the report’s rounded midpoint |
| Exiger | February 2025 to February 2026 | $75 billion, the report’s midpoint |
| Department of Commerce | 2025 | Roughly $109 billion in its broad trade-transfer screen |
| Altana | Annual, calendar year unspecified | $303 billion in potential exposure, a broad upper bound |
The report’s annual lost-revenue scenarios range from roughly $10 billion to $136 billion, using assumed tariff differences of 25% to 45%. Those scenarios do not fully include additional antidumping and countervailing duties. Even the low estimate dwarfs the individual civil recoveries below.
The size of the problem makes transshipment tariff evasion cases worth pursuing. They turn on what happened between factories and ports: where the goods were made, what work happened along the way, and what the importer told Customs.
The importer declares the value, classification, and duty rate. Customs can release the goods before it settles the final duty bill, a process called liquidation. With antidumping and countervailing duties, the final rate can arrive after the goods have been sold. The goods leave. The duty question stays open.
The paper trail has several authors. Before ocean cargo loads abroad, the importer files an Importer Security Filing. The carrier separately supplies a manifest. The bill of lading, commercial invoice, and entry summary on Customs Form 7501 come from different stages of the transaction. Their descriptions, parties, and values can be compared long after the container leaves the port.
Origin adds another difficulty. National import statistics use declared origin, while the production evidence may sit in a foreign factory. Marking rules, trade preferences, and the duty order can ask different origin questions. A country column in a trade table cannot show the machinery, materials, or work that went into the product.
Comparing a country’s imports with its trading partners’ exports can help identify products and routes worth investigating. The World Customs Organization’s Mirror Analysis and Revenue Fraud, published in 2015, explains how a missing quantity under one product code can reappear under another carrying less duty. Combining the codes can hide the discrepancy. The product detail matters more than the grand total.
When estimating the lost revenue, the paper makes a point that belongs beside every large transshipment estimate:
This is an important stage, since the biggest differences in values or quantities do not necessarily generate the biggest revenue losses.
Mirror Analysis and Revenue Fraud, World Customs Organization, 2015
The economic incentive also shows up in trade data. Measuring Tariff Evasion and Smuggling, published in NBER Reporter in 2009, describes a study of Hong Kong-to-China trade that associated a one percentage point tariff increase with a three percentage point increase in the gap between reported exports and imports. It helps explain why the duty attached to a particular product matters so much to the investigation.
Customs found far more lost revenue in its fiscal 2024 audits than it collected:
in lost trade revenue identified through 417 audits in fiscal 2024.
$117.6 million collected from those audits.
U.S. Customs and Border Protection, Trade Fact Sheet reporting fiscal 2024
The same fact sheet puts annual imports at $3.37 trillion. The audit gap sits inside an enormous flow of goods.
More recently, the Justice Department’s July 14, 2026 announcement reported that Customs had assessed more than $2.1 billion in commercial trade penalties so far that fiscal year and barred 35 parties from doing business with the federal government.
The Government Accountability Office’s unpaid antidumping and countervailing duty bills span many years. They cannot supply an annual customs fraud loss.
Its 2016 report found about $2.3 billion uncollected as of mid-May 2015 on goods entered in fiscal years 2001 through 2014. Twenty importers accounted for about half the balance. Most had stopped importing before receiving their first bill.
The 2019 report put open and uncollected bills at $4.5 billion as of August 2019 for fiscal years 2001 through 2018. They reflect the system’s retrospective calculation of antidumping and countervailing duties, where the final amount can exceed the deposit taken at entry.
In shell importer duty evasion, the bill can arrive after the importer is gone. The business behind that importer matters: who controlled it, what assets it had, and who directed the imports. Executive Order 14411’s importer of record requirements address that problem by directing changes to asset, bonding, ownership-disclosure, and shell-company rules.
The Department of Justice’s Other FCA category does not provide customs recovery statistics. The annual False Claims Act tables accompanying its announcement separate health care, defense, and everything else. Customs shares that last category with procurement, grants, loans, and other programs. Growth in that category cannot tell an importer how many customs cases succeeded or how much duty they recovered.
The DOJ Trade Fraud Task Force also reaches beyond importers. Its mandate covers customs brokers, downstream distributors, and commercial end users who knowingly profit from unlawfully imported goods.
Individual cases become more useful when the dollar amount stays attached to the conduct. In Perfectus Aluminum’s customs settlement, the government alleged that Chinese aluminum extrusions entered as finished pallets to avoid duties. The civil agreement put the alleged unpaid duties at more than $3 billion.
The settlement agreement accompanying the May 12, 2026 announcement required $549,594,030. It tied that obligation to sales of warehouses and aluminum pallets, with net proceeds credited toward the civil payment. The task force’s later announcement expressly reported collection.
The agreement provided an 18% whistleblower reward from the net civil payment.
Ceratizit USA’s customs settlement shows a different product and several alleged ways of reducing the bill. The Justice Department’s December 18, 2025 announcement set the settlement at $54.4 million over tungsten carbide products. The allegations concerned Chinese goods routed through Taiwan, incorrect tariff classifications, and unpaid origin-marking duties. The department said the whistleblower would receive approximately $9.75 million of the settlement proceeds.
The case documents connect the amounts to false product descriptions, incomplete values, and decisions to leave entries uncorrected.
Global Plastics reached its civil settlement in 2025 after disclosing problems with plastic-resin imports. The government alleged false origin and value declarations. The civil agreement accompanying its announcement credited an independent investigation, preserved records, a damages analysis, and changes inside the business. The resulting duty account depended on what the company uncovered about its own shipments.
Grosfillex settled in 2025 over allegations that Chinese aluminum furniture parts entered as finished kits and that earlier false declarations stayed uncorrected after the company learned they were wrong. The agreement accompanying its announcement makes the later decision part of the alleged scheme.
Allied Stone settled in 2025 over allegations that it described Chinese quartz as marble or crystallized glass and failed to ensure that manufacturers and third-party importers declared and paid the duties. The settlement agreement accompanying its announcement follows the goods to warehouses and jobsites. The whistleblower’s complaint supplies a detail that a national trade table never could:
Allied’s quartz crate labels did not include the stone type, the description of where the stone would be used, the color name, or an indication of from where the quartz came.
Whistleblower’s allegation, United States ex rel. Melinda Hemphill v. Allied Stone Inc., et al., complaint
Ameri-Source International’s 2016 settlement turned on the size of graphite electrodes used in steelmaking. The Justice Department alleged misclassification of their size to avoid antidumping duties on small-diameter electrodes. The duty distinction concerned products around 16 inches or less in diameter. A product specification could answer a question that a dollar total could not.
Evolutions Flooring‘s 2025 settlement adds the factory question. The Justice Department alleged false manufacturer and origin information for Chinese multilayered wood flooring. Its announcement describes factory visits in Thailand, shipment reviews, import-data analysis, and witness interviews. Investigators went beyond the country written on the entry.
Value can reach beyond the supplier’s main invoice too. In Yogibo’s 2023 settlement admitting a dual-invoice practice, the broker received the lower commercial invoice while a separate invoice charged for inland freight, design, and quality control. Eos Energy Storage’s 2022 resolution involved omitted battery-production components and other costs. Those components illustrate customs assists: production inputs supplied to the foreign manufacturer whose value can belong in the import declaration.
The useful customs fraud evidence connects what the company imported and paid with what it declared and knew. A broker’s instructions or a decision to leave false entries uncorrected can explain why the duty went unpaid.
Accounts payable, sourcing, compliance, and the warehouse may each hold a different part of that picture. An insider who can explain how those records fit together adds something the national statistics cannot supply. We build that account with you.
A competitor can bring a customs qui tam case. Island Industries, a competitor of Sigma Corporation, brought the case over Chinese welded outlets described as steel couplings. A jury found Sigma liable in 2021. The court’s account connects knowledge of the product with the declarations that avoided duty.
A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. A customs fraud whistleblower reward depends on the recovery in the case, not the value of goods in a national estimate. Our experts assess the unpaid duty and the evidence with you.
If you keep seeing rerouted or misdescribed goods move through your company or your market, speak to one of our whistleblower experts. We connect the duty, the documents, and the decisions inside the business to build your case with customs fraud whistleblower lawyers who understand the products and duty orders involved. We stay beside you from the first assessment through the case.