Where you report illegal imports can determine whether you receive a share of the recovery. A customs fraud tip gives the government a lead. A whistleblower case can give the person reporting a share. One invoice goes to Customs. Another reflects what the supplier actually gets paid. These are the gaps an insider can explain. The competitor that paid in full and the taxpayers owed that money both have a stake in getting it back.
To decide how to report customs fraud, talk with our whistleblower experts about the case your evidence could support. A False Claims Act case can pay a recovery share, a Customs informer award has a ceiling, and an EAPA allegation pays nothing. We assess the evidence, the unpaid duties and the reporting options with you.
CBP e-Allegations and other trade violation reporting give U.S. Customs and Border Protection information to investigate. Only the government can bring a customs penalty case. The person who supplied the tip cannot take over that case if the government decides against pursuing it.
A customs informer award is discretionary and can pay up to 25% of the net recovery, capped at $250,000 per case. The cap holds however much the government recovers. That is a very different proposition from a customs fraud whistleblower reward under the False Claims Act.
A private person or company can bring a customs fraud case under the False Claims Act on the government’s behalf. That is a qui tam case. Knowingly keeping duties owed to the government is enough for one, even though the importer never asked the government to pay it anything.
A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. In Ceratizit USA‘s $54.4 million settlement, the Department of Justice reported an award of about $9.75 million for the whistleblower. Customs’ informer program could never pay an award that large.
An Enforce and Protect Act allegation asks Customs to investigate antidumping or countervailing duty evasion and pays the person who files it nothing.
A domestic producer may have evidence for a whistleblower case. We assess it with you, including any report already made, before choosing a path.
To prepare a customs fraud report, we connect what the business bought, paid and sold to what it told Customs. Useful customs fraud evidence also shows who directed the declaration and what happened when somebody questioned it.
The paperwork comes from different desks. The supplier prepares an invoice, logistics staff handle shipment records, and a customs broker may transmit the entry. The importer remains responsible for the duty. An employee inside that chain may know exactly where the accounts diverged. Former employees and customs brokers can also bring that knowledge to us.
For ocean cargo, the importer’s security filing identifies the manufacturer or supplier, origin, tariff classification, container-stuffing location and consolidator. The entry summary, Customs Form 7501, declares the value, classification and duty rate. Those records let an investigation connect a factory and shipment to the declaration that determined the bill. You do not need every customs document in hand to speak with us about what you know.
A customs description that does not fit the product can be visible to someone who sells or handles it every day. Sigma Corporation‘s catalog called its products welded outlets. Its customs forms called them steel couplings, which carried no antidumping duty. The name changed where the bill was calculated.
The court’s account describes fittings with a beveled end for welding to a pipe and a threaded end for an attachment. Island Industries, a competitor, recognized the product and investigated. Its sales manager found the relevant order and ruling within 24 hours. A Sigma executive testified that the company had imported the products for years without seeing either. Island brought the whistleblower case, pursued it after the government declined to join, and won.
A declared value that leaves out a payment connects the accounting desk to the customs entry. Supplier invoices, purchase orders, payment records and instructions to the broker can show how much the business paid and which figure reached Customs.
The apparel undervaluation complaint against Barco Uniforms makes that connection concrete. The Department of Justice alleged a double-invoicing scheme in which false entry summaries understated the value of imported garments. A former Barco employee started that case as a whistleblower, and the government joined it.
The valuation rules reach beyond the factory’s invoice. A buyer-supplied mold, known as an assist, can carry value the factory never billed when it was provided free or at reduced cost. The purchasing team may know about it while the broker sees only the finished-goods invoice.
When the buyer and supplier are related, or a trading company sits between the factory and the importer, we examine the transaction chain and the payments behind the declared price. That is where an insider’s account of who actually paid whom matters.
An origin claim the production does not support can run through several countries. Origin for the label and origin for duty treatment can follow different rules. The factory records show what was made and what work happened in each country.
Ceratizit’s case included allegations that Chinese tungsten carbide products went through Taiwan and were declared Taiwanese to avoid Section 301 tariffs. The material is used in cutting tools and other components. The same settlement also covered allegations of misclassification and unpaid duties on goods missing their country-of-origin markings.
In the investigation of Evolutions Flooring, Customs visited factories in Thailand, examined shipments with flooring specialists and analyzed import records. The Department of Justice alleged false manufacturer and origin information for multilayered wood flooring. An insider who knows which factory made the goods can identify where investigators should look for the production records.
Sales and customer records matter when an importer claims the goods are finished merchandise. DOJ alleged that Perfectus Aluminum spot-welded aluminum extrusions into supposed pallets that had no customers and were never sold. A finished product without a market supplied the claimed reason to escape the duty.
Grosfillex allegedly packaged aluminum furniture parts as sham kits. Its whistleblower complaint quoted an engineering manager’s explanation:
We are also trying to avoid to show anything that could indicate we are buying separate components. The less info is visible, the best [sic] it is. We are buying kits: not seats and backs.
Engineering manager’s words quoted in the whistleblower complaint, United States of America ex rel. Edward Wisner v. Grosfillex, Inc., paragraph 51.
The quoted message shows why the people buying components and assembling the furniture may understand the declaration better than anyone looking only at the shipping label.
A warning and the company’s response show what the business knew when it left duties unpaid. The Department of Justice alleged that Barco continued underpaying duties after an outside auditor recommended checking the calculations underlying its supplier prices. The audit gives the story a before and after: the entries, the warning and the payments that followed.
The Grosfillex allegations included leaving earlier entries uncorrected after learning they were false. That concerned a different subset of parts from the sham kits. An insider may know both when the warning arrived and what happened to those entries afterward.
A competitor can report customs fraud and bring a qui tam case, as Island Industries did. Product knowledge can expose a description that someone outside the trade would accept. Trade associations can also bring information forward: the Aluminum Extruders Council was among the whistleblowers in the Perfectus settlement.
For a competitor assessing tariff fraud evidence before contacting CBP, an implausible price or unusual shipping pattern can identify where closer examination would pay off. The World Customs Organization’s 2015 paper Mirror Analysis and Revenue Fraud, drawing on work in Cameroon and Ecuador, describes comparing trading partners’ reported quantities, weights and values to identify suspicious trade flows and guide investigations.
The purpose of mirror analysis is not to produce a document but to combat fraud.
Mirror Analysis and Revenue Fraud, World Customs Organization, 2015, p. 14.
In the paper’s method, import values below the trading partner’s reported export values, without a comparable gap in quantity, can direct investigators toward individual declarations and possible undervaluation. It then calls for those hypotheses to be compared with inspectors’ and investigators’ experience. For a competitor, the practical point is the connection between that trade pattern and the product you know: its specifications, its likely production source and the way it is sold. We assess that connection with you and identify what the entry and payment records need to establish.
The customs bill reflects the goods’ value, classification, origin and applicable duty treatment. The commercial invoice records the sale. The freight invoice, tooling agreement and royalty payments can explain the difference. We examine those records alongside the price declared to Customs.
The entry summary carries estimated duties. Customs can determine the final amount afterward. An earlier entry, the instructions behind it and a later decision to leave it uncorrected can all matter to the case.
Shipment records can also expose how an order was divided. In a 2019 settlement announcement, the Department of Justice alleged that Selective Marketplace split customer orders into smaller shipments to avoid duties under the low-value exemption then in effect. The useful comparison was between the customer’s order and the shipments created to fulfill it.
DOJ tariff fraud reporting can reach companies throughout the supply chain. The August 2025 announcement of the joint DOJ Trade Fraud Task Force describes the Department of Justice and Homeland Security pursuing customs violators through Customs’ penalty law and the False Claims Act. Entries, emails and payment records can matter to both. Its later description of the mandate reaches across the supply chain, including importers, brokers, distributors and commercial end users.
If you have already reported the conduct or know of another complaint, we assess that history with you as part of choosing the route for your case. Can a whistleblower remain anonymous? We work through that question with you and your customs fraud whistleblower counsel.
If you know which invoice reached Customs, which factory made the goods or why the declared product could never be what your business sells, speak with our whistleblower experts about building your strongest customs whistleblower case. We test the evidence, build the strategy and bring in customs fraud whistleblower counsel who know valuation, origin and antidumping cases. We stay in your corner from that first conversation through the case.