Every fraudulent customs declaration can eventually become a financial transaction. And as investigators connect invoices, ownership records and money flows across global supply chains, that is a connection that’s becoming more consequential for the financial institutions facilitating and underwriting global commerce.
The U.S. Department of Justice (DOJ) announced a permanent section dedicated to trade-related offenses for financial institutions in the government’s joint resource guide outlining enforcement and compliance expectations entitled “A Resource Guide to Trade Fraud Enforcement.”
The DOJ’s Trade Fraud Task Force, which operates with the Department of Homeland Security, also in recent weeks surpassed $1 billion in civil and criminal recoveries, penalties, forfeitures and publicly charged losses in less than a year.
As federal investigators pursue tariff evasion, false declarations, transshipment and forced-labor violations across supply chains, the financial institutions processing the associated payments are moving closer to the enforcement perimeter.
After all, an importer that understates the value of goods must still pay its supplier. A company disguising a product’s country of origin leaves behind invoices, accounts and shipping records, while a distributor selling illegally imported merchandise eventually receives and moves the proceeds.
See more: Federal Approval No Longer Guarantees CFOs a Green Light
Trade Enforcement Follows the Money All the Way to the Bank
Banks already review invoices, purchase orders, bills of lading and inspection records in trade-finance transactions. Financial-crime teams also monitor for trade-based money laundering, in which criminals manipulate the price, quantity or description of goods to move illicit value. Customs fraud is different. The money itself may be legitimate while the product classification, valuation or country of origin is false.
Prosecutors can use the False Claims Act, tariff statutes, criminal fraud laws, conspiracy charges, seizures and forfeitures against importers and other parties that misrepresent products or evade trade restrictions. The initiative reflects a broader shift in posture: Customs violations are increasingly being treated not as administrative errors but as economic crimes.
The central compliance question is not whether every customs discrepancy should generate an alert. It is whether banks will increasingly be expected to recognize when trade documentation and payment activity tell different stories. Payment amounts can reveal the actual economics of an import. Account ownership can expose relationships among suppliers, intermediaries and importers. Transaction histories may show invoice splitting, unusual routing or payments inconsistent with goods declared at the border.
Consider an importer that declares a shipment at $500,000 while its bank records a $900,000 supplier payment. The difference could reflect freight, insurance, services or several combined orders. It could also indicate undervaluation. The enforcement opportunity lies in reconciling those mismatches. The difficulty is that banks rarely possess complete customs records, while customs agencies do not necessarily see every related payment.
Research by PYMNTS Intelligence shows that 85% of merchants said their main fraud-related challenge is preventing these incidents without harming the customer experience. And 51% of global eCommerce merchants said they expected fraud-management staffing costs to stay flat or decrease, even as 63% plan to spend more on fraud-prevention technology.
See also: Innovation Keeps Expanding Compliance for Mid-Market Firms
Banks Have the Fraud Data, but Not the Execution Context
Trade monitoring remains difficult because product descriptions are inconsistent, prices fluctuate and transactions often involve multiple legitimate intermediaries. Effective detection would require combining payments data with tariff codes, beneficial ownership, origin information, shipping routes and historical pricing. Much of that context sits outside a standard payment message. And technology cannot reconcile records it cannot access, nor can it infer criminal intent from a discrepancy alone.
“Many of the financial institutions, the larger behemoths, have really, over the last several years, come to the conclusion that they can’t build out most of the enhancements quick enough,” Boost Payment Solutions Founder and CEO Dean M. Leavitt told PYMNTS in May. “Companies like ours that are very agile, that have our ears constantly to the ground in the marketplace and know what the market needs, and maybe what the market needs next year or the year after. It’s working quite well.”
Washington has not created a bank-reporting regime specifically for customs fraud, and institutions should not treat every tariff dispute as evidence of a crime. But the direction is clear: Investigators are connecting documentation, ownership and money flows across entire supply chains.
Read more: Fed Study Shows B2B Payments Are Becoming a Cost-Per-Event Problem
The task force’s $1 billion milestone shows that duty evasion is no longer being treated as a rounding error in global commerce. For financial institutions, the next question is whether moving the money will also mean greater responsibility for recognizing the fraud behind it.
Sixty-eight percent of financial institutions increased their fraud-detection budgets year over year, according to the 2025 “State of Fraud and Financial Crime in the United States,” a PYMNTS Intelligence report produced in collaboration with Block. That spending comes as 46% of institutions report increasingly sophisticated fraud schemes, up from 35% a year earlier.
Behavioral analytics were used by 70% of institutions surveyed, while 61% reported using machine learning or artificial intelligence. Those technologies allow fraud systems to compare a transaction with a customer’s previous behavior and look for combinations of unusual activity rather than relying only on fixed rules or authentication.
For all PYMNTS B2B coverage, subscribe to the daily B2B Newsletter.
