Chicago U.S. Attorney’s Office to Take Lead to Prosecutorial Task Force
Earlier last week, the Department of Justice (“DOJ”) announced that the U.S. Attorney’s Office for the Northern District of Illinois in Chicago will serve as a lead prosecutorial partner on the newly created Trade Fraud Task Force, “designed to bring robust enforcement against importers, purchasers, supply chain actors, and other parties who seek to defraud the United States” according to the accompanying press release. U.S. Attorney Andrew Boutros was part of the announcement, seemingly chosen due to leading the largest food fraud prosecution in U.S. history which included, “27 corporate and individual defendants across multiple indictments, with losses totaling approximately $260 million” during his previous tenure in the office as an Assistant United States Attorney. The Task Force will pursue enforcement through duty and penalty collection under the Tariff Act of 1930, civil actions under the False Claims Act, seizures/forfeitures, and parallel criminal prosecutions when applicable. The selection of Chicago is also being touted as a good strategic court due to being one of the nation’s largest inland ports, providing broad venue opportunities since any importation offense may be prosecuted in any district through which goods travel, as they often do through the Chicagoland at some point.
Indonesian Jewelry Company Charged with $86 Million Tariff Evasion Scheme
If the Chicago announcement tells us what is coming, a recent case out of New Jersey may offer some insight into what we can expect as the task force gets off the ground. In November, federal prosecutors criminally charged Indonesian jewelry manufacturer PT Untung Bersama Sejahtera, known as “UBS Gold,” its co-owner, and two employees with orchestrating a sophisticated, multi-year scheme to illegally evade more than $86 million in U.S. customs duties and tariffs on over $1.2 billion worth of jewelry shipped to American customers. According to the indictment, when jewelry imports from Indonesia became subject to new duties starting in 2021, the company tried to get around the duties by shipping the goods to Jordan, which has a Free Trade Agreement with the U.S., and then falsely claiming the jewelry was actually made in Jordan before shipping it to the U.S. When the U.S. eventually imposed broader tariffs on goods from both Indonesia and Jordan in 2025, according to the indictment, the defendants allegedly pivoted again and began shipping scrap gold from the U.S to Jordan under the pretense that it needed assembly or finishing there. Instead, the scrap gold was swapped out for finished jewelry manufactured in Indonesia, which was then shipped back to U.S. customers with fraudulent documentation claiming the goods had been made in the U.S., a designation that would eliminate all applicable tariffs. “This case underscores HSI’s unwavering commitment to protecting the integrity of U.S. trade and ensuring that those who attempt to evade lawful duties or circumvent U.S. laws are held accountable,” said Homeland Security Investigations (HSI) Newark Special Agent in Charge Michael S. McCarthy. Should they be found guilty, the wire fraud conspiracy charge carries a maximum of 20 years in prison and a maximum fine of either $250,000 for the individual defendants or $500,000 for the corporate entity or twice the gain or loss from the offense, whichever is greater.
The UBS Gold prosecution is part of a broader, accelerating federal push against trade and customs fraud. The announcement of the Trade Fraud Task Force led by a leading prosecutor who is intimately familiar with how these seemingly sophisticated schemes work makes clear that this case is just a preview of enforcement actions will look like moving forward.
