$500 idea · Pattern break · Edition 059
Justice priced the entire national supply of trade-fraud leads at 24 hours.
At 91 FR 72922, published this morning, 12 November 2026, the Justice Department’s National Fraud Enforcement Division gave notice of a new collection — the “Global Trade & Commerce Enforcement Section Lead Intake Form,” OMB 1105–0NEW, signed Darwin Arceo and dated 9 November 2026. The section “will be using the form to provide investigative leads in the trade fraud space,” and “The form will not be posted on a website but provided directly to inter-agency partners, non-governmental organizations, attorneys for industry, and other sources that generate leads.” Its own estimate of how much information that channel will carry: “Total Estimated Number of Respondents: 144,” “Estimated Time per Respondent: 10 minutes,” “Frequency: Once,” “Total Estimated Annual Time Burden: 1,440 minutes” — 24 hours — with “Total Estimated Annual Other Costs Burden” left blank. The other channel, the one open to anybody, took 1,297 filings last year and paid $330,358,218.
When an importer pays less duty than it owes, nobody is robbed in a way anyone can see: the money is simply never collected, and the government usually finds out because somebody tells it. An old federal law lets that somebody sue on the government’s behalf, in secret, and keep a share of whatever is recovered — the government may take the case over or leave it with the person who brought it. The Justice Department has now built a second, separate channel for the same kind of information, and published how much of it it expects to receive. Today’s edition is about what the United States pays for a trade-fraud tip, and how long it makes you wait to be paid.
Start with what the notice is, because it is small and it is not nothing. A Paperwork Reduction Act notice is an agency telling the public how many pieces of paper it expects and how long each will take, and this one announces a part of the Justice Department that did not exist under this name a year ago: the National Fraud Enforcement Division, and inside it the Global Trade & Commerce Enforcement Section. The form is “Voluntary.” Its “Affected Public” is “Primary: Government, State, or Tribal.” The section “will be working with several different law-enforcement agencies to vet, triage, and deconflict the information they receive.” Comments run 60 days, to 11 January 2027.
Now read the three numbers together, because they are the finding. 144 respondents. 10 minutes each. 1,440 minutes a year. The United States is in the largest tariff-enforcement push in a century, and the division built to run it has told the Office of Management and Budget that the national flow of trade-fraud leads into its new intake is 24 hours of somebody’s time — three working days, spread across every agency, every trade association and every industry lawyer in the country. The field where that effort would be priced in money is printed and left empty.
Against it, the channel the Justice Department did not build and cannot close. 31 U.S.C. § 3730(b)(1): “A person may bring a civil action for a violation of section 3729 for the person and for the United States Government.” § 3730(b)(2): the complaint “shall be filed in camera, shall remain under seal for at least 60 days, and shall not be served on the defendant until the court so orders,” served on the Government with “written disclosure of substantially all material evidence and information the person possesses.” § 3730(d)(1) pays “at least 15 percent but not more than 25 percent of the proceeds” where the Government takes the case over, and § 3730(d)(2) pays “not less than 25 percent and not more than 30 percent” where it does not. The Department’s own Fraud Statistics — Overview for 1 October 1986 to 30 September 2025 records 1,297 new qui tam matters in FY2025 against 401 government-initiated ones, $5,340,006,336 of qui tam settlements and judgments, and $330,358,218 of relator share awards paid.
So the private form expects 144 leads where the public statute drew 1,297 suits — 11.1025% — and the public one came with a cheque. That is the whole asymmetry, and it is published in two documents nobody reads beside each other.
What the United States actually pays is not a range in a statute; it is three numbers from three settlements, and they agree to within a point. Perfectus Aluminum, 12 May 2026, $549.5 million, on 2.2 million aluminium extrusions declared as finished “pallets” — “the relator share will be 17.5 percent of the settlement proceeds that are returned to CBP,” relators Mike Rapport, Eric Shen and the Aluminum Extruders Council, docket 5:15-cv-00712 (C.D. Cal.). Ceratizit USA, 18 December 2025, $54.4 million on tungsten carbide transshipped through Taiwan, relator Mark Stover, approximately $9,750,000 — 17.9228% — docket 2:22-cv-12291 (E.D. Mich.). Everlight Electronics, 5 August 2026, $5.15 million on LEDs, relator Tao Wang, a former employee, $876,146 — 17.0125% — docket TDC-21-cv-1607 (D. Md.). Mean 17.4784%. Across the whole thirty-nine years the Department publishes, relators have taken $9,963,696,036 of $60,972,925,646 — 16.3412%.
Here is the non-consensus reading, and the arithmetic for it is in the statute. Everyone reads tariffs from the importer’s side, as a cost. Read them from the other side. 31 U.S.C. § 3729(a)(1) makes a violator liable for “3 times the amount of damages which the Government sustains” plus a civil penalty per claim, held for 2026 at $14,308 to $28,618; § 3729(a)(1)(G) reaches anyone who “knowingly conceals or knowingly and improperly avoids or decreases an obligation to pay or transmit money” to the Government, which is what an unpaid duty is; and § 3729(b)(1) needs “no proof of specific intent to defraud.” At full trebling, a 17.5% relator share is 52.5% of the duty the importer never paid, and the realised 16.3412% is 49.0235%. The United States will pay roughly half of an evaded duty to whoever names the evader — and the division that runs the enforcement has just told OMB it expects its own tip channel to generate twenty-four hours of paperwork a year.
The door is a court clerk’s fee. The District Court Miscellaneous Fee Schedule effective 27 May 2026 prints “Filing Fee for Civil Case” at $405.00 and notes that it “Includes a $55.00 administrative fee” — so $350 of statute and $55 of administration, 81% of a $500 budget, $95 left. There is nothing else to pay: no licence, no examination, no registration, no bond, no fee for the lead intake form and no fee for the § 3730(b)(2) disclosure. In practice relator’s counsel advances the $405, because the one thing you may not do is file it yourself.
And the target arithmetic is the strangest this series has run, because it has a time axis. $5,000 a month kept after 2026 federal tax — single filer, ordinary income, standard deduction $16,100, no self-employment tax — needs $65,704.5455 a year, $5,704.5455 of tax, an effective 8.6821%. At the realised 16.3412% share and an assumed 40% contingency fee, that is $670,132.57 of recovery to the United States for every year you wait, and the three cases above waited 3, 5 and 11 years from docket to settlement. No published contingency rate for False Claims Act relator counsel was found on this run, so the 40% is an assumption, and the playbook is where it is tested.
The evidence
11 findings“Total Estimated Number of Respondents: 144” and “Estimated Time per Respondent: 10 minutes”
“AGENCY: National Fraud Enforcement Division, Department of Justice.” “ACTION: 60-Day notice.” The abstract: “The Global Trade & Commerce Enforcement Section (GTCES) will be using the form to provide investigative leads in the trade fraud space,” and “The GTCES will be working with several different law-enforcement agencies to vet, triage, and deconflict the information they receive.” Then the sentence that defines the channel: “The form will not be posted on a website but provided directly to inter-agency partners, non-governmental organizations, attorneys for industry, and other sources that generate leads.” “Obligation to Respond: Voluntary.” “Affected Public: Primary: Government, State, or Tribal.” “Frequency: Once.” “Total Estimated Annual Time Burden: 1,440 minutes.” “Total Estimated Annual Other Costs Burden” is printed with no value. Signed Darwin Arceo, Department Clearance Officer for PRA. Comments run 60 days, to 11 January 2027. What is not in it. The notice lists no data fields, no definition of a qualifying lead, and no statement of what a lead source receives in return — because the answer to the last one is in a different statute.
1,297 new qui tam matters in FY2025, $330,358,218 of relator share awards
FY2025: 401 new non-qui-tam matters and 1,297 new qui tam matters, $5,340,006,336 of qui tam settlements and judgments, $330,358,218 of relator share awards. Cumulative FY1987–FY2025: 18,253 new qui tam matters, $60,972,925,646 of qui tam settlements and judgments, $9,963,696,036 of relator share awards. How this was read. The table’s columns are positional in the published PDF and were matched by position and by checking that the subtotals reconcile; the figures above are therefore verified as to the document and derived as to which column is which. Note also the cohort problem that every ratio in this edition carries: awards paid in a year belong to suits filed years earlier, so $330,358,218 and 1,297 are not two halves of the same fraction.
“at least 15 percent but not more than 25 percent of the proceeds”, or 25 to 30 if the Government declines
(b)(1): “A person may bring a civil action for a violation of section 3729 for the person and for the United States Government,” and “The action shall be brought in the name of the Government.” (b)(2): the complaint “shall be filed in camera, shall remain under seal for at least 60 days, and shall not be served on the defendant until the court so orders,” served on the Government with “written disclosure of substantially all material evidence and information the person possesses,” the Government having 60 days to elect to intervene. (b)(5), the first-to-file bar: “no person other than the Government may intervene or bring a related action based on the facts underlying the pending action.” (d)(1) and (d)(2) set the share, with public-disclosure cases capped at “in no case more than 10 percent.” (e)(4)(A), the gate that decides who may play: the court “shall dismiss” where “substantially the same allegations or transactions” were publicly disclosed in a federal hearing, a federal report or audit, or “from the news media,” unless the relator is “an original source.”
“3 times the amount of damages which the Government sustains”, penalties $14,308–$28,618
§ 3729(a)(1) makes a violator “liable to the United States Government for a civil penalty of not less than $5,000 and not more than $10,000,” as adjusted for inflation, “plus 3 times the amount of damages which the Government sustains because of the act of that person.” (a)(1)(G) reaches one who “knowingly makes, uses, or causes to be made or used, a false record or statement material to an obligation to pay or transmit money or property to the Government,” or who “knowingly conceals or knowingly and improperly avoids or decreases” such an obligation — the reverse false claim, which is the shape every unpaid duty takes. (b)(1) defines “knowingly” to include “deliberate ignorance” and “reckless disregard” and to “require no proof of specific intent to defraud.” Chip. The statute is verified; the 2026 penalty range of $14,308 to $28,618 is read from an agency’s own Federal Register notice of 21 May 2026 stating that the § 3729(a) amounts “will remain” at those figures — the Justice Department’s own 2026 adjustment of 28 CFR § 85.5 was not retrieved on this run.
“the relator share will be 17.5 percent of the settlement proceeds that are returned to CBP”
Perfectus Aluminum Inc., Perfectus Aluminum Acquisitions LLC and four affiliated warehousing companies “agreed to pay a total of $549.5 million” over “more than 2.2 million aluminum extrusions in the form of ‘pallets’” imported from China “from July 2011 through June 2014” and presented to CBP “as finished merchandise not subject to antidumping and countervailing duties.” Relators Mike Rapport, Eric Shen and the Aluminum Extruders Council; United States ex rel. Rapport v. PengCheng Aluminum Enterprise Inc., No. 5:15-cv-00712 (C.D. Cal.), with a parallel criminal case at No. 2:19-cr-00282-GK. Quoted: Acting Attorney General Todd Blanche, Assistant Attorney General Brett A. Shumate of the Civil Division, First Assistant U.S. Attorney Bill Essayli, and Susan S. Thomas of CBP’s Office of Trade. The Civil Division “coordinated this action through the Department of Justice’s Trade Fraud Task Force.” Read the share carefully. It is 17.5% of proceeds returned to CBP, which is a subset of $549.5 million, so the relators’ take is at most $96,162,500 and the edition never treats it as exactly that.
Relator Mark Stover receives approximately $9,750,000 of $54.4 million
Tungsten carbide products from China allegedly transshipped through Taiwan and declared Taiwanese “from Aug. 2020 to Mar. 2024” to avoid Section 301 tariffs, with a separate misclassification allegation running “from June 2015 to Mar. 2024” and unpaid marking duties. United States ex rel. Stover v. Ceratizit USA, et al., No. 2:22-cv-12291 (E.D. Mich.). Quoted: Brett A. Shumate, Jerome F. Gorgon Jr., U.S. Attorney for the Eastern District of Michigan, and CBP Commissioner Rodney S. Scott. The release records that “On Aug. 29, 2025, the Department of Justice launched a cross-agency Trade Fraud Task Force” and that “The Justice Department encourages whistleblowers to utilize the qui tam provisions of the False Claims Act.” Derived: $9,750,000 ÷ $54,400,000 = 17.9228%; docket year 2022 to settlement 2025 is 3 years, and the exact filing date was not retrieved.
Relator Tao Wang, a former employee, receives $876,146
Everlight Electronics and Everlight Americas allegedly “knowingly misrepresented the country of origin on Chinese-manufactured LEDs” routed through Taiwan from July 2018 to January 2022 to avoid Section 301 tariffs, and from January 2022 to November 2025 allegedly failed to segregate Chinese-origin LED dice in Taiwanese manufacture. United States ex rel. Wang v. Everlight Electronics Co., Ltd., No. TDC-21-cv-1607 (D. Md.). U.S. Attorney Kelly O. Hayes and CBP’s Susan S. Thomas quoted; allegations only, no determination of liability. Why this one matters most. It is the smallest verified customs relator award located on this run and therefore the nearest thing to a floor: $876,146 ÷ $5,150,000 = 17.0125%, on a case whose docket year is 2021 and which settled in 2026 — 5 years, exact filing date not retrieved.
“Filing Fee for Civil Case” $405.00, including “a $55.00 administrative fee”
The schedule prints “Filing Fee for Civil Case” at $405.00 and the note that it “Includes a $55.00 administrative fee for filing a civil action, suit or proceeding,” effective 27 May 2026. Derived: $405 − $55 = $350 of statutory fee; $405 ÷ $500 = 81% of the budget, $95 left. Nothing else in the route carries a published price: the lead intake form is free and voluntary, the § 3730(b)(2) disclosure has no fee, and there is no licence, examination, registration or bond anywhere in § 3730. Not verified. No published contingency-fee rate for False Claims Act relator counsel was located on this run, and in practice counsel advances the $405.
Standard deduction $16,100, and a 12% bracket to $50,400
For taxable years beginning in 2026, unmarried individuals other than surviving spouses and heads of household: standard deduction $16,100; 10% to $12,400; $1,240 plus 12% of the excess over $12,400 to $50,400; $5,800 plus 22% to $105,700; $17,966 plus 24% to $201,775; $41,024 plus 32% to $256,225; $58,448 plus 35% to $640,600; $192,979.25 plus 37% above. Two assumptions carry the solve. A relator award to a person not in the trade or business of bringing such actions is treated here as ordinary income not subject to self-employment tax, and the deductibility of the contingency fee is not resolved — both are not verified and both are large. No state or city income tax is modelled.
$111.8 billion of duties, taxes and fees on $3.35 trillion of imports — in FY2022
CBP’s public trade-statistics page reports $111.8 billion collected in duties, taxes and fees, $3.35 trillion of import value and 39.1 million entry summaries, for fiscal year 2022, and carries “Last Modified: Sep 19, 2024.” That is the finding inside the finding. The agency at the centre of the largest tariff programme in a century has not refreshed the public page that states how much it collects in more than two years, so this edition cannot and does not put a current denominator under any of its ratios. Every share quoted here is a share of the Justice Department’s own published enforcement figures, never of the national duty base.
The channel, the share, the door and the wait, shown
The channel. 144 × 10 = 1,440 minutes = 24 hours; 144 ÷ 1,297 = 11.1025%; 1,297 ÷ 980 = 1.3235, the increase on the previous record; 5,340,006,336 ÷ 6,888,000,000 = 77.5262% of FY2025 recoveries came from qui tam. The share. 9,750,000 ÷ 54,400,000 = 17.9228%; 876,146 ÷ 5,150,000 = 17.0125%; with Perfectus’s stated 17.5% the mean of the three is 17.4784%; 9,963,696,036 ÷ 60,972,925,646 = 16.3412%; 3 × 17.5% = 52.5% and 3 × 16.3412% = 49.0235% of an evaded duty, at full trebling. The stock. 9,963,696,036 ÷ 18,253 = $545,866.2157 of relator award per qui tam matter ever filed — a mean over an extreme distribution and over unresolved cases, not an expectation — which is 1,347.8178 times the $405 filing fee and 8.3079 years of this edition’s target; 330,358,218 ÷ 1,297 = $254,709.4973 per suit filed in FY2025, across mismatched cohorts. The door. $405 − $55 = $350; 405 ÷ 500 = 81%; $95 left. The target. Single filer, 2026, ordinary income, no self-employment tax: gross $65,704.5455; less the $16,100 standard deduction, taxable $49,604.5455, inside the 12% bracket; tax $1,240 + 0.12 × $37,204.5455 = $5,704.5455; kept $60,000.00, $5,000.00 a month, effective 8.6821%. The wait. 65,704.5455 ÷ 0.163412 = $402,079.54 of recovery per year waited with no fee; ÷ 0.6 = $670,132.57 with an assumed 40% contingency; at 3, 5 and 11 years that is $2,010,397.72, $3,350,662.87 and $7,371,458.32; 54,400,000 ÷ 2,010,397.72 = 27.0593, 5,150,000 ÷ 3,350,662.87 = 1.5370, 549,500,000 ÷ 7,371,458.32 = 74.5443. Plot. X(Y) = 86 + 574Y ÷ 12; Y(V) = 330 − 250V ÷ 8,000,000.
The ladder
From $500 to $5,000 a monthSix rungs from $405 — 81% of the budget, and the regulator’s share of it is zero — to $5,000 a month, on a statute that pays 15 to 30 per cent of a trebled recovery and a division that has just told OMB it expects 144 tips a year.
-
Read the notice as a supply estimate, because that is what a PRA notice is
91 FR 72922 is not a policy. It is the Justice Department telling the Office of Management and Budget how much information it expects: 144 respondents, 10 minutes each, 1,440 minutes a year, cost burden left blank, and a form that “will not be posted on a website.” Three working days of national effort, routed by invitation to “attorneys for industry.” That is the government’s own estimate of how thin the lead supply is.
144 × 10 min = 1,440 min = 24 hours · comments close 11 Jan 2027 -
Price the other channel, which is open, pays cash, and nobody needs to invite you to it
§ 3730(b)(1) lets any person sue “for the person and for the United States Government.” § 3730(d) pays 15–25% where the Government intervenes and 25–30% where it does not. In FY2025 that channel drew 1,297 suits — 1.3235× the previous record of 980 — and paid $330,358,218. The new private form expects 144, which is 11.1025% of it.
1,297 filed · $330,358,218 paid · 144 ÷ 1,297 = 11.1025% -
Learn what the share actually is, because three settlements agree to within a point
Perfectus, $549.5M, “17.5 percent of the settlement proceeds that are returned to CBP.” Ceratizit, $54.4M, Mark Stover, $9,750,000 — 17.9228%. Everlight, $5.15M, Tao Wang, $876,146 — 17.0125%. Mean 17.4784%, against a thirty-nine-year realised 16.3412%. The statutory band is wide; the observed one is not.
17.5% · 17.9228% · 17.0125% · all-time 16.3412% -
Do the trebling, because that is where the number stops looking like a tip jar
§ 3729(a)(1) is “3 times the amount of damages” plus $14,308 to $28,618 a claim, and (a)(1)(G) catches anyone who “knowingly conceals or knowingly and improperly avoids or decreases an obligation” to pay the Government — an unpaid duty exactly. At full trebling a 17.5% share is 52.5% of the duty evaded. The United States pays about half of what the importer kept.
3 × 17.5% = 52.5% of the evaded duty · no specific intent required -
Count the door, then count the thing the door does not buy
$405.00, “Filing Fee for Civil Case,” including “a $55.00 administrative fee” — 81% of the budget, $95 left, and $0 of licence, examination, registration or bond anywhere in the statute. What it does not buy is the only input that matters: § 3730(e)(4)(A) makes the court “dismiss” a case built on what was already public unless you are “an original source,” and § 3730(b)(5) gives the whole subject to whoever filed first.
$405 door · § 3730(e)(4) original source · § 3730(b)(5) first to file -
Do the target arithmetic on a time axis, then read the verdict, which is Switch
$5,000 a month after 2026 federal tax on ordinary income needs $65,704.5455, tax $5,704.5455, effective 8.6821%. At the realised 16.3412% net of an assumed 40% fee, that is $670,132.57 of recovery for every year of wait, and these cases waited 3, 5 and 11. Since 1987: 18,253 matters filed, $9,963,696,036 paid — $545,866.2157 each, over a distribution where one case is 74.5443× the bar.
$65,704.5455 ÷ 0.163412 ÷ 0.6 = $670,132.57 per year waited
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