Analyst Insight: U.S. Customs and Border Protection has moved its focus to enforcement from trade facilitation in recent years. This has intensified through the many executive orders signed by the Trump Administration that include enforcement wording.  Understanding that there is a “new sheriff in town” that’s on the offensive, and has heavily funded resources, requires supply chain executives to implement strict trade compliance strategies that will hold up against CBP’s compliance initiatives.

The agency’s role continues to be revenue collection, with an additional concentration on the enforcement of regulations, identifying and prosecuting fraudulent acts by importers, and identifying instances of forced labor in the supply chain. 

CBP's enforcement takes a multi-faceted approach, with recent plans for 2025-2029 emphasizing strengthened border capabilities, enhanced trade enforcement, and improved internal organization. This includes using intelligence and data to detect high-risk activity, partnering with other agencies, and investing in its workforce to combat threats like sophisticated transnational criminal organizations and unfair trade practices. 

Companies involved in global trade have three primary responsibilities in managing their international supply chains: Due diligence, reasonable care and supervision, and control over the import process, including the management of service providers. 

While not always broadcasted, a fourth responsibility, proactive engagement, has long been an expectation of CBP.  Supply chain managers must proactively gain knowledge, remain current on government regulatory changes, and obtain training on how to execute compliant supply chains.

CBP’s focus for 2025 has been fighting fraud. This is particularly of concern due to the extensive and complicated changes to tariffs. Valuation, harmonized tariff classification, and country of origin continue to drive CBP requests for information, but now with an even greater scrutiny. 

To structure a  supply chain trade compliance program accordingly, the C-suite needs to create a culture that supports trade compliance management in the global supply chain. This needs to be structured in corporate policies, through additional oversight and the allocation of resources. 

There also needs to be a structured trade compliance program, with a person or team taking on the responsibility singularly, or as part of their overall supply chain responsibilities. This can be effectively assisted with outsourcing. 

It’s important to establish trade compliance procedures, protocols, and internal controls on how your company manages your trade compliance responsibilities. These SOP’s should include an annual audit.

As stakeholders in the global supply chain, all personnel should receive trade compliance training. This training needs to be documented and supported with annual updates.

Training may be customized, but should include the following basics: government regulations overview, internal administration of the regulations, consequences for non-compliant activities, review of all internal trade compliance protocols, and case studies.

Trade compliance management can be successfully managed by integrating robust technology resources into day-to-day operations, such as denied parties screening, tariff classification, compliant documentation administration, recordkeeping, operational applications to what we can and cannot do, and problem escalations.

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Outlook: CBP will invest significant resources to catch potential fraud in new screening systems and analysis tools, including artificial intelligence. Additionally, a new collaborative initiative between CBP and the Department of Justice has been developed to identify fraud and pursue aggressive compliance actions with both civil and criminal options and penalties.  Successfully and aggressively managing trade compliance in your global supply chain will keep you out of trouble, and have a favorable impact on resiliency and sustainability.