Between January 20 and December 15, 2025, U.S. Customs and Border Protection (CBP) collected a record $200 billion in tariff revenue, putting a sharp spotlight on the enforcement vigor and increased scrutiny that the current administration is applying to cross-border trade. With import tariffs now sitting at the top of enforcement priorities for the U.S. Department of Justice (DOJ), importers and logistics-intensive businesses without a bullet-proof compliance strategy and a strong due diligence process have serious cause for concern.
The government is pulling out all the stops to maximize tariff revenue and thwart bad actors attempting to circumvent tariffs. A new cross-agency Trade Fraud Task Force (TFTF) brings together DOJ's Civil and Criminal Divisions, Homeland Security and CBP to "aggressively pursue enforcement actions against any parties who seek to evade tariffs and other duties, as well as smugglers who seek to import prohibited goods into the American economy." DOJ has also expanded its whistleblower pilot program to cover "trade, tariff and customs fraud by corporations."
As part of that effort, an e-Allegations program enables the trade community and general public to report suspected trade violations to CBP via an electronic portal. DOJ and CBP have their work cut out for them — fraudsters are executing carefully calculated schemes to evade duties and tariffs, often at substantial scale. For example, an Indonesian jewelry company was recently charged with running a years-long scheme to evade more than $86 million in customs duties and tariffs on $1.2 billion of jewelry imports.
From a supply chain perspective, this tightening enforcement environment makes supplier transparency beyond tier 1, origin verification and HTS classification discipline strategic imperatives rather than back-office tasks. Importers will need to reassess first sale valuation practices, transshipment risk maps and use of foreign trade zones. Failing to do so risks retroactive tariff payments, treble damages and reputational harm that can land hard on the balance sheet.
