One enforcement announcement is a headline. A succession of directives, new enforcement structures, operational guidance, and major cases is a business issue.
Since June 2026, developments across U.S. Customs and Border Protection, the Department of Justice, and the Department of Commerce have reinforced a consistent message: customs compliance deserves executive attention, not just attention when a shipment stops moving.
Taken together, these developments point toward more coordinated enforcement and greater scrutiny across the supply chain.
Consider the signals.
June: An explicit direction to strengthen customs enforcement
The June 3, 2026, executive order, Strengthening Customs Enforcement, directed action on importer accountability, bonding, enhanced vetting, supply-chain disclosures, increased audits, broker due diligence, and penalties. It also prioritized enforcement involving forced labor, misclassification, undervaluation, and illegal transshipment.
These were directions for agency action. They were not evidence that every contemplated requirement immediately took effect.
The distinction matters. But so does the breadth of the agenda.
This was not a directive focused on one commodity or one evasion technique. It outlined a wider approach to who imports, what information supports the entry, and how compliance failures should be addressed.
June: Forced-labor expectations became more clearly documented
On June 12, CBP released consolidated Forced Labor Enforcement Operational Guidance for Importers, covering Section 307, the Uyghur Forced Labor Prevention Act, and the Countering America’s Adversaries Through Sanctions Act.
The guidance includes enforcement process maps, detention and exclusion procedures, recommended supply-chain documentation for high-priority sectors, and practical due-diligence examples. CBP specifically encouraged importers to review the guidance and conduct supplier due diligence before importing.
For management, the practical question should be straightforward:
Could we produce the evidence needed to support our supply chain, or would we begin looking for it only after a detention?
July: Enforcement acquired additional institutional backing
On July 14, DOJ announced the creation of the Global Trade & Commerce Enforcement Section, a dedicated section focused on criminal import, trade, and related fraud offenses. DOJ and DHS also released a joint Resource Guide to Trade Fraud Enforcement, explaining relevant requirements and civil and criminal enforcement approaches.
My reading: this is a signal of institutional commitment, not simply another warning to the trade community.
July: The numbers made the enforcement message tangible
In the same July 14 announcement, DOJ reported that the Trade Fraud Task Force had surpassed $1 billion in combined civil and criminal recoveries, penalties, forfeitures, and publicly charged losses.
That figure should not be described as $1 billion collected. It combines different categories.
DOJ also reported that CBP had assessed more than $2.1 billion in commercial trade penalties during the fiscal year to that point. Assessments likewise are not necessarily collections.
Even with those important distinctions, these are substantial enforcement indicators.
July: Country-of-origin allegations produced criminal cases
DOJ’s July announcement also described two gold-jewelry prosecutions involving allegedly false country-of-origin declarations. The government alleged approximately $38 million in avoided duties in one scheme and approximately $13.6 million in another. These were charges and allegations, not findings of guilt.
The compliance takeaway is a question every sourcing team should be prepared to answer:
What evidence supports the origin we declare, not merely the country from which the goods ship?
July: Commerce-to-CBP collaboration delivered an EAPA determination
On July 31, Commerce announced that CBP had determined the previous day that 14 importers evaded antidumping duties on carbon and alloy steel threaded rod from India.
The case followed Commerce’s first EAPA allegation submitted to CBP in August 2025. According to Commerce, the importers improperly claimed eligibility for a zero-percent all-others rate instead of the rate assigned to their producer or exporter. The agencies identified millions of dollars in uncollected duties.
This example deserves attention because the issue was not simply whether the product was subject to an order. It was whether the correct producer/exporter rate had been applied.
October: A civil duty-and-penalty action named both the company and its CEO
On October 7, DOJ announced a civil lawsuit against Uni-Tile & Marble Inc. and its chief executive officer, seeking $67.9 million in unpaid duties and $222.5 million in fraud penalties, approximately $290.4 million combined.
The government alleges transshipment, undervaluation, and merchandise misdescription involving shell companies and 503 entries. The civil action follows criminal charges announced in December 2025. The civil claims remain allegations, with no determination of liability.
The executive-accountability point is significant: the government is pursuing both the business and its CEO in this case. That does not establish automatic personal liability for executives, but it does make this more than a corporate duty-reconciliation story.
The exposure does not necessarily stop with the importer
DOJ has explicitly described the Trade Fraud Task Force’s scope as extending across the supply chain, including brokers, downstream distributors, industrial and commercial end-users, and other actors who knowingly profit from illegally imported merchandise.
For businesses that buy imported goods without serving as importer of record, that should prompt a review of supplier oversight and escalation procedures. It should not prompt an assumption that customs issues belong exclusively to someone else.
What should leadership do with these signals?
Rather than treating each announcement as an isolated event, I would use them to organize a practical management review:
- Test entry accuracy. Select actual transactions and examine classification, valuation, origin, and applicable additional duties.
- Validate sourcing changes. Require evidence supporting claimed changes in manufacturing location or origin.
- Review AD/CVD controls. Examine scope analysis, producer/exporter identification, and rate selection.
- Challenge supplier documentation. Ask whether records are complete, consistent, and retrievable.
- Evaluate broker oversight. Review instructions, exception handling, and the process for correcting errors.
- Practice responding. Run a mock information request or detention-response exercise.
- Assign executive ownership. Make sure material findings reach someone with authority to fund remediation.
These are proposed management actions. They are not a substitute for a broader compliance program. And that program does not stop at making sure your CBP Form 5106 is correct, or at breathing easier because your IEEPA refunds came through.
Some companies are taking action. Just look at the number of trade compliance jobs waiting to be filled on LinkedIn. It is a good sign, but it pales in comparison to the number of companies that have not taken the first step.
The bottom line
The developments since June support a broader conclusion: trade compliance should be treated as a governance and financial-risk issue, not simply a shipment-processing function. Policy direction, agency coordination, enforcement infrastructure, and individual cases are all part of that picture.
The question for leadership is not:
“Do we have a trade-compliance policy?”
It is:
“Can we demonstrate, with records, controls, and tested processes, that our program works?”
