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Larry Ordet

Telephone: 305.894.1003
E-mail: lordet@strtrade.com

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Customs Enforcement Under Trump, 2020: Exercising Reasonable Care, Performing Post-Entry Reviews, and Filing Prior Disclosures

The Trump administration is further tightening its import enforcement efforts, which began in early 2017 with the issuance of executive orders directing federal authorities to step up the collection of antidumping and countervailing duties and the prosecution of trade and customs law violations.  In 2020, the Administration has promised to vigorously enforce U.S. trade agreements and will focus on compliance of imports involving or potentially involving Sections 232 (aluminum/steel) and 301 (China).  With this renewed enforcement emphasis, importers should act quickly to review their processes, practices, and entry data to identify potential trade compliance risks. In addition, every company import manager, internal auditor, in-house counsel, and compliance officer needs to understand the options for conducting self-audits and filing prior disclosures, which can be effective tools in protecting businesses (as well as their officers, directors, and employees) from harsh penalties.

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