Top-Down Enforcement: From the President to CBP and Everywhere in Between

Trade enforcement is no longer just a matter of what happens at the port. Since the America First Trade Policy, enforcement has expanded beyond CBP to a growing number of federal agencies, each with its own authorities, penalties, and timelines, and increasingly sharing information and coordinating enforcement efforts. 

This webinar will examine how this whole-of-government approach is changing the risk landscape for importers. Attendees will learn where the most significant enforcement risks now lie, which pending deadlines and developments require immediate attention, and how stronger documentation, supply chain mapping, supplier verification, and reasonable-care practices can help demonstrate compliance when imports come under scrutiny. 

• How the America First Trade Policy and E.O. 14215 widened enforcement from the traditional CBP-centered model to a whole-of-government approach. 

• Increasing criminal and civil exposure due to the DOJ’s new priorities on trade and customs fraud, the DOJ-DHS Trade Fraud Task Force, and the False Claims Act. 

• Changing CBP’s priorities to heighten scrutiny on country of origin, valuation, classification, AD/CVD, forced labor, and China transshipment.  

• Actions from agencies importers often overlook, including FCC import bans, CPSC eFiling and enforcement, Commerce and AD/CVD, and the FMC’s proposed actions. 

• The tariff toolbox: what to expect from Sections 232, 301, 338 and 122 actions, as well as an update on the pending litigation and how to preserve refund rights. 

• The changing importer-of-record obligations due to Executive Order 14411. Topics include U.S. versus foreign IOR status, “good standing” registries, higher bonds, and CBP’s proposed rules on supply chain visibility and traceability. 

• Best practices for how to demonstrate compliance: documentation is the best defense