July 2025

High Tariffs, High Stakes: The Rise in Customs Fraud and Enforcement Risk

As tariffs climb and global trade grows more complex, a growing number of importers are testing the limits, or outright breaking the law, to reduce or avoid duty payments. U.S. enforcement agencies, including Customs and Border Protection (CBP) and the Department of Justice (DOJ), have made it clear that customs fraud will not be tolerated and is a top enforcement priority. 

High Tariffs = High Incentive to Cheat

High tariffs create an incentive to cheat. Whether it’s through misclassifying goods, undervaluing imports, or using deceptive transshipment routes, some companies are turning to creative or outright illegal strategies to reduce their tariff liability.

This is not theoretical, we’ve seen it before. During the U.S.–China trade war of 2018–2019, there was a surge in country-of-origin fraud, particularly Chinese goods re-labeled as “Made in Vietnam.” Known as a “country of origin wash,” this practice misleads CBP and avoids duties tied to China. 

These incentives have contributed to the emergence of a cottage industry of “tariff reduction” companies that advertise ways to cut import costs. However, many of these so-called strategies amount to evasion, putting importers at serious legal risk.

DOJ Prioritizes Customs Fraud

The Department of Justice is watching closely. In a May 2025 memo, Matthew Galeotti, head of the DOJ’s Criminal Division, named trade and customs fraud as one of the top enforcement priorities in white-collar crime.

The DOJ also expanded its Corporate Whistleblower Awards Pilot Program […]

ICYMI: President Trump Lifts Syria Sanctions

On June 30, 2025, President Trump issued an Executive Order formally terminating the Syria sanctions program, which had been in place for two decades.  

The Executive Order (effective July 1, 2025) revoked the following six prior executive orders dating back to 2004:

  • Executive Order 13338 of May 11, 2004 (Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria),
  • Executive Order 13399 of April 25, 2006 (Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria)
  • Executive Order 13460 of February 13, 2008 (Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria)
  • Executive Order 13572 of April 29, 2011 (Blocking Property of Certain Persons with Respect to Human Rights Abuses in Syria)
  • Executive Order 13573 of May 18, 2011 (Blocking Property of Senior Officials of the Government of Syria)
  • Executive Order 13582 of August 17, 2011 (Blocking Property of the Government of Syria and Prohibiting Certain Transactions with Respect to Syria).

The revocation of Executive Order 13338 ended the national emergency that underpinned the subsequent executive orders.

The Executive Order also waived certain sanctions imposed by the Syria Accountability Act and the Chemical and Biological Weapons Control and Warfare Elimination Act.

On […]

Go to Top