Executive Summary
Tariff increases, rising costs, and supply chain disruption are pushing some importers to look for savings wherever they can find them. Trade compliance is one place where that instinct can backfire badly. CBP’s published statistics show that between fiscal years 2024 and 2025, collections from importer audits rose 100.1% (from $117.7 million to $235.5 million), collections from trade penalties and liquidated damages rose 75.7%, and the number of liquidated damages claims rose 136.8%. The pace has continued into fiscal 2026. Behind the numbers is a broader enforcement buildout—from Executive Order 14411 to DOJ’s trade fraud task force—that makes cutting corners riskier and more expensive than it used to be. This analysis walks through the data, explains how penalties work, and lays out a practical, two-step approach to managing risk that turns compliance from a cost center into a cost-control tool.

The Real Cost of Compliance Shortcuts: What CBP’s Enforcement Numbers Say About Importer Risk

(合规捷径的真实代价：CBP执法数据揭示的进口商风险)

1 · The Temptation: Cost Pressure Meets Compliance

Where Shortcuts Come From

In an environment of higher tariffs and tighter margins, it is easy to see why compliance can start to look like a place to save money. Typical shortcuts include:

• Classifying goods under a lower-duty code without a documented basis
• Understating value, or using transaction structures whose paperwork does not fully support the declared value
• Relying on supplier statements about origin without verifying them
• Skipping internal reviews or training to save staff time
• Assuming a customs broker or forwarder takes care of everything

None of these look dramatic in the moment. The problem is that CBP’s post-entry review tools are designed to find exactly these patterns, and the consequences accumulate quietly until an audit, a request for information, or a penalty notice brings them to the surface.

2 · What the Numbers Show

CBP’s Published Trade Statistics

CBP publishes year-by-year trade enforcement figures. Comparing fiscal year 2024 with fiscal year 2025 (October 1 through September 30):

Source: CBP Trade Statistics, as summarized in trade press analyses.

Recoveries from CBP’s entry summary reviews—another post-entry check—also climbed steeply over the same period; ST&R’s analysis of CBP’s published data puts the increase at 505.5%. Because that metric is reported in different ways in different CBP publications, treat the exact multiple with some caution; the direction is not in doubt.

The Trend Is Continuing in 2026

CBP’s trade statistics updated as of late July 2026 show that, with roughly two months of fiscal 2026 still to go, CBP had already completed 262 audits and collected $204.2 million from importer audits—about 87% of the full FY 2025 total. Collections from trade penalties and liquidated damages stood at $70.6 million, already more than 50% above the entire FY 2025 figure.

Reading the Numbers Carefully

Two points of context are worth keeping in mind:

• “Collected” is not the same as “found.” Audit dollars arrive on their own schedule: amounts collected in a given year can reflect findings from earlier years. CBP’s FY 2024 trade fact sheet, for example, reported that its 417 audits identified $576 million in lost trade revenue—a figure that sits alongside, but is not the same as, the amount collected.
• CBP describes its statistics as a snapshot, intended for monitoring purposes rather than as official government trade statistics.

Even with those caveats, the direction is unmistakable: more post-entry scrutiny, and more money recovered from importers.

3 · Why Scrutiny Is Widening

CBP’s Priority Trade Issues—and More

CBP has long organized its trade enforcement around what it calls priority trade issues, including:

• Antidumping and countervailing duties
• Trade agreements and preference programs
• Intellectual property rights
• Import safety
• Agriculture
• Textiles and apparel
• Revenue, including the collection of tariffs imposed under different statutory authorities

Today, enforcement also extends to the prohibition on imports made with forced labor, economic sanctions, and other measures. With several tariff authorities now stacked on top of one another, the revenue side of the mission has become more complex—and more closely watched.

A Broader Enforcement Buildout

The statistics above sit inside a larger picture that we have tracked through 2026:

Together, these developments mean a compliance gap is less likely to go unnoticed—and more likely to be treated as a serious matter when it is found.

4 · Why Shortcuts Are Expensive: How Penalties Work

The Statutory Framework

Under 19 U.S.C. § 1592, CBP can assess penalties for violations committed through fraud, gross negligence, or negligence. Generally:

On top of the unpaid duties themselves, importers may face liquidated damages claims against their bonds, loss of privileges, and more frequent audits.

What Has Changed Recently

• Less room for mitigation. Executive Order 14411 establishes a minimum penalty floor of 50% of the assessed penalty and eliminates mitigation for repeat offenders.
• False Claims Act exposure. DOJ’s Resource Guide to Trade Fraud Enforcement highlights the False Claims Act, which allows treble damages and whistleblower-initiated cases—meaning a current or former employee or business partner can bring a compliance gap to the government’s attention.
• Liability beyond the importer of record. Enforcement authorities have said they intend to pursue customs brokers, logistics providers, wholesalers, resellers, and executives where appropriate.

Why This Matters: the cost of a shortcut is not the duty savings; it is the duty savings minus the full exposure if the shortcut is found. When penalties can be several times the underpaid duty—and are harder to mitigate than before—the arithmetic rarely favors cutting corners.

5 · A Two-Step Approach: Identify Risk, Then Manage It

Step 1: Identify the Risks You Face

Risk is not uniform across an import program. It varies with:

Mapping these factors across your product lines and suppliers shows where a mistake would be most costly, and where review effort should go first.

Step 2: Manage Risk by Meeting the Reasonable Care Standard

Importers of record are required to use reasonable care when entering goods and declaring value, classification, and origin (19 U.S.C. § 1484). In practice, meeting that standard generally involves:

• Consulting a customs expert where the right answer is not clear
• Establishing effective internal controls, with clear responsibilities for classification, valuation, origin, and recordkeeping
• Conducting proactive compliance reviews, rather than waiting for CBP to find the problem

CBP has also been direct that responsibility does not transfer to an intermediary. At its September Trade and Cargo Security Summit, a senior CBP official said that “each entity must own its compliance,” adding that an importer should not rely solely on a broker or freight forwarder to validate its supply chain.

6 · What Proactive Compliance Looks Like in Practice

A Practical Checklist

• Classification: Document the basis for each tariff classification, especially for high-value or high-duty products
• Valuation: Ensure invoices, payments, and related-party arrangements support the declared value; review any post-entry adjustments
• Origin: Verify supplier origin claims with production records, bills of materials, and manufacturing process documentation
• Special programs: Confirm eligibility for free trade agreement claims and the correct treatment of AD/CVD and other trade remedies
• Recordkeeping: Keep required entry records for five years and make sure they can be retrieved quickly
• Broker oversight: Confirm that your broker follows documented procedures, escalates discrepancies, and retains records
• Training and ownership: Assign named owners for compliance functions and keep training current and documented

What a Compliance Review Delivers

A well-designed import compliance review typically includes:

• A risk assessment of products, suppliers, and transaction types
• An analysis of internal controls and procedures
• Transaction compliance testing of sample entries against CBP standards
• A gap analysis and confidential report with prioritized recommendations

Where a review identifies an error, companies can work with trade counsel to evaluate whether a prior disclosure to CBP is appropriate—which can substantially reduce penalty exposure compared with having CBP discover the issue first.

7 · Considerations for Logistics Providers

Customs brokers, freight forwarders, and 3PLs have their own exposure and their own opportunity:

• Exposure: Enforcement authorities have signaled that intermediaries who file inaccurate information, or who repeatedly represent noncompliant clients, can face penalties of their own.
• Opportunity: Importers under cost pressure need reliable partners who can flag risk early. Providers that offer clear documentation practices, discrepancy escalation, and compliance support are better positioned to retain and win clients as scrutiny rises.
• Practical step: Review client intake and onboarding to confirm that classification, valuation, and origin data are supported by documents—not just by instructions.

8 · Conclusion: Compliance as Cost Control

The Real Math

CBP’s numbers tell a consistent story: more audits, larger collections, and rapidly growing use of liquidated damages. Combined with tighter penalty rules and a broader enforcement apparatus, the risk-adjusted value of a compliance shortcut has fallen sharply.

The Strategic Takeaway

The most dependable cost savings in customs come from getting the entry right the first time—the right classification, the right value, the right origin claim, and the paperwork to back all three. Importers that map their risks, apply reasonable care, and review their programs proactively are not just avoiding penalties; they are building a more predictable cost base.

If your organization would benefit from a risk assessment or an import compliance review, our trade compliance team is available to help you identify gaps before they become problems.

This analysis reflects CBP’s published trade statistics for fiscal years 2024 and 2025 and fiscal year 2026 through late July, CBP’s FY 2024 trade fact sheet, and related public guidance and analysis through October 2026. Statistics are CBP figures intended for monitoring purposes; collections in a given year can reflect findings from earlier periods. Penalty ranges are stated generally; actual penalties depend on the facts of each case. Importers should consult customs counsel and trade compliance professionals for guidance tailored to their circumstances.