Source: Freightwaves
Date: 7th August 2025

Compliance Enforcement Predicted to Make Importer Fraud Top Revenue Source for Regulators.

As the latest round of tariffs from the administration took effect, a leading customs compliance consultancy warned that regulatory agencies will significantly intensify enforcement efforts.

The U.S. Department of Justice (DOJ) and U.S. Customs and Border Protection (CBP) are expected to focus heavily on ensuring accurate tariff payments, with scrutiny now extending to import documentation such as merchandise value, country of origin, and potential transshipment schemes.

According to the consultancy, the DOJ’s involvement in customs compliance cases has risen to unprecedented levels over the past year.

The consultancy predicted that circumvention of tariffs will become the top revenue-generating penalty category, overtaking valuation and record-keeping violations that historically dominated CBP enforcement actions.

The projected rise in DOJ activity, estimated at 200%, is attributed to the scale and speed of recent tariff increases.

Legal experts have also noted that these steep tariffs could drive a rise in False Claims Act prosecutions, as some companies may attempt to avoid compliance costs through fraudulent means.

One emerging tactic flagged by CBP is Modified Delivery Duty Paid (MDDP), where foreign suppliers assume the importer-of-record role and misdeclare entries, allowing buyers to sidestep tariff obligations.

CBP views this as a blatant form of fraud, with all parties involved, regardless of whose name appears on customs declarations, subject to severe penalties.

Customs brokers are being urged to guide importers on the risks and responsibilities of accurate compliance, as penalties can far exceed the value of the goods themselves.