Global trade was shaken and stirred like never before last year, especially concerning tariffs. And if the first weeks of 2026 are any indication, tariffs will continue to shape global trade management this year as well — with the next big development being the upcoming Supreme Court ruling, which may happen any day now, on the legality of the Trump tariffs under the International Emergency Economic Powers Act.
Of course, while all of this shakes out, importers must still stay compliant with current regulations and pay the tariffs due. Not surprisingly, over the past year importers have been looking for ways to avoid or minimize tariffs. But as enforcement of tariff evasion and customs fraud increases, staying informed and compliant with regulations is more important than ever. To help us understand the current enforcement environment and how to avoid any missteps, I spoke with Jackson Wood, Director of Industry Strategy, Global Trade Intelligence at Descartes, on a recent episode of Talking Logistics.
Increases in Enforcement
Much as COVID raised public awareness of supply chain and logistics issues five years ago, tariffs have again increased awareness. What may not be as well known is the increased enforcement around tariff evasion and customs fraud. We began our discussion on this topic.
Jackson started by noting that the volume and velocity of tariff changes have been a challenge for supply chain management, with increased enforcement in the U.S. being a driving factor. But it’s also been a shift in focus. He explained that in the past, the primary emphasis was on export controls, such as military technology or computer chips. Over the past year, however, there has been much more awareness of import tariffs and related enforcement.
This shift is also driven by the sheer volume of money involved. During 2025, “the Treasury Department collected over $200 billion in import tariffs,” Jackson noted. “That’s a massive number.”
With this level of inflow, the government is taking a more critical look at importers’ mitigation and evasion tactics. “The stakes are just much higher on both sides now,” Jackson commented.
Trade Fraud Task Force
One significant development in this area is the formation of the Trade Fraud Task Force. Jackson explained that one of the key differences now is that, while enforcement was previously localized within specific government departments such as Treasury or Commerce, the new task force operates under the Department of Justice, one of the most powerful agencies in the federal government.
The task force has partnered with the Departments of Homeland Security and Customs and Border Protection to “aggressively pursue enforcement actions against any parties who seek to evade tariffs and other duties, as well as smugglers who seek to import illegal goods into the U.S.” This, Jackson emphasized, is a massive signal from the administration that trade fraud enforcement is being taken very seriously.
Jackson also pointed out that while export controls historically focused on national security, the current emphasis on imports reflects growing concern around economic security. This shift also reflects a broader “whole-of-government” approach, with trade enforcement now tied not only to compliance, but to broader economic and national security concerns.
Enforcement Tactics
What tactics is the task force using for enforcement? Jackson explained that, at a high level, the focus is on determining companies’ intent to illegally evade paying tariffs and duties. As a result, companies both large and small are putting tremendous pressure on compliance and supply chain personnel to find ways to legally minimize what they have to pay.
Enforcement agencies are closely scrutinizing tactics such as:
- Undervaluing imported items
- Misclassification from an HTS perspective
- Misdeclaration of country of origin
- Transshipment
- Dodging anti-dumping or countervailing duties
- Setting up shell companies
Jackson stressed that this is not about honest mistakes. “It’s purposeful and intentional actions to obfuscate what is being brought into the U.S.” He added that this is where the task force is focused—and where consequences will follow.
Recent Examples
There are already examples of companies being caught and penalized for these types of evasive practices. Jackson cited a jewelry company operating in Indonesia that, over multiple years, attempted to evade more than $86 million in duties on over $1 billion worth of imports into the U.S. using several of the tactics outlined above.
A more recent example involves a forklift company in Denver that sold equipment made in China but labeled it as made in America, while also undervaluing the products and generating fake commercial invoices. In addition to a $250,000 fine, individuals involved are facing potential prison time.
“The expectation being set across the market is that these aren’t going to be inconvenient engagements with the task force,” Jackson emphasized. “These are going to be material disruptions to the business—and potentially personal disruptions in the form of criminal charges for individuals who may have directly or indirectly enabled these transgressions.”
“It’s fraud, and regulators don’t look kindly on that.”
Actions to Take
What actions should companies take to address these risks? Jackson shared several important insights into how organizations should approach this critical area, including how to work with external partners such as freight forwarders and customs brokers. Rather than summarize those recommendations here, I recommend watching the full episode to benefit from Jackson’s insights and expertise. Then continue the conversation by sharing your own comments and questions!
