Learn why internal auditing, cross-functional teams, and automation are critical to mitigate severe customs fraud risks
Bruno J. Navarro
Senior Editorial Strategist, Finance
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The new year marks more than a new fiscal year; it signals the start of an unprecedented era of trade and customs enforcement.
For CFOs, the days of reacting to rapid-fire tariff rollouts appear to be over. The focus has shifted from managing the immediate cost to mitigating the severe legal and financial risks associated with non-compliance.
The message to the C-suite is clear: Trade and customs fraud is now a top-tier white-collar enforcement priority for the U.S. Department of Justice. This heightened scrutiny, coupled with the sophisticated auditing capabilities of Customs and Border Protection (CBP), means that import data scrutiny is about to reach new, machine-driven highs.
¡°There¡¯s going to be increased scrutiny on every single import,¡± Christopher Desmond, principal in the customs and international trade group at PwC, . Desmond added that officials are ¡°using AI to do audits now and spotting things that they haven¡¯t seen before.¡±
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The felt like a chaotic practice lap, full of policy shifts, complex exceptions, and hasty adjustments by companies just trying to keep the supply chain moving.
But here¡¯s the critical warning: That ¡°practice lap¡± was actually being recorded.
The CBP now holds a full year of 2025 import data. Entering 2026, the agency is using AI and advanced analytics¡ªa high-definition, slow-motion replay capability¡ªto analyze trends, flag anomalies, and spot infractions that were previously too subtle for human auditors to catch.
For CFOs, this means every fiscal position taken in 2025 regarding imports, pricing, and classification is now under the microscope. Finance leaders must review their data and self-correct processes before the enforcement referees blow the whistle.
As the Federal Reserve Bank of Richmond noted in , ¡°CFOs remain concerned about tariffs and anticipate price increases of more than 3% in 2026.¡±
To effectively mitigate the risks associated with this escalating tariff enforcement, CFOs must move beyond simple firefighting and adopt a robust, proactive compliance strategy centered on internal auditing, collaboration, and technology.
In the eyes of the CBP, ignorance is not a defense, but voluntary disclosure is a major penalty mitigator. The first step is to assume errors exist and launch a deep-dive investigation to find them.
Organizations can no longer make tariff compliance the sole responsibility of the logistics or customs department. It touches transfer pricing, tax liability, procurement costs, and supply chain design. The silo approach is a compliance liability.
The volume and complexity of tariff impacts are moving too quickly for manual processes to reliably keep pace. Relying on spreadsheets and manual entry is a guaranteed path to non-compliance in the AI-driven enforcement environment.
CFOs must assume that the CBP will question and challenge every financial decision related to imports.
For CFOs, the threat is twofold: significant financial penalties and severe reputational damage. Fines for customs violations can be staggering, but involvement of the Department of Justice can escalate the consequences to criminal charges for white-collar crime, affecting individuals and the enterprise's standing.
The investment in robust internal auditing, cross-departmental collaboration, and technological automation is a mandatory risk-mitigation strategy. As the enforcement ramp-up of 2026 begins, the time for merely reacting is over: Proactive compliance is the new fiscal imperative.
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