How U.S. Customs and DOJ Are Identifying High-Risk Importers for Tariff Enforcement

By Simran Sethi, Senior Industry Solutions Consultant, Global Trade Intelligence, Descartes

Import tariffs are now firmly at the center of U.S. trade enforcement. The Department of Justice (DOJ) has elevated trade and customs fraud (including tariff evasion) to a top enforcement priority, reinforced by the launch of a cross-agency Trade Fraud Task Force with the Department of Homeland Security.

For importers, however, the most important question is no longer whether tariff enforcement is intensifying.

It is how enforcement is actually happening.

Across the U.S. government, authorities are increasingly using trade data analytics, cross-agency intelligence sharing, whistleblower reporting, and supply chain analysis to identify high-risk importers and suspicious shipments. The result is a far more targeted enforcement environment—one in which irregularities in import data can trigger scrutiny long before a formal investigation begins.

For companies operating complex global supply chains, understanding how regulators identify potential violations has become a critical part of managing trade compliance risk.

• U.S. enforcement agencies are increasingly using data analytics and anomaly detection to identify suspicious import patterns and high-risk importers.
• The DOJ–DHS Trade Fraud Task Force is strengthening coordination between CBP, DOJ, Homeland Security Investigations, and other enforcement bodies.
• Regulators are closely monitoring HTS classification patterns, declared customs values, country-of-origin claims, and supply-chain routing data.
• Whistleblower programs and competitor complaints are becoming an important source of enforcement leads.
• Recent settlements ranging from $4.9 million to $54.4 million demonstrate the DOJ’s willingness to pursue customs violations using the False Claims Act and other enforcement tools.
• In a data-driven enforcement environment, companies must treat trade compliance as a governance and analytics challenge, not just a customs filing exercise.

Historically, customs enforcement relied heavily on post-entry audits and physical inspections at ports of entry. While these tools remain important, the modern tariff enforcement model is increasingly intelligence-driven.

U.S. Customs and Border Protection (CBP) now analyzes vast volumes of import data using automated targeting systems designed to identify unusual patterns across millions of transactions. These systems compare import declarations against industry benchmarks, historical import behavior, and other intelligence sources.

Instead of broad, untargeted audits, regulators can now identify specific companies or supply chains that appear statistically abnormal.

Many investigations therefore begin not with a port inspection, but with an anomaly detected in trade data.

At the center of modern enforcement is the data submitted with every import entry through the Automated Commercial Environment (ACE).

This information includes:

• Harmonized Tariff Schedule (HTS) classification codes
• declared customs value
• country of origin
• importer and manufacturer identification
• port of entry
• shipping and routing information

When analyzed across thousands of entries, these data points reveal patterns in importer behavior.

Authorities increasingly combine entry data with additional intelligence sources such as:

• shipping manifests and bills of lading
• Importer Security Filing (ISF) data
• trade and pricing databases
• corporate ownership records
• supply chain intelligence

Together, these datasets allow investigators to reconstruct global supply chains and detect inconsistencies between declared information and actual trade activity.

Trade analytics are particularly effective at identifying patterns that may indicate tariff evasion. Some of the most common signals include unusual HTS classification patterns.

If an importer consistently declares goods under tariff codes with significantly lower duty rates than competitors importing similar products, the discrepancy may trigger scrutiny.

Regulators frequently compare classification patterns across industries to identify statistical outliers.

Declared customs values are often analyzed against:

• historical import prices
• industry pricing benchmarks
• export data from supplier countries

When declared values appear substantially below market levels, investigators may suspect undervaluation designed to reduce duty exposure.

Country-of-origin declarations are closely examined for signs of transshipment through third countries.

Common indicators include:

• sudden shifts in manufacturing location after tariff increases
• goods routed through low-tariff jurisdictions despite production links to high-tariff countries
• inconsistent supplier documentation

These patterns frequently emerge in trade data long before a tariff enforcement case is formally opened.

Trade analytics can also identify shipping routes that appear designed to obscure product origin.

Multiple intermediary countries, unexpected routing changes, or inconsistent supplier networks can signal attempts to avoid tariffs or trade remedies.

Another major shift in the enforcement landscape is the growing coordination between U.S. government agencies.

The Trade Fraud Task Force, launched in 2025, formalizes collaboration among:

• U.S. Customs and Border Protection (CBP)
• Department of Justice (DOJ)
• Homeland Security Investigations (HSI)
• other federal enforcement partners

This structure allows agencies to share intelligence, coordinate investigations, and pursue civil and criminal enforcement simultaneously.

For importers, the implication is significant. What once might have resulted in a customs penalty or administrative action can now escalate into False Claims Act litigation, whistleblower suits, or criminal investigations.

Data analytics are not the only source of enforcement leads.

The DOJ has expanded its Corporate Whistleblower Awards Program to include tariff and customs fraud, creating financial incentives for insiders to report suspected violations.

At the same time, CBP’s e-Allegations reporting system allows companies, brokers, and competitors to report suspected trade violations.

Potential whistleblowers may include:

• employees in procurement or compliance roles
• customs brokers or logistics providers
• former business partners
• competitors affected by alleged tariff evasion

These reports often provide investigators with highly specific information that can be combined with trade data analysis to support tariff enforcement actions.

Recent False Claims Act settlements highlight how aggressively U.S. authorities are pursuing customs duty violations.

Examples from 2025 include:

These cases illustrate a consistent enforcement theme: systemic errors in classification, valuation, or origin declarations can lead to multi-million-dollar liability under the False Claims Act.

In a data-driven enforcement environment, traditional compliance practices are often insufficient.

Regulators now analyze importer behavior across thousands of transactions—making patterns of inconsistency far easier to detect.

Forward-looking organizations are responding by strengthening governance around trade data and classification decisions.

Key elements of modern compliance programs include:

• centralized HTS classification management
• documented valuation and origin methodologies
• continuous monitoring of import data for anomalies
• stronger oversight of brokers and supply-chain partners
• comprehensive documentation supporting tariff mitigation strategies

In short, trade compliance programs are evolving from manual regulatory processes into data-driven risk management systems.

Trade enforcement in the U.S. is entering a new phase—one defined by data analytics, cross-agency collaboration, and intelligence-driven investigations.

Through advanced targeting systems, whistleblower incentives, and expanded DOJ enforcement authority, regulators now have unprecedented visibility into global import activity.

For importers, the implication is clear:

The same data used to manage global supply chains is increasingly being used to evaluate compliance risk.

Organizations that invest in strong trade data governance, automated classification tools, and analytics-driven compliance programs will be far better positioned to navigate this new enforcement environment—and avoid becoming targets in the next wave of tariff enforcement actions.

As trade enforcement becomes increasingly intelligence-driven, companies need tools that combine authoritative trade content, automation, and analytics.

Descartes helps importers strengthen their compliance programs through solutions that provide:

• global tariff and trade content covering more than 160 countries
• advanced HS/HTS classification search capabilities
• integration with ERP, GTM, and customs filing systems
• analytics to identify anomalies in import data
• audit-ready documentation and governance workflows

Solutions such as Descartes CustomsInfo™ help compliance professionals maintain consistent classification decisions, improve supply-chain transparency, and strengthen their ability to defend compliance positions during audits or investigations.