The numbers are hard to ignore. In FY2024, US Customs and Border Protection (CBP) collected $117.7 million through importer audits. By FY2025, that figure had doubled to $235.46 million. Through just the first seven months of FY2026, CBP had already recovered $182.22 million from only 181 audits—more than $1 million per audit [1]. 

Today, CBP auditors aren’t relying solely on auditors reviewing spreadsheets and paperwork. Instead, they are increasingly leveraging artificial intelligence to map supply chains, detect anomalies, and identify high-risk transactions across massive volumes of import data. Issues that once took years to uncover can now be identified in a matter of weeks.

The surge in audit activity is not happening by accident. In 2026, two powerful forces are converging to create one of the most aggressive customs enforcement environments in recent history.

Force One: AI-Powered Targeting Is Operational

CBP has invested in artificial intelligence and data analytics capabilities for trade enforcement. The agency’s Automated Targeting System (ATS) cross-references import entry data against commercial databases, financial records, supplier information, and historical entry patterns simultaneously. The ATS enhancements mean that the same data that used to require a manual audit for analysis is now screened automatically on every entry at the time of filing. The AI systems are looking for specific anomaly types:

• • Classification inconsistencies: The same product classified differently across multiple entries, or inconsistently with the declared product description on previous supplier invoices.
  • Valuation anomalies: The same product valued differently across multiple entries.
  • Origin patterns: Supply chain routes consistent with transshipment through third countries, sudden shifts in country of origin for the same product from the same supplier, or declared origins, inconsistent with the supplier’s known manufacturing footprint.
  • Preference claim mismatches: FTA preference claims combined with supply chain data that does not support the claimed origin qualification, or duplicate tariff exclusion claims across multiple entries.
  • Shell company indications: Importing entities with minimal commercial footprint, new entities claiming large import volumes, or entities whose profile is inconsistent with the declared import value and product category.

The AI system flags statistical anomalies and inconsistencies. A CBP officer then reviews the flagged entries and decides whether to issue a CF-28 Request for Information, a CF-29 Notice of Action, or to refer the case for a formal investigation.

Force Two: The DOJ-DHS Trade Fraud Task Force and an Executive Order

In August 2025, the U.S. Department of Homeland Security and the Department of Justice launched a joint Trade Fraud Task Force with a mandate to pursue customs fraud through parallel criminal, civil, and False Claims Act enforcement. By December 2025, it had secured a $54 million settlement involving allegations of misclassification, country-of-origin marking violations, and transshipment. Most notable about this case is that the alleged misconduct dated back to 2015, demonstrating that enforcement actions can reach well beyond recent import activity. The case also included criminal charges against a corporate officer for duty evasion, further reinforcing that liability doesn’t just belong to the importing entity but is levied against individuals responsible for customs compliance decisions as well.

On June 3rd, 2026, President Trump signed an Executive Order giving DHS and CBP a broader set of custom enforcement reforms. The Executive Order's central focus is the importer of record ("IOR"). The IOR is responsible for making entry, using reasonable care, providing accurate information to CBP, and paying duties, taxes, and fees. CBP has 180 days to revise IOR eligibility regulations, guidance, and policies to include:

• A minimum level of domestic assets and/or increased bond coverage.
• Require an IOR to be designated and reported to CBP for formal and informal entries.
• Require additional information, including anticipated import volumes, year organized, ownership disclosures, and any other information CBP considers necessary.

Additionally, the Executive Order places heightened scrutiny on foreign IORs. DHS must take steps to prohibit foreign IORs from filing informal entries. For formal entries the Executive Order directs CBP to impose additional requirements on foreign IORs such as:

• A foreign IOR may not rely on a continuous bond unless CBP determines that revenue will be fully protected and compliance will be assured.
• A foreign IOR may need to be validated in the Customs Trade Partnership Against Terrorism (“CTPAT”), if eligible, or use a CTPAT-validated and licensed customs broker to file entries with CBP.

Connection to USMCA Compliance

The emphasis on supply-chain transparency, foreign records access, ownership disclosures, and forced labor investigations suggests that CBP is increasingly expecting importers to maintain documentation that can trace products and materials deeper into the supply chain, not just support preferential tariff claims.

How Tradewin Can Help

Tradewin can help importers prepare for this heightened enforcement environment by reviewing importer of record structures, assessing bond sufficiency, strengthening supplier and origin documentation, and improving customs broker oversight and due diligence procedures. We can also support companies in building stronger audit trails, securing access to foreign export records, and monitoring CBP regulatory developments so importers are better positioned to demonstrate reasonable care and respond confidently to CBP scrutiny. We’re here to help.