CBP just released FY2025 enforcement statistics showing a dramatic spike in customs audits and penalties. If you haven't audited your compliance posture yet, CBP's numbers should terrify you—and inspire immediate action.
On April 1, 2026, U.S. Customs and Border Protection released enforcement data that painted a stark picture: CBP collected $235.5 million in audit penalties in FY2025, with 465 completed audits and a trend that shows no signs of slowing. What's more unsettling? The agency is deploying new AI tools to detect transshipment schemes, and CBP's enforcement velocity is accelerating.
But here's the thing: most of these penalties are preventable. They're not the result of bad intent—they're the result of overlooked documentation, misclassified shipments, or valuation methods that didn't hold up under scrutiny. If your company imports anything, you're in CBP's sights. The question is whether you're prepared.
The Numbers That Should Keep You Up at Night
The FY2025 enforcement report shows just how aggressive CBP has become. Customs audits recovered $235.5 million in audit collections alone. That's not including the $46.0 million collected from combined penalty and liquidated damage settlements. For perspective, that's enough to bankrupt most mid-market importers in a single audit action.
But the headline number doesn't tell the whole story. What matters more than the total is the trajectory. In FY2025, CBP completed 465 audits—that's already 6% higher than the five-year average of 438. By March 2026, CBP had already completed 71 audits in a single month, identifying $310 million in lapsed duties and fees. If that pace holds, FY2026 will see nearly 850 audits, potentially doubling the five-year average.
And CBP isn't done. The agency is investing in AI-powered supply chain mapping technology to detect illicit transshipment. These tools are still maturing, but when they go live across all of CBP, enforcement velocity will jump again. You can't hide; you can only prepare.
Why Are Audits Increasing? The Top Three Violation Categories
CBP doesn't audit randomly. The agency targets companies based on risk signals, and three categories account for the vast majority of violations: valuation, classification, and origin.
Valuation is the leading problem. CBP audits have found importers adjusting base prices downward, cherry-picking supplier values, or failing to include indirect costs that count toward appraised value. The Customs Valuation Agreement is deceptively simple—pay duty on the price the buyer actually paid, plus adjustments for shipping, insurance, royalties, and assists. But in practice, the definitions are elastic. CBP auditors see importers shaving 10%, 15%, sometimes 30% off declared values. When audited, the difference is multiplied across years of imports. A $50,000 undervaluation on a single entry can become a $500,000 penalty across 10 years of similar shipments.
Classification is the second biggest vulnerability. Many importers incorrectly classify goods as "similar" items to achieve lower duty rates. The 5-digit HTS code looks right; the 8-digit tariff rate is wrong. The difference might be 2.5% versus 12.5%—not huge on a single entry, but scaled across volume, it's a multi-million-dollar liability. And the HTS is intentionally complex. The difference between "plastic film" (3916) and "plastic sheeting" (3917) is small but material. CBP auditors live in this gray area, and they're trained to find it.
Origin is the silent killer. Rules of origin seem straightforward—goods must be made in a particular country to qualify for preferential rates under trade agreements. But the devil is in tracing the supply chain. A shirt marked "Made in Vietnam" might have fabric from India, buttons from China, and embroidery from Cambodia. If Vietnam's value-add doesn't exceed the threshold, the shirt doesn't qualify for Vietnam's duty rate. CBP's auditors are increasingly sophisticated about supply-chain forensics, and importers who haven't traced their supply chains deeply enough are vulnerable.
How CBP Identifies You
If you're waiting for CBP to knock on your door with an audit notice, you've got the timeline backward. CBP doesn't start with your facility—it starts with your entry data.
The agency uses "Risk Analysis and Survey Assessments" (RASA) to flag entries for further review. These assessments look at dozens of factors: entry value, country of origin, product type, declarant history, and increasingly, AI-powered anomaly detection. If CBP flags your entry, you move to the Focused Assessment phase.
A Focused Assessment has two phases. First is the Pre-Assessment Survey (PAS), where CBP contacts you (your customs broker or importer of record) and asks for documents: invoices, packing lists, bills of lading, supplier contracts, manufacturer certifications, testing reports. You have 30 days to respond. If your documentation is incomplete or inconsistent, CBP will issue a CF-28 form—a notice of action to reliquidate entries and recalculate duties. Second is Assessment Compliance Testing (ACT), where CBP may send auditors on-site to examine your records, interview staff, and trace goods through your warehouse.
Here's where it gets serious: if CBP finds violations, the penalties scale with culpability. Negligent violations are capped at the lesser of the domestic value or 2× revenue loss. Gross negligent violations go up to 4× revenue loss. And fraud violations are capped at the full domestic value. For a company importing $10 million annually, even a "negligent" violation can exceed six figures in penalties.
The New Enforcement Tool: AI-Powered Transshipment Detection
CBP awarded contracts to AI companies in 2025 to build supply-chain-mapping technology that can detect transshipment schemes automatically. These tools analyze shipping patterns, supply-chain networks, and trade flows to identify goods that are routed through intermediary countries to circumvent tariffs or gain unauthorized preferences.
The implications are major. Right now, transshipment detection is labor-intensive—CBP auditors have to manually trace supply chains. With AI, the agency can screen every entry in real time. Transshipment schemes that currently go undetected for years could be caught on your first shipment.
If you source through intermediaries or trading companies, you need to know the true country of origin and manufacturing location. Plausible deniability no longer exists.
What You Should Do Right Now: Six Critical Actions
If you import anything into the U.S., you are exposed. Here's what you need to do:
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Conduct a Valuation Audit — Work with your customs broker or a customs attorney to review your declared values for the past three years. Compare your entry prices to your supplier invoices, cost accounting, assists, and indirect costs. Identify any instances where your declared value is below your actual cost. Request a binding Advance Ruling (ART) from CBP if your valuation method is novel or ambiguous. Why: CBP will discover misvaluation in an audit. If you self-correct before they find it, penalties are reduced or waived.
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Classify Your Top SKUs Correctly — Don't assume the HTS code you're using is correct. Work with a customs attorney or HTS specialist to confirm classification for your top 20 SKUs. Request a Binding Tariff Classification (BTC) from CBP if the code is uncertain. Why: Misclassification is the second-most common violation. A BTC binds CBP for three years; if you get it right, it shields you from challenge.
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Map Your Supply Chain — Trace the origin of your materials and components to the country of manufacture. If you claim origin in a free-trade-agreement country, ensure the value-add in that country meets the threshold. Document this with supplier certificates of origin, invoices, and manufacturing records. Why: Origin violations are rising, and CBP's new AI tools will detect patterns you can't see. Pre-emptive transparency shields you.
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Strengthen Your Record-Keeping — Audits are about documentation. If you can't produce invoices, packing lists, bills of lading, or manufacturing records within 30 days of a CF-28, CBP will estimate your liability against you. Implement a system (even a spreadsheet) to organize entry documents by entry number, date, and product. Why: Good records reduce penalties. Poor records result in CBP's "best judgment," which is always against the importer.
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Request a Pre-Audit Review from Your Broker — Many customs brokers offer internal compliance reviews as part of their service. Ask them to run a risk assessment on your top 50 entries over the past year. Identify which entries have the highest exposure to audit risk. Why: Early detection of problems lets you self-correct before CBP finds them. The Customs laws allow mitigation if you disclose voluntarily.
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File Protests on Liquidation Decisions You Dispute — If CBP liquidates an entry in a way you believe is incorrect (valuation, classification, origin), you have one year to protest. File a CF-29 form with CBP. Even if you lose, the protest preserves your right to challenge the decision in the Court of International Trade if the amount exceeds $2,500. Why: Many importers don't protest because they assume CBP is right. CBP gets things wrong. A protest is a cheap insurance policy.
The Bigger Picture: Why CBP Is Tightening Now
CBP's enforcement surge isn't random. The agency has been understaffed for years, but FY2025 saw increased staffing for trade enforcement. Additionally, CBP is under pressure to collect more revenue for the federal government—tariffs have become a major funding lever in trade policy. Finally, the Agency is working to address a surge in illegal transshipment and evaded duty that costs the U.S. billions annually. Your company isn't being targeted personally; you're being swept up in a systematic enforcement wave.
The good news? You can stay ahead of it.
The Action You Can't Avoid
If CBP audits you, you can't negotiate away the findings. What you can do is minimize the scope and severity of penalties by cooperating, providing good documentation, and self-correcting before CBP finds the problems. The companies that get destroyed by audits are those that waited until the CF-28 arrived to start organizing their records.
The statistics say CBP will audit nearly 1 in 500 importers this year—higher odds than most people realize. If your company imports to the U.S., prepare as though you're next. Because statistically, you might be.
TariffLens helps importers and brokers stay ahead of compliance risk by organizing entry data, flagging classification and valuation anomalies, and preparing for audits. But whether you use a tool or a spreadsheet, the imperative is the same: get your house in order before CBP does it for you.
This article is for informational purposes only and does not constitute legal, tax, or customs advice. Consult a licensed customs broker or trade attorney for guidance specific to your situation.