Enforcement Tools and Where They Stall

The customs system has four ways to catch trade fraud. Each works as designed, and each stalls at the point where a violation becomes a case.

The Enforcement Tool Kit

Click a tool to see how it works, how it stalls, and how bad actors thwart it

What it is

Importers self-declare value, classification, and origin; CBP audits records and re-checks paperwork after the fact.

Where it stalls

Once a penalty is contested, the matter leaves CBP for a slow civil process the government rarely takes to trial — so it ends in a negotiated settlement years later

How bad actors beat it

Intentional fraud is built to look like a clean entry, so routine review won’t flag it — and a contested matter can be dragged out until the statute of limitations runs

A. Administrative

CBP · §1592

By the numbers

$34.4Bnet revenue recovered through entry summary reviews, FY2025, up from $668M in FY2024. Higher tariff rates drove the jump, not more fraud caught.

$46Mcollected in trade penalties and liquidated damages, FY2025. FY2026 to date: $91.6M. Rising, and still small next to $217B in duties collected.

Source: CBP Trade Statistics

What actually happens

Importers declare value, classification and origin themselves. CBP reviews after the goods have cleared.
Mistakes are corrected and billed. Negligence, gross negligence or fraud triggers a §1592 pre-penalty notice, with about 30 days to respond.
If the importer pays or settles, the matter closes inside CBP.

Why it stalls

If the penalty is contested and unpaid, CBP cannot collect it. The case is referred to DOJ to sue in the Court of International Trade, which takes years and usually ends in a discounted settlement.
Routine review is built to catch errors. Fraud designed to look like a clean entry passes it.
The five-year statute of limitations is the defendant's friend.