Gregory Husisian on Customs Compliance Violations – 'It's a sharply increased risk profile'

Foley & Lardner LLP partner Gregory Husisian joined the SupplyChainBrain Thought Leaders episode, “Getting Ahead of Customs Compliance Violations,” to describe the heightened risk environment importers face under the current trade and regulatory regime.

In a high-tariff environment, it is much easier to generate underpayments and subsequent penalties, Husisian explained. He also pointed to the unprecedented access of U.S. Customs and Border Protection given the agency can conduct sophisticated data mining into electronic import-related data to identify underpayments, signaling from the White House to focus on potential tariff underpayment, and the U.S. Department of Justice’s listing of tariff underpayment and customs enforcement as high priorities.

“If you put it all together, you have a much greater chance of underpayments being discovered than ever before, you have a much greater chance of running up underpayments, and you have much greater attention by Customs itself and the Department of Justice for potential criminal matters,” Husisian explained. “You add it all up and it’s a sharply increased risk profile for importation.”