Gregory Husisian on Voluntary Disclosures to Customs – 'Importing has never been riskier'

Foley & Lardner LLP partner Gregory Husisian authored the SupplyChainBrain article, “Best Practices for Making Voluntary Disclosures to Customs,” sharing insight on this vital strategy for companies looking to mitigate risk from U.S. Customs and Border Protection.

“Importing has never been riskier,” Husisian writes. “The combination of a high-tariff environment, increasingly sophisticated data analytics by U.S. Customs and Border Protection, and a tougher penalty posture by the federal government means that even minor compliance lapses can carry major consequences.”

He lists several important considerations for companies eyeing voluntary disclosures, emphasizing the importance of quick action and staying attuned to Customs communications, deciding whether to conduct a limited or full disclosure, undergoing a thorough internal review, keeping transparent, complete, and organized documentation, and devising a corrective action plan.

“In a world of elevated tariffs, aggressive Customs enforcement and advanced data mining, voluntary disclosures are more essential than ever for importers managing their trade-compliance risks,” Husisian concludes. “But to be effective, disclosures must be structured, comprehensive, and credible.”