Foley Attorneys Underscore Customs Compliance Challenges for Importers

Foley & Lardner LLP attorneys Gregory Husisian, Matthew Kruger, and John Turlais were highlighted in International Trade Today for their comments at the Foley Fall International Trade Webinar Blitz.

The article summarizes the key takeaways from a Foley webinar held on October 22, 2025, which addressed the changing international trade landscape and importers’ growing exposure to U.S. Customs and Border Protection (CBP) enforcement.

In the article, “Import Compliance Becoming a Team Effort Beyond Customers, Lawyers Say,” Husisian explained, “People misunderstand the role of the customs broker. The customs broker is basically there to expedite the submission of the entry summary information. They’re not there to classify your goods.”

He also recommended adding flexibility with alternative suppliers and advised importers to include clear tariff-related risk management in contracts.

“Filing prior disclosures has been a long-term trend — that people were filing more and more prior disclosures each year. We used to handle one or two a year, and now we handle dozens a year. And I think a lot of this has been driven, even before the Trump tariffs, by the better use of data mining by CBP,” Husisian said.

According to Turlais, in the article, “Lawyers: Importers Should Be Cautious of Tariff Mitigation Advice From Suppliers,” another theme that’s emerging is “a lot of incentive” to report competitors for customs violations. He explained that the heightened tariff environment has led companies to “want to make sure that the playing field is level,” and the government is actively encouraging them to report or refer situations “where they see tariff evasion.”

Krueger added that the DOJ is “willing to go after” companies and individuals it “believes are responsible for promoting tariff evasion.”

Such cases have “a long tail” and he predicts they might not “ultimately be resolved and brought public well into the 2030s, which is somewhat frightening to think about.”

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