What Every Multinational Should Know About … Best Practices For A Customs Disclosure In The New Tariff Environment

In the current global trade environment, importers are facing an unprecedented convergence of pressures. A sharp rise in new tariffs, the increasingly sophisticated data-mining of entry data by U.S. Customs and Border Protection (CBP), and a more aggressive government-enforcement posture have made even minor compliance failures potentially costly. In this context, the voluntary self-disclosure mechanism — long recognized by trade professionals as a key risk-mitigation tool — has taken on new urgency. For importers that uncover potential underpayments of tariffs, a properly executed voluntary disclosure can significantly limit financial liability, demonstrate good faith, and enhance the importer's broader compliance program.