Tariff Evasion Risk Questionnaire

The U.S. Department of Justice (DOJ) has issued new white-collar enforcement guidance (May 2025) identifying tariff and customs fraud—including tariff evasion—as a top prosecutorial priority. The move signals heightened risk for companies engaged in global trade, particularly those in industries with complex supply chains or prior customs scrutiny. Effective tariff management and compliance are essential helping to reduce potential risk and ensuring smooth cross-border operations.  

To note: 

• Tariff evasion now ranks alongside healthcare fraud, money laundering, and sanctions violations among DOJ’s enforcement priorities 
• DOJ encourages whistleblower tips involving trade and customs fraud through an expanded Corporate Whistleblower Awards Pilot Program 
• Companies that misclassify goods, misstate origin, or underreport import values may face criminal exposure 
• Cases involving senior-level involvement, significant loss, or obstruction will receive the highest priority in enforcement actions 

Leverage our interactive questionnaire to understand the gaps in your company’s current practices and controls related to customs and tariffs. The questions look at key areas such as executive oversight, country of origin verification, tariff classification, valuation, transshipment monitoring, compliance program maturity, and training. 

Your responses to the questions will help identify areas for review, including strengths and potential gaps in your organization’s trade compliance framework. BDO can assist in assessing your company’s tariff exposure, conducting an internal customs review, or responding to a government inquiry.  

Please answer the questions based on your company’s current policies and procedures to identify areas that may require further review