As tariff policy shifts and customs scrutiny intensifies, companies face heightened risk in restructuring supply chains. Maintaining trusted industry relationships, not simply adjusting routing or paperwork, will define successful tariff mitigation in the current trade environment, according to Richard DiNucci, senior international trade advisor at Venable LLP and former U.S. Customs and Border Protection director of field operations. Speaking during a media briefing last month, DiNucci said many companies have moved quickly to blunt the impact of new tariff measures, but oversight has tightened in parallel.
Compliance Pressure Rises as Companies Restructure Supply Chains
DiNucci cautioned that firms navigating tariff changes under President Donald Trump’s policy overhaul must ensure any new sourcing or network models stand up to regulatory scrutiny. “Customs scrutiny in this regard is increasing daily,” he said, noting that CBP has launched more audits as it examines how companies are protecting revenue.
Engaging early with licensed customs brokers is essential, he added, particularly when restructuring trade flows or modifying origin designations. According to industry advisers, U.S. customs has stepped up enforcement around tariff engineering and transshipment risks, making assumptions about permissibility a dangerous bet. DiNucci emphasized that compliance missteps carry elevated consequences in the current climate.
Industry Networks Become a First-Line Defense
Beyond technical expertise, the former CBP leader urged companies to expand their network of advisors, including brokers, consultants and ports. Active participation in trade associations can help executives stay ahead of regulatory developments, especially when federal guidance is fluid. “Your knowledge is what’s going to get you through this,” DiNucci said, highlighting the value of real-time intelligence from industry peers and practitioners.
While the U.S. government shutdown has complicated communication with headquarters-level officials, DiNucci and Port of Los Angeles Executive Director Gene Seroka noted that port operations continue largely uninterrupted, with essential CBP staff maintaining entry processes.
Why Tariff Strategy Now Demands Broader Market Scanning
As customs tightens oversight and tariff policy remains in flux, the edge may belong to companies that treat trade compliance as a continuously monitored discipline, rather than a periodic exercise. In recent cycles, government data and industry reporting show customs targeting valuation practices, related-party transactions and supply-chain diversion strategies more aggressively. That pattern suggests organizations that pair legal precision with strong external networks will be better positioned to anticipate enforcement trends, and move faster than peers still treating tariff strategy as a reactive function.