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Tariff Evasion Enforcement Continues To Be A Top Priority for DOJ and CBP

Recent developments highlight a coordinated, aggressive approach by the U.S. Government to crack down on schemes that undermine U.S. trade laws.

An Indonesian jewelry company, UBS Gold, its co-owner, and two employees were charged with conspiring to evade over $86 million in U.S. customs duties on jewelry imports. Two individuals were arrested and face up to 20 years in prison for wire fraud conspiracy, while UBS Gold faces fines up to $500,000 or twice the gain.

The alleged scheme involved routing Indonesian-made jewelry through Jordan to exploit its free trade agreement with the U.S., falsely claiming goods were made in Jordan. Later, after tariffs on Jordan were imposed, the conspirators allegedly developed a new method: sending scrap gold from a U.S. company to Jordan, swapping it for Indonesian jewelry, and falsely declaring the jewelry as U.S.-made to avoid tariffs.

CBP Launches Pilot Program to Expand CTPAT Membership to 3PLs

CBP announced a five-year pilot program, starting no earlier than December 1, 2025, to allow both asset-based and non-asset-based third-party logistics providers (3PLs) to participate in the Customs Trade Partnership Against Terrorism (CTPAT).

CTPAT, created under the SAFE Port Act, is a voluntary public-private partnership aimed at securing the international supply chain and facilitating trade. Certified members benefit from reduced cargo examinations, lower risk scores, and expedited clearance.

The pilot responds to the CTPAT Pilot Program Act of 2023, which directed DHS to assess whether expanding membership to 3PLs enhances port security and supply chain integrity.

  • Eligibility: Participants must handle international cargo, meet minimum security criteria, maintain a staffed office in North America, and comply with licensing and bonding requirements.
  • Structure: The pilot will include 10 asset-based and 10 non-asset-based 3PLs, selected on a first-come, first-served basis.
  • Application: Interested entities must email CBP and complete a detailed security profile via the CTPAT portal.
  • Validation: Certified participants will undergo on-site validation within one year.

If successful, the pilot could significantly broaden CTPAT’s reach, integrating more logistics providers into the program and strengthening supply chain security.