Is your trade compliance team organized for battle?

For years, trade compliance functions were tucked under various parts of the company, including traffic, shipping, purchasing, finance, and tax—wherever this regulatory group seemed to fit in the organization. Basically, trade compliance people classified goods for export, made a license determination, and shipped. On the import side, they worked with Customs brokers for classification, confirmed country of origin, declared value, and arranged for delivery.  Ahh—the Good Old Days!

The landscape has dramatically changed, and the old ways are completely outdated. Export sanctions and tariffs are driving corporate strategy, security policy, and decisions regarding where in the world to do business. Trade compliance organizations now have a seat at the leadership table, helping to determine where in the world to source and build products, and what companies and people you can sell to and ship to. Government agencies are becoming much more aggressive, and trade compliance groups find themselves having to defend their decisions. These battles have become much more complex, time-consuming, and costly.

Trade fraud task force

On Aug. 29, 2025, the U.S. Department of Justice, together with the Department of Homeland Security, announced an Interagency Trade Fraud Task Force. This new interagency group is aimed at aggressively pursuing parties who evade tariffs and other duties. Now, tariff problems are increasingly treated as potential fraud, not just clerical errors. The importer is held responsible, not the Customs broker.

On the export side, the use of software tools and intelligence gathering by the Department of Commerce and the Department of Defense has resulted in intense scrutiny on exports to companies and people on the Denied Persons list, and on the export of technology products.

Benchmarking trade compliance organizations

We recently conducted a benchmarking study to determine how companies are organizing to respond to these changes in trade compliance. Trade compliance organizations have gained more stature and visibility, and now often contribute to strategic decisions in sourcing and manufacturing locations. These organizations are more likely to work closely with legal and tax departments in their companies. This is a major change from compliance organizations in the 2010s and before, which were considered administrative and tactical.

The people have changed

Today’s trade compliance organizations have added lawyers and experienced customs brokers to their staff. Hiring now includes professionals with advanced degrees and experience in strategy roles. The work and responsibilities have changed and so have the skills required of trade compliance professionals.

Organizational structure

Many companies have split their trade compliance organizations into two separate groups for imports and exports. Import compliance is now typically organized under finance/tax, with a dotted line to legal. This is because of the major financial impact of import tariffs that are treated as taxes. The legal connection is particularly important, too, as classification changes on products, to take advantage of different Harmonized Tariff (HTS) numbers and lower tariff rates, may be later investigated by Customs, and the reasons for the changes will have to be legally defended.

Export compliance groups are now often organized under the Legal department. Federal enforcement agencies have signaled a more aggressive posture and are coordinating with other agencies to pursue export violations, particularly for misclassifying goods, and shipping to denied persons and parties.

Software changes

Some larger companies have moved away from trade compliance point-solution software to the use of trade compliance modules that are part of an ERP system, such as Oracle GTM and SAP GTS. This allows for full integration with other functions and data required for effective screening. It also enables faster and more efficient upgrades and reduces integration risk.

Industry coalitions and associations

Industry coalitions and associations have become a significant source of information and strategy development. Most companies are actively involved in organizations such as WITNC, PAEI, and attend seminars and conferences hosted by KPMG, Baker McKenzie, the US government, and others.

Companies must look ahead

Trade compliance will likely get more, not less, aggressive in the future. The use of data collection and AI will assist the government in finding and pursuing companies that violate import/export laws. It’s time to rethink your trade compliance organizational structure and prepare to defend your trade compliance decisions. The better, more informed, and justifiable decisions you make now will help to ease your global shipments and data transfers.

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