Innovation in a Dynamic Trade Environment: CBP’s Trade Enforcement Mission Part 1

Welcome to “HSDF THE PODCAST,” a collection of policy discussions on government technology and homeland security brought to you by the Homeland Security and Defense Forum

 Trade just got harder, faster, and far more granular—and we’re on the hook to make it work at the border. With a surge of White House trade actions and hundreds of new tariff lines, the old duty math has evolved into a puzzle of components, end uses, and origin rules that demand proof down to where raw materials were pulled from the ground. We walk through how our teams turn policy into action, adjusting systems, issuing guidance, and enforcing at ports while keeping legitimate commerce moving at the speed of electrons.

 Featuring:

• Brandon Lord, Executive Director, Office of Trade Policy & Programs, CBP
• Eric Choy, Executive Director, Trade Remedy Law Enforcement, Office of Trade, CBP 
• C. Shane Campbell, Executive Director (Acting), Cargo and Conveyance Security, Office of Field Operations, CBP
• Brenda Smith, Former EAC for Trade, CBP (moderator)

 This discussion took place December 12, 2025 at 8th Annual Homeland Security & Defense Forum Border Security Symposium

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Transcript

Setting The Stakes: Trade And Tariffs

From Simple Duties To Complex Rules

SPEAKER_00 0:08

Well, good morning. And all of you who have gone to get coffee, you need to come back because this will be the best panel of the day. So we're really excited to be here. The trade mission is one of those that in your world doesn't always get a lot of exposure. But this year has been an amazing year for CBP's people, for its capabilities and for its impact on the global trading order. We have seen 45, I think that's the latest count, White House actions specifically focused on trade. That is an amazing amount of activity. There have been two nearly 260 new tariff numbers, which in our world really matters. It's a huge, much greater number than we've ever seen before. CBP has collected over$225 billion in revenue. It's a big number, far bigger than it was when I was with CBP. 150% increase over last year. Lots of enforcement actions, lots of shipment detentions. And my question for the panel today is really how does that work? And what do you need to do an even better job of enforcing US trade laws? So, Brandon, um, thanks for being here. Let's start with an overview of really what the CBP's trade mission is and the significance of all this tariff activity for DHS and CBP.

SPEAKER_02 1:54

Sure. Yeah, absolutely. And pleasure to be here. Uh, it's good to be with you all this morning and appreciate you all taking time out of your day. You know, so let me just start by saying, you know, that we're up here talking about trade. We're really talking about the customs mission, right? And the customs mission in the United States started with the very founding of our country. And the revenue collection that the customs service uh pulled in from the beginning of our republic uh really powered our growth uh largely through uh arguably the beginning of the 20th or middle of the 20th century. So we've been collecting revenue for a very, very long time. We're very good at it, right? What has changed uh is not just the scale, the numbers that Brenda mentioned, but also the complexity, right? So historically, it was relatively straightforward on how to on how to calculate a tariff, right? You would just say, what is the product? How much is it worth, which country is it from, and you do some very basic math uh with a percentage multiplied by the value of that good. But now what we're increasingly seeing, and this is this is not just new in the last few months, it's just been turbocharged in the last few months. We're seeing tariffs on components of a finished product, right? So I just want to put a tariff on the steel in the finished thing, right? We're seeing uh tariffs that are based on end use provisions, right? You have to pay a tariff on this thing unless you intend to use it for this process, right? Uh we're seeing tariffs on where was the thing originally mined or where was the thing uh originally melted or poured or formed that goes into a finished good, right? And what that's leading to is super interesting like concerns from the trade that frankly concern us. You know, comments like, well, I don't know where the steel came from in my finished product, but I know it didn't come from Russia, so please don't make me pay the Russia 200% tariff, which is a law enforcement agency for us that's like just stop and play the tape back for a minute. Uh that that's not a convincing enough argument, right? So this is what is fun, this is the fundamental shift. And it started in 2018 and has continued through to present day, but certainly has been turbocharged in the last few days. And this is this is like the challenge of the moment in the custom space uh and in our mission set within CBP. How do we address what I'll just kind of call these new and innovative ways to assess tariffs on products coming into the United States?

Turning Policy Into Practice At CBP

SPEAKER_00 4:37

Great overview. It really comes down, I think, for CBP to its people, right? Um and how who really is enforcing the law? Um we have a lot of folks in uniform that do that. We have a lot of folks who are not in uniform that are really part of the trade team. Um you work closely with a lot of trade policy agencies, but CBP is where the rubber meets the road because you're the implementers. Can you talk a little bit about who is implementing and kind of what their skill sets are?

SPEAKER_02 5:16

Yeah, absolutely. And I'll I'll start and then I'll I'm gonna throw it to my colleague Shane Campbell, because we we are sort of a the two-headed monster here, right? So you you know what what happens when a trade action comes down, you know, the the what I call sort of the capital T, capital P trade policy agencies in the US government. So commerce, USTR, uh sometimes the Treasury Department. Um when they make a decision, it comes to CBP to enforce that decision. Right? And so when that happens, we have to be savvy enough to examine the legal documents that have that have established that decision, established that that that uh that tariff. We have to then figure out how that intersects with our people, our processes, our tools, our own legal authorities, our IT systems, make the updates to those things that are needed, right, and provide guidance to importers and customs brokers on how to comply with that new tariff. And all that has to be done at the speed of executive decision making, which, as Brenda mentioned, we're well over 40 presidential decisions on tariffs in the last 11 months. So we do move very fast. When that is put in place, it comes down to our personnel at our ports of entry in the field, in the Office of Field Operations, to work the actual enforcement of those rules and frankly to let us know over on my side if we need to tweak any of those things. And so I'll turn it over to Shane to talk about how that actual enforcement occurs once we get these things put in place. Sure.

Field Operations And Hidden Experts

SPEAKER_03 6:58

So Brandon's probably got the worst job, right? Because he's got to do the policy aspect of this. Um, my job is relatively easy. We have to, like within the Office of Field Operations, particularly in my role within CCS, I have to figure out how to implement that policy at the 328 ports of entry that we have, along with some of our international footprint. And so when you corral over 67,000 employees of CBP and put them into this mission, um, usually those of us in uniform, like that's that's who you typically see, right? If you're crossing an international border or if you see something on National Geographic, they're usually focused on the uniforms, right? Not CBP officers, agriculture specialists, border patrol, air marine, those folks. But really, the hub of it are those experts that are behind the scenes, right? My job as an officer is relatively easy. I see a box, I open the box, I think it's suspicious, and then I hold the box, and then I let our true cargo and trade experts come in. That's our import specialists, the entry specialists, trade specialists, and others that come in, laboratories and scientific services. And those are those are like all the unsung heroes that are helping us make those decisions on the front line. And can't give those folks credit enough because they allow us to do our job better at protecting this country from bad stuff and bad people coming in. So as they're working to help give us the advice if something is admissible or not admissible, or what to look for, what questions to ask, right? I really can't overstate the importance of what it is, of what they do and what they bring to CBP as an agency. So that I I don't I don't know how deep to go into the enforcement part, because when when folks ask me, like even my kids ask me, like, what do you do? And I'm 30 years into this job, I can't like in a single sentence or paragraph explain what it is that I do because it is so varied and so complex. And as we talked about at the very beginning, it changes on a day-to-day basis, right? And I think that's like a key is that when when asked what I'm doing, I probably should just say, I do what it takes to make this country safe and secure. Whether that's in the passenger or the cargo or any other environment, is that's my job, is to try to make this country as secure as we can.

SPEAKER_00 9:12

Great, thank you. So let's let's dig a little deeper and give you a little bit more time to describe the impact on CBP of all this White House activity. And I'm gonna ask first Shane and then Eric to talk a bit about what enforcement really looks like at CBP.

Enforcement In A Faster Policy Cycle

SPEAKER_03 9:35

Sure. So um, particularly with the new executive orders that have come out, right? It's new complexities that Brendan explained. It's digging deeper than probably we have been digging. Um, not saying that necessarily in a bad way, but it's it's helping us to rethink how we can get better positioned to make sure that we level the playing field for the United States compared to some of our foreign competitors, right? So we dig a little bit deeper into uh the paperwork, into um the actual physical cargo that's in front of us. And to do this at speed, right? Some of the the data moves at the speed of electrons, right? That's amazingly fast. And for a lot of our processing, it's literally cleared at the speed of electrons. So we have to make sure, like when I talk about those specialists, those hidden folks behind the scenes, like our OIT programmers and all those other folks, they have to make sure that those algorithms are set just right, that the the keys that they put in our system for us to look for are just right. So I'm not really sure what am I missing here.

Who Actually Enforces Trade At Ports

SPEAKER_01 10:45

So so really just kind of echoing behind Shane and Brandon in the sense that you know, when we looked at, you know, the new America First Trade Policy has really put uh trade at the forefront of the national security as a key part of national security. It's economic security, which is national security. And really what that has changed fundamentally is that that trade enforcement has really come to the forefront, and not only here within the agency, uh, but within the department and broadly across the federal interagency has really coalesced more or less to really come together to really look at those things that Shane had mentioned, right? Where does economic security, we're at the intersection of economic security, the different roles and responsibilities across the various departments and agencies, how do we intersect? How do we work better together to really chip away at this uh trade enforcement mission, right, collectively? But within the agency, broadly trade enforcement is done uh across the agency. So not any one office, not any one uh branch or division is focused on trade enforcement. They all all are a fundamental piece of the overall cog of enforcing the trade mission. Um, where things that um that have that uh you know is changed with regards to the American First Trade policy and the agency's renewed focus on putting enforcement up at the forefront is leveraging all those available authorities that the agency has uh to bear uh to enforce against those that are violating trade, uh that are committing trade fraud, and those are looking to evade uh the duties that are due to the country, right? So things like uh like our forced labor enforcement authorities, those are things that that one has driven over the past couple of years, has driven um renewed look at supply chains, right, which has now been somewhat prescient in the sense that that has driven industries, those are looking to comply and um and conduct lawful trade to to create tools and advanced tools that give a deeper look into where things are pulled out of the ground, where things are pulled out of the sea, because that supply chain visibility is required at time of entry. And those are also things that uh level the playing field between US businesses and the way businesses conduct um business overseas and uh and create unfair competition. Uh so these things that um that uh we're doing really is focusing on uh collecting the revenue is is is first and foremost, right? And then then focusing on protecting the US consumers, really those things that whether it's it's counterfeit goods or uh things like that are produced with force labor uh are creating safety, safety issues for the for the US consumers. Also protecting US industry, making sure that we're leveling the playing field, um, but then also chasing after it and and leveraging the maximum tools to put consequences on those who are looking to defraud the government and and evade the duties that are due to the government. And those, and that's how we work broadly together uh with not only on the policy side, but also with our operators in the field, but also in those authorities that we have within the agency to bring to bear.

SPEAKER_00 13:46

Great. Thanks, Eric. Um, I think that's a a good overview. And I think what I want to do is go off script a little bit and maybe take a step back and give our audience a better understanding of the field organization. How is CBP on the trade side organized? You know, they know Border Patrol stations, they know ports of entry, but who else is out there that enforces the law? And then Eric, I'm gonna ask you to dig a little bit deeper on those issues. You talked about counterfeit goods, but let's let's give a little bit more um understanding of what those laws are about and what are the big chunks of risk. So maybe Shane, if we could start with you.

SPEAKER_03 14:40

Sure. So if if we want to go at the port of entry level and go beyond our officers and agriculture specialists, right? We also have our centers of excellence and expertise, which houses our import specialists, uh entry specialists, drawback specialists. Um there's a conversation to like go down with drawback, right? Nobody ever wants to talk about drawing back.

SPEAKER_00 14:59

Nobody wants to talk about drawback.

SPEAKER_03 15:00

So we'll we're not gonna talk about drawback here either. Um, but our import specialists play a crucial, a vital role um in the cargo and trade environment. Um, like they they are the ones, um, I'll use textiles as an example, right? They are the ones who will dig into like containers with us, rolls and rolls of fabrics, and they can help us determine, hey, this was declared as 100% cotton. And they help us find is it really 100% cotton or is it 80% cotton, 20% of something else or other percentages? And that really helps make the determination as to whether or not like what the duty rates are, or if somebody is uh violating our anti-dumping, countervailing duties issues that we see on a frequent basis. Um, they those are the specialists that I talked about in the very beginning that help like they have different training, they have a different academy than we do as CVP officers. So they really know how to dig into the weeds. And then, of course, we have our laboratories and scientific services folks who, when we really have to go even deeper and we have to do analysis or pollen testing or getting into like fiber counts and things, like we can turn to our LSS counterparts who help us do that work.

Why Origin And Supply Chains Matter

SPEAKER_00 16:11

I love that you picked up on the laboratories and scientific services, because I know every trade person really relies on their analysis for things like um origin. Where did this good actually come from? Right. In my time, that for us, figuring out and and confirming origin, where did that good actually come from was a huge issue.

SPEAKER_03 16:39

And and that's crucial, right? So, well, like what's in the news recently, and we talk about oil and where does certain where does oil come from? Our LSS folks can tell us which regions of the world that oil is coming from on the tankers. They are they they dig deeper than I think most people expect, and they can give us really valuable information that not only protect the revenue, but also help the government enforce sanctions and other types of enforcement actions and revenue collection.

SPEAKER_00 17:08

Okay.

SPEAKER_01 17:09

And so certainly, you know, the laboratory and scientific services certainly they explore all available, you know, cutting edge technologies, working together with national labs and also capability providers as well to see what latest, latest um capabilities are available, you know, things that you know both Hashane and Brandon had mentioned, you know, is are important to understand. You know, when we talk about, you know, the some of the biggest challenges all kind of really go back to the origin of supply chain, the supply chain of the goods. So if we're talking about a specific tariff on a specific portion of a good, um, that necessarily like say the steel content within a good, then you know, understanding whether how that is that steel content is represented and how the tariff calculation is being done may or may not necessarily be accurately represented by the importer, may not be known by the importer, right? It may be, they may be taking representations based upon what was represented to them. And so being able to identify not only the origin of the goods, but all those that had a hand in the supply chain of making that good. I mean, if you talk about like a piece of machinery is fairly complex, uh, but say going back to something more simple, say like a shirt, um, you know, most folks would think, okay, well, shirt, you know, probably went, you know, you had fabric going to a factory, uh, and then that shirt was just sewn together and then shipped to the United States, right? But you know, it really goes back to like where does it, where was the cotton pulled out of the ground, right? Who who had a hand in spinning that cotton, making the thread, uh, making the fabrics, and then and then where those fabrics go to make the specific portions of the shirt, like you know, you know, the pockets, the different panels could all come from different manufacturers and different sources, um, especially if we're if we're looking at the lowest cost, you know, lowest costs available for those that are manufacturing them. And so understanding how that's all put together, how that all lends into the the duty calculations. There may be free trade agreements that affect that as well, right? Based upon where specific panels or threads come from that are part of where that shirt is being manufactured. Um so and all that is is something that needs to be accurately represented by the manufacturer, by the importer at time of entry. So we understand that the that we're collecting the the appropriate tariff rate, that we're are uh that the import that the goods that's coming in ultimately is admissible into the into the United States.

Tools: Labs, Forensics, And Data

SPEAKER_00 19:25

And we've seen, I think, in and that was a great description of, you know, you take a shirt that that most of us wear on a daily basis and really trying to break it down into where did it actually come from, um, is a challenge not only for CBP, but it's also a challenge for the private sector. Because the expectation is that the US importer will know where that shirt came from. And now it is not only where was the factory that actually sewed that shirt together located. But where did the pieces come from? Where did the basic materials come from? And so the onus on proving to CBP really falls on that US importer. And so as I think about the technology for origin verification certification, it is not important only to the government, but it's also important to the hundreds of thousands of US importers that are responsible for knowing the origin of their products. Could you give us a little bit of a view on what is the technology that you're using around origin? And from my perspective, I think it's a mix of testing, and you've put out some great guidance on isotopic testing, but it's also AI comes into play. Could you talk a little bit about those technologies? Any of the three of you, but maybe we'll start with Eric.

Proving Origin: Paperwork To Isotopes

SPEAKER_01 20:58

Well, certainly I think again, we're looking more broadly, you know, nothing comes, nothing can at this point in time, nothing really kind of uh makes up for the human uh, you know, on the ground, right? Our our import specialists, our officers on the ground, you know, looking, you know, having that day-to-day relationship with the importers, with the manufacturers, having those accounts and looking at the importations coming in day in and day out, and understanding what the environment looks at, and understanding when potentially an anomaly within those supply chains occurs. And that's what's occurring generally on a day-to-day in and day out basis at our ports of entry and at the centers of excellence. Now, certainly, you know, there are a lot of avenues by which you know allegations come in or awareness that maybe uh fraud could be occurring, or some type of verification that we could be doing just generally on a specific commodity within specific supply chains. And um, you know, and when we work together with the importer uh who is working with his or her manufacturers or their manufacturers, it really goes back to one, um, the paperwork. Uh, and it and right now it's relatively rudimentary in that sense, where the transactional paperwork between manufacturers, all those that had a hand within the supply chain is critical to demonstrate um provenance of the goods and where the goods originated from. So whether it's the cotton, going back to the shirt example, like understanding where the cotton came from, what field it came out of, you know, who had a hand in spinning it, and and things like you know, the purchase orders, the transportation documents, you know, two or three of those things that that represent kind of that transaction between uh business-to-business transactions are things that that importers are going are having to show to the centers and the ports to demonstrate the origin of those goods, right? And then and then there's also Shane had mentioned the scientific pieces where when we look at things that not necessarily we can look at scientifically and and through forensic process of understanding where that raw material actually came out of the ground, that maybe there's other areas like the pollen analysis or the dust analysis that's on top of a specific piece of equipment that could be analyzed that says, well, this piece of this pollen only exists in this part of the world. So potentially this thing probably came from this area. Or uh, you know, there is there is technology that shows that, you know, things like for cotton or even uh uh like petroleum-based goods, where you could do some type of scientific forensic analysis that shows that there is a specific like isotopic content within these goods that show that it came from, most likely came from this region of the world. Um, and these are all things, and then ultimately um then looking at the overall data, right? Um, you know, we have mass volumes of data, not only us, but with across the private sector. I mean, the industry has mass amounts of data that we're we're not necessarily at AI. I mean, we look at you know, process automations that can kind of condense down the volume of data that we have that gives us, gives us some ability to look at how things are kind of traveling through supply chains, how the business-to-business interactions are occurring that give us a general idea of that whether a good did actually come from a specific area or a specific company as represented in the documentation that comes in.

Closing Notes On Challenges And Tools

SPEAKER_00 24:08

Excellent. Really good picture, I think, of what the challenges that you're dealing with, and then some of the tools that you're using to address those challenges. Shane, I'm gonna again go off script and