Are You Customs Ready? How Importers Can Prepare for Increased Enforcement

Host: Lalo Solorzano & Andy ShilesGuest(s): Kathleen AugustPublished: August 27, 2026Length: ~30 minutesPresented by: Global Training Center Summary How ready would your company be if U.S. Customs and Border Protection came knocking tomorrow? In this episode of Simply Trade, hosts Lalo Solorzano and Andy Shiles sit down with former CBP auditor Kathleen August to discuss why being “audit ready” is no longer enough. With more than 33 years of experience on the CBP side of the desk, Kathleen offers an insider’s perspective on today’s enforcement environment and explains why importers need to become truly “Customs Ready.” The conversation covers the growing importance of CF28 responses, ACE data, internal controls, record retention, post-entry reviews, supply-chain visibility, and cross-functional communication. Kathleen also explains why having a trade compliance manual sitting on a shelf doesn’t equal an effective compliance program. Companies need procedures tailored to their operations—and executable tools that employees actually use. From unexpected changes in entered value to country-of-origin questions, forced labor concerns, USMCA documentation, and shifting sourcing strategies, CBP has more data and analytical capability than ever before. The message for importers is clear: know your data, know your supply chain, document your processes, and be prepared to respond before Customs asks the question. Main Topic / Discussion Being audit ready is important—but Kathleen argues that today’s importers need to go further and become Customs Ready. With CBP operating in an enforcement-focused environment, companies may encounter CF28s, questions about their supply chains, entry reviews, or other inquiries even if they are never selected for a full audit. Kathleen explains that a strong compliance foundation starts with documented internal controls tailored specifically to the company. But documentation alone isn’t enough. Companies need “executable documents”—checklists, logs, databases, classification records, broker procedures, and other tools that turn a compliance manual into everyday action. The discussion also highlights the importance of reviewing ACE data from CBP’s perspective. Changes in entered value, country of origin, classification, sourcing, or other entry information can create patterns that draw attention. As Kathleen puts it, Customs is like a highly capable chess opponent—and they may already be “two steps ahead.” Importers also need visibility beyond the trade compliance department. Sales, purchasing, engineering, finance, sourcing, and leadership can all make decisions that affect customs compliance. Tooling assists, supplier changes, certificates of origin, USMCA qualification, and sourcing shifts are just a few examples. Ultimately, becoming Customs Ready means building a system that allows the organization to identify problems, maintain records, respond to questions, and pivot quickly as tariffs and enforcement priorities change. Key Takeaways • Be Customs Ready, not just audit ready. A full CBP audit is only one potential compliance event. Importers also need to be prepared for CF28s, investigations, and questions about individual entries or their broader supply chain. • Document internal controls—and actually use them. Compliance procedures should be customized to the company rather than copied from a generic manual. Pair written procedures with executable tools such as checklists, CF28 logs, databases, classification records, and broker instructions. • Know what your ACE data says about you. CBP can identify changes and patterns across entries. Importers should review their own data for unusual shifts in value, classification, country of origin, sourcing, and other areas before those patterns generate questions. • Understand your entire supply chain. Know who you are buying from, where products and components originate, where transformation or assembly occurs, and when suppliers or produ