Issue link: https://iconnect007.uberflip.com/i/1547450
54 SMT007 MAGAZINE I NOVEMBER 2026 expanded ownership and supply-chain disclosures, good-standing requirements, a registry and risk tiers, and enhanced vetting. Under the order, foreign IORs are prohibited from informal entries and generally restricted from using continuous bonds for formal entries. They also need CTPAT validation, if eligible, or a CTPAT-validated licensed broker. What this means for businesses is that, while DDP terms remain contractually available, foreign sellers may find performance more expensive, more diffi- cult, or more structurally complex. Where DDP terms cannot be used, a U.S. buyer may need to take over IOR obligations, inheriting responsibility for customs clearance and everything that comes with it—classi- fication, valuation, origin, tariffs, recordkeeping, and admissibility—not just a freight invoice. Tariff Evasion Vs. Optimization Given all the mounting pressures on landed costs, the temptation to take shortcuts to avoid tariffs can be strong. The government, however, is taking aim at those who evade tariffs unlawfully. Stood up in August 2025, the DOJ-DHS Trade Fraud Task Force recently surpassed $1 billion in civil and criminal recoveries, penalties, forfeitures, and publicly charged losses in under a year. False origin and transshipment, misclassification, undervaluation, shell or nominal IOR structures, free-trade-agree- ment fraud, and forced-labor violations are in the government's crosshairs. Next, I'll examine how the government is using the False Claims Act, along with administrative penalties and criminal customs statutes, to target bad actors and tariff evaders. I'll also take a look at the legal and supportable ways to reduce tariff burdens, which are becoming a critical aspect of a broader supply chain and cost optimization strategy for companies in the electronics industry. Tariff Terminal is a series exploring how trade policy, tariffs, and customs developments impact the electronics manu- facturing industry. James Kim is an international trade lawyer at ArentFox Schiff LLP. Tariff Terminal