According to Supply Chain Dive, former U.S. Customs and Border Protection director Richard DiNucci emphasized during an October 15 Port of Los Angeles media briefing that maintaining strong industry connections remains critical for defending against shifting tariffs. DiNucci, now a senior international trade advisor at Venable LLP, warned that customs scrutiny is increasing daily, with many clients facing audits as authorities examine how revenue is being protected. He specifically recommended connecting with licensed customs brokers and becoming actively involved with industry trade associations, noting that the ongoing government shutdown has made accessing headquarters-level information particularly challenging. Despite the shutdown, both DiNucci and Port of Los Angeles Executive Director Gene Seroka confirmed that customs and ports remain fully operational with essential personnel continuing their work. This expert perspective highlights the growing complexity of international trade compliance in the current environment.
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The Compliance Landscape Shifts Dramatically
What DiNucci’s comments reveal is a fundamental shift in how U.S. Customs and Border Protection approaches enforcement. The days of routine compliance checks are giving way to sophisticated revenue protection initiatives that examine corporate structures and transaction patterns. Companies that previously relied on standard compliance procedures now face auditors who understand global supply chain optimization strategies and can identify when legitimate restructuring crosses into tariff avoidance territory. This represents a significant escalation in enforcement sophistication that many businesses remain unprepared for, particularly those without dedicated trade compliance teams.
Beyond Brokers: The Ecosystem Approach to Trade Intelligence
While DiNucci correctly emphasizes the value of licensed customs brokers, the real strategic advantage comes from building a comprehensive intelligence network. This includes relationships with port authorities, logistics providers, trade attorneys, and even competitors through industry associations. The most successful companies treat trade intelligence as a continuous process rather than a reactive measure. They monitor tariff developments in real-time, participate in comment periods for proposed trade rules, and maintain dialogue with multiple customs experts to cross-verify interpretations. This ecosystem approach provides redundancy when government access becomes constrained, as during the mentioned shutdown period.
The Hidden Risks of Operational Isolation
Companies operating without robust industry connections face multiple hidden dangers. First, they risk developing compliance strategies based on outdated or incomplete information, particularly problematic when dealing with the rapid pace of recent trade policy changes. Second, isolated companies miss crucial context about how enforcement priorities are evolving—what might seem like a minor operational adjustment could trigger significant scrutiny if it matches patterns customs officials are currently targeting. Third, during government disruptions like shutdowns, disconnected businesses lack alternative channels to resolve urgent questions, potentially leading to costly shipping delays or storage fees while awaiting clarification.
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Strategic Implications for Supply Chain Design
The increasing customs scrutiny DiNucci describes necessitates a fundamental rethinking of supply chain architecture. Companies can no longer design supply chains purely for efficiency and cost optimization—compliance resilience must become a primary design criterion. This means building flexibility into sourcing strategies, maintaining detailed documentation trails for every transaction, and developing contingency plans for rapid restructuring when tariff environments shift. The most forward-thinking organizations are now conducting regular “tariff stress tests” that simulate various trade policy scenarios to ensure their operations can adapt quickly without compliance breaches.
The New Normal in Trade Compliance
Looking ahead, the environment DiNucci describes appears to be the new normal rather than a temporary situation. Companies should expect continued intense scrutiny of their international transactions and increasingly sophisticated enforcement techniques. The organizations that thrive will be those that treat trade compliance as a strategic capability rather than a back-office function. This requires ongoing investment in relationship building, continuous education about regulatory changes, and developing internal expertise that can work effectively with external specialists. In this challenging landscape, DiNucci’s advice about industry connections isn’t just helpful—it’s essential for survival.
