CBP AI Enforcement: Why Your Import Data Is Being Scanned

U.S. Customs and Border Protection (CBP) is now using artificial intelligence to scan import data in real time. The system checks tariff classification, declared value, and country of origin — automatically, on every shipment. At the same time, the Department of Justice (DOJ) launched a Trade Fraud Task Force that combines civil and criminal enforcement into a single unit. For anyone involved in export or import documentation, the rules of the game just changed.

This article explains what CBP's AI checks, how the new enforcement pipeline works, and what importers and exporters should do now.

Why Is CBP Using AI to Scan Import Data?

CBP is using AI because the volume and complexity of trade fraud has outpaced what human reviewers can catch. In October 2025, CBP awarded an exclusive, multi-million-dollar contract to Exiger, a supply chain AI company, to deploy its Trade AI platform across CBP enforcement offices nationwide. According to the Exiger announcement, the system is designed to detect illicit transshipment — the practice of routing goods through intermediary countries to hide their true origin.

But the AI does more than catch transshipment. According to the same announcement, the platform is built to validate tariff classification, declared value, and country of origin using AI-enabled checks. It can also create automated bills of material for products, map the flow of raw materials through global supply chains, and assign real-time risk scores to individual shipments.

This is not a pilot program. CBP had already contracted with another AI firm, Altana, in 2023 to provide supply chain intelligence for trade targeting. The Exiger contract expands this capability significantly, giving CBP enforcement personnel across the country access to the platform.

What Does CBP's AI Actually Check?

CBP's AI platform checks three core data points on import entries: tariff classification (Harmonized Tariff Schedule codes), declared customs value, and country of origin. These are the same three fields that determine how much duty is owed — and they are the most common sources of errors and fraud.

The system goes beyond surface-level data matching. According to Exiger's published capabilities, the platform can:

Enrich CBP system data with proprietary trade intelligence to improve decision-making
Map supply chains from finished goods down to raw materials and sub-components
Generate automated bills of material for imported products
Score shipments for risk in real time and flag anomalies before clearance

What this means in practice: if your declared value looks low compared to similar products, the AI flags it. If your HS code doesn't match the product description pattern, the AI flags it. If your goods shipped from a country that doesn't typically produce that product, the AI flags it. These flags can trigger a CF-28 (Request for Information) from CBP — and that is where the new enforcement pipeline begins.

What Is the DOJ Trade Fraud Task Force?

On August 29, 2025, the DOJ and the Department of Homeland Security (DHS) launched a cross-agency Trade Fraud Task Force. According to the official DOJ announcement, the Task Force integrates prosecutors and trial attorneys from both the DOJ's Criminal and Civil Divisions with CBP and Homeland Security Investigations (HSI).

This is significant for one reason: trade fraud enforcement now has both civil and criminal teeth in one unit. Before the Task Force, customs penalties were mostly civil — monetary fines under the Tariff Act. The Task Force explicitly states it will pursue criminal prosecutions under Title 18 trade fraud and conspiracy provisions, with penalties that can reach up to 20 years of imprisonment, according to legal analysis by DLA Piper.

The Task Force targets several specific violations:

Tariff evasion through misclassification or undervaluation
False country-of-origin declarations
Transshipment schemes to circumvent duties
Smuggling of prohibited or counterfeit goods

According to Acting Assistant Attorney General Matthew R. Galeotti, trade fraud is now a top-tier DOJ enforcement priority, not a niche customs matter.

How Do CF-28 Requests Lead to Criminal Charges?

A CF-28 is a formal request for information from CBP. It asks importers to provide documentation or clarification about an entry filing — typically within 30 days. Trade attorneys reported a noticeable rise in CF-28 issuance throughout 2025, according to industry reporting by Sobel Network Shipping.

The enforcement escalation works like a pipeline:

Step 1: AI flags an anomaly in your entry data — a classification that looks off, a value that seems low, or an origin that doesn't match the supply chain pattern.

Step 2: CBP issues a CF-28 requesting supporting documents. You have 30 days to respond with accurate, complete information.

Step 3: If your response is insufficient, CBP issues a CF-29 (Notice of Action). This means CBP has already made a determination — they may reclassify your goods, adjust the duty rate, or assess additional duties.

Step 4: Under the Trade Fraud Task Force, the case can be referred to DOJ for civil penalties under the False Claims Act (FCA) or criminal prosecution. The DOJ has already secured multiple FCA settlements in trade fraud cases in 2025, including a $6.8 million settlement in July 2025 and a $12.4 million settlement in August 2025.

What makes this pipeline more dangerous now is the whistleblower element. In May 2025, the DOJ's Criminal Division expanded its Corporate Whistleblower Awards Pilot Program to cover trade, tariff, and customs fraud. According to Acting AAG Galeotti's September 2025 remarks, the Division received 313 whistleblower tips in just four months, with 120 warranting further investigation. The DOJ also encourages whistleblowers to use the FCA's qui tam provisions, which allow private citizens to file lawsuits on behalf of the government and share in any financial recovery.

What Should Importers and Exporters Do Now?

The combination of AI-powered targeting and criminal enforcement creates a new compliance reality. Here is a practical checklist for companies involved in cross-border trade:

Audit your top SKUs. Review HTS classification, declared value, and country of origin for your highest-volume products. These are the entries most likely to draw AI attention.
Check document consistency. Your Commercial Invoice, Packing List, Bill of Lading, and entry filings should all match — product descriptions, quantities, values, and origin. A single mismatch is exactly the type of anomaly AI is trained to catch.
Verify your supply chain documentation. If your goods pass through multiple countries before reaching the U.S., make sure you can document the manufacturing origin with bills of material, production records, or certificates of origin.
Consider voluntary self-disclosure. The DOJ's Task Force announcement explicitly encourages importers to self-audit and voluntarily disclose violations. Under the Corporate Enforcement Policy, companies that self-disclose can receive a declination of prosecution — the Task Force issued its first such declination in December 2025.
Treat CF-28 responses seriously. A CF-28 is not routine paperwork. It is the first step in an enforcement pipeline that can escalate to criminal charges. Respond with complete documentation within the deadline, and consider engaging trade counsel.

The shift is clear. CBP now has AI that scans every data point. DOJ has a task force that prosecutes. And whistleblowers have a financial incentive to report. The time to check your documents is before the system checks them for you.

Key Takeaways

CBP's AI platform checks tariff classification, customs value, and country of origin in real time
The DOJ Trade Fraud Task Force combines civil and criminal enforcement with penalties up to 20 years
CF-28 issuance is increasing as AI flags more anomalies in import data
Whistleblower programs now cover trade fraud — 313 tips received in four months in 2025
Voluntary self-disclosure can result in a declination of prosecution