Hosts: Andy Shiles & Lalo Solorzano
Adrienne Braumiller, Founder, Braumiller Law GroupGeorge Tuttle III, Founder, Tuttle Law OfficesLength: ~41 minutes
Presented by: Global Training Center
🧭 Episode Summary
Andy and Lalo kick off the new year with two of the most respected voices in international trade law — Adrienne Braumiller and George Tuttle — for a candid, fast-moving discussion on what importers should expect in 2026.
From skyrocketing tariffs and aggressive enforcement to constitutional questions surrounding presidential authority, this episode unpacks how the trade landscape has fundamentally shifted. Adrienne and George explain why many companies are feeling overwhelmed, how Customs enforcement has intensified, and where importers are most exposed — especially around country of origin, valuation, non-resident importers, and Section 232 derivative products.
The conversation also dives deep into IEEPA tariffs, potential Supreme Court rulings, refund uncertainty, and why enforcement actions like CF-29s, investigations without prior notice, and False Claims Act cases are becoming far more common.
If you import goods into the U.S. — especially steel, aluminum, copper, or products subject to anti-dumping or Section 301 — this episode is essential listening.
🗝️ Key Takeaways
Average U.S. duty rates have jumped from under 2% to as high as 15–17%Enforcement is accelerating — often without CF-28 warningsCountry of origin and transshipment risks are at the top of CBP’s priority listValuation scrutiny is increasing, including challenges to DDP deductionsNon-resident importer structures are under growing pressureFalse Claims Act cases tied to customs violations are explodingWhistleblowers can receive significant financial rewardsSection 232 derivative product valuation remains dangerously unclearImporters must actively document reasonable care — not rely on suppliers⚠️ Compliance & Enforcement Trends Discussed
CF-29 notices issued without prior CF-28 requestsImmediate investigations launched with no warningIncreased seizures and penalties tied to origin misrepresentationSurge in enforcement actions under anti-dumping and countervailing duty lawsGrowing risks tied to supplier trust without verificationHeightened scrutiny of steel, aluminum, and copper derivative products⚖️ Legal & Policy Topics Covered
Presidential authority under IEEPASupreme Court challenges to tariff authorityRefund uncertainty if tariffs are ruled unconstitutionalProtests vs. post-liquidation remediesSection 232 valuation disputesCustoms’ evolving enforcement posture👥 About the Guests
Adrienne Braumiller is the founder of Braumiller Law Group and a nationally recognized authority on customs law, trade remedies, and tariff mitigation strategies. She is known for helping companies navigate high-stakes enforcement actions and complex regulatory challenges.
Connect with Adrienne on LinkedIn.
George Tuttle III is the founder of Tuttle Law Offices and a leading expert in customs compliance, valuation, country of origin, and enforcement defense. George regularly advises importers on navigating audits, penalties, and evolving CBP interpretations.
Connect with George on LinkedIn.
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