CBP and Treasury Tighten Customs and Treasury Reporting

Federal agencies are closing gaps between trade filings and financial enforcement, and businesses that operate across borders need to pay attention. A series of 2025 regulatory updates shows CBP and the U.S. Department of the Treasury moving toward tighter alignment of customs entry data, anti-money laundering controls, and sanctions screening — creating a compliance environment in which a single misfiled form can ripple across multiple agencies.

CBP Expands ACE Filing Requirements To Enforce Sanctions

U.S. Customs and Border Protection has rolled out new ACE reporting requirements in 2025, adding data elements for merchandise linked to Russian seafood and diamond sanctions. Importers must now declare the country of harvest, harvest method, vessel details for certain seafood, and country of mining for applicable diamonds. CBP also requires a specific document code for importer self-certifications submitted through the Document Image System.

These additions reflect a broader push to embed OFAC sanctions screening directly into the customs entry process, making ACE a frontline enforcement tool rather than a simple trade-processing platform.

FinCEN Slashes Currency Transaction Report Threshold to $200 at Border

On the Treasury side, FinCEN issued a Geographic Targeting Order in March 2025 requiring certain money services businesses in southwest-border ZIP codes to file Currency Transaction Reports at a $200 threshold — far below the standard $10,000 trigger. The order accompanied a large-scale enforcement operation that drew on more than 1 million CTRs and 87,000 Suspicious Activity Reports, with referrals to the IRS and coordination with Homeland Security.

FinCEN also revised its beneficial ownership reporting rules, exempting U.S.-created entities while maintaining filing deadlines for certain foreign entities registered to do business in the United States. The combined effect signals that Treasury views border-adjacent financial activity as a priority enforcement zone, with reporting obligations now calibrated to capture transactions that previously fell below federal radar.

Treasury Flags Trade-Based Money Laundering, Pushes Interagency Data Sharing

Treasury's 2024 illicit-finance strategy identifies trade-based money laundering as a significant national threat. The strategy sets benchmarks for stronger interagency coordination, including through Homeland Security Investigations' Cross-Border Financial Crime Center. GAO auditors have echoed those concerns, finding that cross-border financial crime frequently falls into agency silos.

The International Trade Data System, built into ACE, is a single-window model in which traders submit data once and participating agencies access what they need. That infrastructure now serves double duty as a compliance checkpoint.

Agencies Heighten Scrutiny on Customs Valuation and Cross-Border Tax Reporting

For importers, accurate customs valuation on Form 7501 remains critical. CBP requires proper reporting of additions such as assists, royalties, and selling commissions, with reconciliation deadlines of 21 months for value and classification issues. Misstatements that once stayed within CBP's orbit can now surface in Treasury data systems.

Cross-border taxpayers also face FBAR filing requirements for foreign financial accounts with aggregate balances exceeding $10,000, due April 15 with an automatic extension to October 15. Separate Form 8938 obligations may apply depending on asset thresholds. Under the Bank Secrecy Act, discrepancies between customs declarations, foreign account disclosures, and anti-money laundering monitoring can trigger simultaneous scrutiny from CBP, FinCEN, IRS, and OFAC.

Compliance Teams Race To Align Internal Systems With New Requirements

Affected businesses should assume that customs, sanctions, AML, and tax reporting will become increasingly interoperable. That means reviewing current ACE filing practices, customs valuation documentation, sanctions certifications, and foreign account reporting procedures to ensure consistency across all submissions. Companies that rely on siloed compliance teams — where trade, tax, and AML functions operate independently — face the greatest exposure.

The safest approach is to monitor updated instructions from CBP, Treasury, FinCEN, OFAC, and the IRS, test whether internal systems can capture newly required data elements, and involve qualified customs counsel and tax advisers before mismatches become penalties or enforcement referrals.

Sources

• U.S. Customs and Border Protection — ACE and Automated Systems
• FinCEN — Beneficial Ownership Information Reporting
• IRS — FBAR Filing Requirements

‍By William Mc Lee, Editor-in-Chief & Tax Expert—Get Tax Relief Now