Global trade compliance isn’t what it once was. Leveling of volatility doesn’t seem likely. Alyson Potenza, Emal Ehsan and Sydney Hurst of Kearney write that organizations treating compliance transformation as a strategic priority will be better positioned to navigate tariff volatility, maintain audit readiness and sustain performance through global trade disruption.
Global trade is undergoing structural transformation. The era of relatively stable, rules-based commerce characterized by predictable tariff schedules, consistent enforcement and incremental regulatory change has given way to one defined by geopolitical fragmentation, escalating enforcement and a pace of policy change that outpaces the capacity of most organizations to respond.
For trade compliance leaders, the implications are profound. Operating models that were designed around stable processes, decentralized execution and reactive compliance are no longer adequate.
The global trade order has fractured. That is a given. US tariff policy has become a moving target: the 2025 surge of IEEPA actions and Section 301 measures, the Supreme Court’s invalidation of the IEEPA tariffs and the immediate pivot to a 10% global tariff under Section 122 — all within the span of months. The EU also has turned markedly more assertive, pairing its anti-coercion instrument with a fully implemented carbon border adjustment mechanism that embeds carbon pricing into import economics. China-anchored supply chains continue to fragment under new export controls on critical minerals.
Regulators are signaling a clear shift: Compliance programs will be evaluated not on whether policies exist but on whether controls function effectively in practice. The DOJ‘s updated “Evaluation of Corporate Compliance Programs” emphasizes structural independence of compliance functions from business operations, sufficient autonomy and resourcing and demonstrable effectiveness. Customs and Border Protection collections from importer audits exceeded $235 million in 2025, with audits consistently targeting recurring control failures and gaps in appropriate documentation.
Further, the proliferation of enterprise systems has created a paradox: more data than ever, yet less visibility. In many large organizations, critical trade data like tariff schedule codes, country of origin and customs valuation exist across multiple systems with no authoritative single source of truth. Data moves sequentially among platforms through manual handoffs, creating reconciliation gaps and audit exposure.
A critical component to success
In the old model, cross-functional engagement was episodic where trade compliance was pulled into a conversation after a problem had already materialized. A sourcing shift had been finalized. A product had already launched. A network redesign was 80% complete. Compliance was left to manage the consequences rather than shape the decision.
In the new model, cross-business unit collaboration is structural, not incidental. Compliance governance sits in standing forums alongside finance, procurement, commercial and supply chain leadership. Decision rights are explicit and escalation paths are defined. And critically, trade intelligence is embedded into the planning processes where it can actually change outcomes versus trying to solve problems after decisions are made.
This is particularly consequential for network design. As companies reassess their manufacturing footprints in response to tariff volatility, the question of where to produce, where to stock and how to move goods across borders is inseparable from trade compliance strategy. Qualification thresholds of the USMCA, free trade zone designations and country-of-origin rules are not compliance footnotes. They are inputs to capital allocation decisions.
Further, as trade policy has become a primary instrument of geopolitical competition, the ability to read the regulatory horizon and translate it into operational strategy has become a genuine source of competitive advantage.
This means monitoring legislative and regulatory developments across jurisdictions, modeling the operational implications of policy scenarios before they materialize and surfacing insights that inform sourcing strategy, network design and commercial planning. It means moving from a function that answers questions to one that asks them before the rest of the business has to.
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No operating model can function without a robust data foundation, yet data management is consistently the most underinvested and most consequential capability gap in multinational organizations. Fields that should be locked sit open for any user to modify, so the same product can carry different classification codes in different systems, creating silent audit exposure that compounds with every transaction.
Building a sound data foundation requires five pillars:
- Single source of truth: Designate one authoritative system per trade data element (e.g., harmonized tariff schedule codes, country of origin, valuation) each with a defined home from which other platforms inherit.
- Clean and accurate data: Establish data quality baselines and ongoing cleansing protocols. Audit existing records for missing supplier codes, inconsistent naming conventions and classification mismatches.
- Streamlined data accountability: Assign clear ownership for data quality, with defined responsibilities, escalation paths and performance metrics tied to accuracy.
- Business-centric data catalog: Create a cataloged inventory of all trade-relevant data elements, their source systems, transformation rules and downstream dependencies.
- Common data structure: Standardize formats, naming conventions and integration protocols across all systems to enable automated validation and exception handling.
The objective is to move from a reactive data environment where teams manually extract data from multiple systems and reconcile discrepancies in spreadsheets to a governed architecture where information flows through an integration layer, is validated automatically and is available to all stakeholders in an analytics-ready format.
Scaling the model from pilot to global standard
Most trade compliance transformations begin at a single site typically where cross-border volume is highest, compliance risk most acute or operational challenges most pressing. This is appropriate. A site-level transformation provides a controlled environment to test assumptions, refine processes and build organizational confidence before scaling.
However, the design must be global from the outset. Operating model principles, governance frameworks and process standards developed at the pilot site should function as global templates that can be adapted to regional regulatory requirements without being reinvented. The scaling pathway typically follows a pattern: initial deployment at the highest-complexity site, extension to adjacent operations within the same region then expansion to other regions with local regulatory adaptation. At each stage, the core model remains consistent while the execution layer accommodates jurisdictional nuance.
Trade compliance has historically operated in the background of supply chain management as a necessary cost but managed reactively and rarely elevated to the strategic agenda. That era is over.
The convergence of geopolitical fragmentation, regulatory escalation and data complexity has turned trade compliance from a back-office cost into a source of material enterprise risk — and material enterprise value.
These forces are secular, not cyclical, and they will only deepen. Companies that invest now in a compliance-first, centrally governed operating model will not only reduce their exposure to present risks; they will build a scalable platform that can flex to whatever the next disruption brings.
