New Year, New Tariffs, New Enforcement: What 2026 Has in Store with Braumiller and Tuttle

Hosts: Andy Shiles & Lalo Solorzano

Guest(s):




• Adrienne Braumiller, Founder, Braumiller Law Group (https://www.braumillerlaw.com/)


• George Tuttle III, Founder, Tuttle Law Offices (https://tuttlelaw.com/)




Published: January 2026

Length: ~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 warnings


• Country of origin and transshipment risks are at the top of CBP’s priority list


• Valuation scrutiny is increasing, including challenges to DDP deductions


• Non-resident importer structures are under growing pressure


• False Claims Act cases tied to customs violations are exploding


• Whistleblowers can receive significant financial rewards


• Section 232 derivative product valuation remains dangerously unclear


• Importers must actively document reasonable care — not rely on suppliers



⚠️ Compliance & Enforcement Trends Discussed



• CF-29 notices issued without prior CF-28 requests


• Immediate investigations launched with no warning


• Increased seizures and penalties tied to origin misrepresentation


• Surge in enforcement actions under anti-dumping and countervailing duty laws


• Growing risks tied to supplier trust without verification


• Heightened scrutiny of steel, aluminum, and copper derivative products



⚖️ Legal & Policy Topics Covered



• Presidential authority under IEEPA


• Supreme Court challenges to tariff authority


• Refund uncertainty if tariffs are ruled unconstitutional


• Protests vs. post-liquidation remedies


• Section 232 valuation disputes


• Customs’ evolving enforcement posture



👥 About the Guests


Adrienne Braumiller is the founder of Braumiller Law Group (https://www.braumillerlaw.com/) 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 (  / adriennebraumiller  ) .



George Tuttle III is the founder of Tuttle Law Offices (https://tuttlelaw.com/) 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 (  / george-tuttle-iii-89b6707  ) .


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