What 2025 Taught Importers, Exporters, and Compliance Leaders Worldwide
Global trade compliance accelerated throughout 2025. Enforcement intensity remained high, sanctions programs expanded, export controls evolved rapidly, especially for advanced technologies and supply chain accountability continued to move from aspiration to operational reality.
But 2025 also widened the compliance perimeter. Beyond “classic” sanctions and export controls, trade teams faced additional pressure from evolving tariff policies, increased customs scrutiny of low-value e-commerce flows, expanded environmental trade measures, and a growing expectation that compliance programs be technology-enabled and audit-ready.
Across the United States, European Union, United Kingdom, Middle East, Africa, and Asia, regulators delivered a consistent message: compliance expectations are rising, and organizations must modernize to keep pace.
This article highlights the most significant global trade compliance developments of 2025 and outlines the trends trade and compliance professionals should prepare for in 2026.
Key Takeaways
- Sanctions and export control enforcement remained historically elevated in 2025, with large penalties and cross-agency coordination.
- Export controls for advanced computing and artificial intelligence (AI) stayed volatile. Rules shifted, but national security-driven enforcement continued.
- EU and UK sanctions regimes expanded and matured, with increased focus on circumvention and stronger enforcement infrastructure.
- Forced labor enforcement scaled significantly, creating direct shipment disruption and revenue risk.
- Tariffs, customs enforcement, and e-commerce import controls became more operationally disruptive, raising the importance of classification, origin, documentation, and landed-cost governance.
- Regulators increasingly expect technology-enabled compliance, while agencies expand their own use of data and analytics to detect risk.
Enforcement and Penalties: Corporate Exposure Remained Material
United States: sanctions enforcement stayed high impact
OFAC’s civil penalties in 2025 totalled approximately $265.7 million, including a single enforcement action exceeding $215 million.
For compliance teams, the message from OFAC’s 2025 posture is less about one large case and more about recurring control themes:
- Sanctions screening failures (including indirect exposure)
- Weak ownership/control analysis and escalation
- Insufficient third-party due diligence
- Poor auditability (what did you know, when, and what did you do?)
Export controls: “advanced tech” enforcement remained a priority
BIS export enforcement continued to focus on advanced computing, semiconductor ecosystems, and military end-use concerns. A notable example was Cadence Design Systems, which agreed to a $95 million BIS civil penalty for unauthorized exports to Chinese entities tied to military supercomputers.
Department of Justice (DOJ) announced a coordinated resolution in which Cadence agreed to plead guilty and pay over $140 million in combined penalties/forfeiture.
This type of coordinated civil/criminal approach reinforces a 2026 reality: high-risk export control matters increasingly involve multiple regulators, multiple legal regimes, and multi-year historical activity.
Sanctions: Expansion, Circumvention, and Multi-Jurisdiction Complexity
EU: accelerated packages and circumvention focus
The EU continued expanding Russia-related sanctions and intensified its emphasis on circumvention, including targeting networks supporting Russia’s “shadow fleet.” The Council’s May 2025 package explicitly highlighted shadow-fleet targeting as part of broader efforts to curb energy revenues and access to military technology.
This matters operationally because it increases risk in sectors that may not see themselves as “sanctions-facing,” including:
- Shipping, forwarding, and maritime services
- Insurers and finance-linked trade services
- Industrial exporters with complex distributor chains
UK: enforcement architecture matured
In the UK, enforcement capacity is no longer a future-state concept. The Office of Trade Sanctions Implementation (OTSI) published its first-year operational update (covering 2024–2025), reinforcing its role as a dedicated trade sanctions authority.
The Office of Financial Sanctions Implementation (OFSI) continued issuing penalties and public enforcement actions, reinforcing expectations not only around compliance but also responsiveness and cooperation when regulators request information.
Export Controls: AI, Semiconductors, and Regulatory Volatility
Few domains moved as quickly in 2025 as export controls on advanced technologies.
AI and advanced computing: the policy direction stayed clear even as mechanisms changed. Even where specific frameworks evolved, the strategic direction was consistent: governments are using export controls to manage national security risk tied to AI, advanced computing, and semiconductor-related ecosystems.
For exporters, cloud providers, and high-tech manufacturers, the compliance challenge is no longer simply classification. It’s the combination of:
- End-use/end-user risk assessment
- Entity/ownership screening
- Subsidiary governance
- “Deemed export” controls (people + data access)
- Operational controls (geo-fencing, account controls, licensing workflows)
Asia-Pacific: strategic trade controls tightened and enforcement moved closer to the supply chain
A major 2025 storyline—often missed in Western-only summaries—is that APAC enforcement and control updates increasingly intersected with U.S./EU export-control objectives.
Examples of “practical impact” developments include:
- Singapore’s heightened scrutiny of potential advanced chip diversion, including investigations and prosecutions connected to alleged illegal flows of controlled technology.
- Hong Kong updates its strategic commodities control lists to reflect changes adopted by leading international non-proliferation regimes.
- India’s Directorate General of Foreign Trade (DGFT) updates to the Special Chemicals, Organisms, Materials, Equipment, and Technologies (SCOMET) list, reflecting a broader tightening in emerging technology controls.
Forced Labor and Supply Chain Compliance: Operational Disruption Became the Metric
U.S. UFLPA enforcement reached scale
DHS reported that as of August 1, 2025, CBP had reviewed more than 16,700 shipments valued at almost $3.7 billion under the UFLPA framework.
This continues to shift corporate behavior: forced labor compliance is now directly tied to:
- Importability
- Delivery commitments
- Inventory planning
- Customer service levels
- Financial risk (detentions, delays, rework, and re-sourcing)
EU: enforcement infrastructure for forced labor controls advanced
Even where enforcement “go-live” timelines extend beyond 2025, 2025 mattered because it strengthened the institutional build-out and compliance expectations around supply chain traceability and proof of due diligence.
2026 implication: organizations should treat forced labor controls as part of trade execution, not just Environmental, Social and Governance (ESG) reporting.
Customs, Tariffs, and Import Controls: The “Other” Trade Compliance Pressure That Grew in 2025
A truly complete 2025 trade compliance summary must include the reality many importers felt most acutely: tariff volatility and customs friction.
Tariff shifts: compliance and landed-cost governance moved into strategic planning.
Major news coverage documented how U.S. tariff policy in 2025 increased uncertainty and operational planning complexity.
This matters for trade compliance because it amplifies the value—and scrutiny—of:
- Classification governance
- Origin determinations
- Free Trade Agreement (FTA) qualification support
- Landed-cost models and duty engineering controls
- Documentation and broker oversight
E-commerce and de minimis: higher documentation expectations changed the cadence.
A separate operational development in 2025 was increased scrutiny of low-value imports and documentation sufficiency, creating delays, holds, returns, and higher compliance overhead for many businesses, especially those reliant on cross-border parcel flows.
For 2026, this points toward more enforcement attention on:
- Product safety and admissibility (U.S. Food and Drug Administration (FDA)-style holds)
- Origin and valuation evidence
- Consistent entry documentation even for high-volume, low-value channels
Environmental and ESG-Linked Trade Measures: CBAM Became “Real” for 2026 Readiness
Carbon Border Adjustment Mechanism (CBAM): transitional phase ended and definitive regime planning accelerated
The European Commission’s CBAM guidance and updates reinforced that CBAM moves into its definitive regime from 2026 (following the 2023–2025 transitional phase).
In October 2025, the Commission published CBAM simplifications, including a 50-tonne annual threshold exemption (designed to reduce burden for smaller importers while still covering the vast majority of emissions in scope).
2026 implication: CBAM readiness becomes a cross-functional effort spanning trade, procurement, finance, and sustainability data, where audit-quality supplier information is the limiting factor.
Middle East and Africa: Growing Enforcement Relevance, Especially Through Transit and Customs
Middle East: compliance expectations rose alongside trade hub influence
For many global supply chains, Middle Eastern hubs are operationally critical. Especially for routing, re-exporting, and free-zone activity. Practitioner and investigations coverage in 2025 continued to highlight the region’s evolving risk and reform landscape around sanctions and export controls, particularly connected to re-export sensitivity.
Africa: customs integrity and origin verification remained central
While Africa’s sanctions landscape is more limited, customs enforcement and verification—classification, origin claims, valuation, and fraud prevention—remain the most consistent trade compliance drivers across many jurisdictions. In 2026, many global companies will continue to experience Africa compliance primarily through the lens of customs audits, broker governance, and documentation readiness.
Technology and Data: A Defining Theme Across 2025 Enforcement
Across major jurisdictions, regulators increasingly assess whether compliance programs are built to prevent violations—not simply respond to them.
This trend aligns with how enforcement agencies themselves are evolving: more analytics, more anomaly detection, more capacity to identify high-risk trade patterns.
A “modern trade compliance program” is increasingly expected to include:
- Denied party screening with ownership/control logic
- Automated product classification workflows and audit trails
- End-use/end-user risk scoring integrated into order management
- Export license determination embedded into fulfillment
- Forced labor due diligence evidence management
- Customs documentation quality control and broker oversight metrics
Practical Priorities for Trade Compliance Teams in 2026
Organizations preparing for 2026 should prioritize:
- Strengthening screening and escalation processes across jurisdictions
- Improving end-use/end-user diligence for controlled technologies
- Building traceability and evidence libraries for forced labor due diligence
- Tightening customs governance for classification, origin, and valuation
- Operationalizing CBAM readiness through supplier and data workflows
- Investing in scalable technology to create audit-ready compliance execution
Looking Ahead
The developments of 2025 confirmed that trade compliance is becoming more complex, more interconnected, and more enforcement-driven across sanctions, export controls, customs, and supply chain regulation.
Organizations that modernize now by embedding compliance into trade execution, integrating data and technology, and strengthening governance will be best positioned to manage risk and maintain resilience in 2026 and beyond.
How Descartes can Help?
The defining lesson of 2025 is that trade compliance risk no longer lives in isolated rules or one-time decisions, it lives in execution. Regulators are evaluating whether organizations have systems, controls, and data that actively prevent violations across sanctions, export controls, customs, and supply chain regulations.
Descartes helps organizations operationalize modern trade compliance by embedding controls directly into global trade and logistics workflows—where decisions are made, transactions are executed, and audit trails are created.
Turning regulatory complexity into operational control
As enforcement expands across jurisdictions and regimes, compliance teams need more than policy frameworks. They need scalable, technology-enabled execution. Descartes supports this shift by enabling organizations to:
- Identify restricted-party and ownership risk in real time
Advanced denied party screening with ownership and control logic helps organizations address sanctions risk beyond simple name matching, supporting defensible escalation, investigation, and audit readiness.
- Manage export control obligations across volatile regulatory landscapes
Automated product classification, export license determination, and end-use/end-user screening help organizations manage advanced technology controls, re-export risk, and deemed export obligations within day-to-day order fulfillment.
- Operationalize forced labor compliance at the shipment level
Descartes enables organizations to collect, manage, and retrieve supplier documentation and traceability evidence supporting Uyghur Forced Labor Prevention Act (UFLPA)UFLPAreviews, minimizing shipment disruption, and aligning forced labor controls with import execution rather than after-the-fact remediation.
- Strengthen customs governance amid tariff volatility and increased scrutiny
Integrated classification, origin, valuation, and documentation workflows help importers improve entry accuracy, manage landed costs, and maintain broker oversight, especially critical in high-volume and e-commerce channels.
- Prepare for CBAM and ESG-linked trade requirements with audit-quality data
By supporting structured supplier data collection and traceable reporting workflows, Descartes helps organizations align trade compliance, procurement, and sustainability data as CBAM moves into its definitive regime.
Built for auditability, scale, and regulator expectations
A consistent theme across 2025 enforcement actions was auditability: regulators increasingly asked not only what decision was made, but how it was made, based on which data, and with what controls in place.
Descartes solutions are designed to support:
- Embedded compliance checks within operational systems
- Consistent application of controls across regions and business units
- Defensible records of screening, classification, licensing, and due diligence
- Scalability as enforcement scope, data volume, and regulatory overlap increase
Enabling compliance as a business enabler, not a bottleneck
As global trade becomes more complex, organizations that rely on manual processes or disconnected tools face higher disruption risk, slower response times, and greater exposure during audits or investigations.
By integrating compliance into global trade execution, Descartes helps organizations move from reactive compliance to proactive risk management, supporting business growth while meeting rising regulatory expectations in 2026 and beyond.
