The Soundtrack of TCSS 2026: We’re All in This Together… Aren’t We?

Reflections and Key Takeaways from the 2026 CBP Trade and Cargo Security Summit

By Jamie Adams

Every conference seems to develop its own theme. Sometimes that theme is deliberate, carefully crafted by the organizers and repeated throughout the event. Other times, it emerges organically as speakers approach different subjects but repeatedly arrive at the same conclusions.

At the 2026 CBP Trade and Cargo Security Summit (TCSS) in Dallas, the message that emerged was unmistakable. Trade compliance is increasingly intertwined with economic security, and economic security is increasingly viewed as national security. The traditional expectation that an importer accurately classify, value, declare the origin of, and pay the appropriate duties on merchandise remains important, but it is no longer sufficient. CBP’s expectations are moving deeper into the supply chain and earlier in the transaction.

Companies are being asked to know substantially more about the businesses with which they transact, the parties behind those businesses, the materials incorporated into their products, the locations where production occurs, and the logistics networks through which merchandise moves. They are also being asked to preserve the evidence supporting those conclusions, identify anomalies before the government does, and demonstrate that reasonable care is an active process rather than a policy sitting on a shelf.

There was also another theme that was difficult to miss. The language of trade enforcement has become considerably more serious. Discussions of partnership and trade facilitation existed alongside discussions of economic warfare, national defense, criminal prosecution, bad actors, bad brokers, whistleblowers, forced labor, illegal transshipment, tariff evasion, and increased enforcement. At several points, the tone sounded less like a traditional customs conference and more like a call to participate in a broader national security mission.

That contrast stayed with me throughout the conference. It was not necessarily a contradiction, because strong enforcement and trade partnership can coexist. Still, the two messages did not always seem completely harmonized.

Perhaps that is why I came home from TCSS with a soundtrack.

A Few of My Favorite Things… Sort Of

If I had to choose a musical introduction to TCSS, “These Are a Few of My Favorite Things” from The Sound of Music would be an appropriate place to begin.

Throughout this article, I use several songs to help frame the major themes and, occasionally, add a little levity to some very serious subject matter. YouTube links to each of the songs referenced in the article are provided together at the end of the document.

To be clear, some of the things discussed in Dallas would not ordinarily make my list of favorite things. Criminal enforcement, forced labor, fraudulent transshipment, bad actors, supply chain vulnerabilities, cybersecurity threats, tariff evasion, and compressed regulatory implementation periods are hardly raindrops on roses and whiskers on kittens.

Nevertheless, several messages from the conference were encouraging and important. CBP clearly recognizes that technology will play an essential role in the future of trade. There was significant discussion of artificial intelligence, data analytics, supply chain mapping, ownership intelligence, and modernization of government systems. There was also an important acknowledgment that AI cannot replace human responsibility. Technology can research, identify, compare, analyze, and recommend, but the ultimate compliance decision remains a human responsibility.

The conference also strongly reinforced the need for proactive compliance. Companies should not wait for a detention, investigation, CF-28, enforcement action, or other government intervention before determining whether they understand their own supply chains. Mapping, due diligence, documentation, and internal validation need to occur before the problem arrives at the border.

Those are concepts I can put on my list of favorite things.

I’m in the Army Now: Economic Security Becomes National Security

One of the more striking aspects of TCSS was the repeated use of national security and military terminology. By the end of the conference, “I’m in the Army Now” by Status Quo began to feel surprisingly appropriate.

The connection between trade and national security is certainly not new. What felt different was the extent to which economic security, customs enforcement, industrial policy, forced labor, critical minerals, export controls, tariffs, cybersecurity, and geopolitical competition were discussed as parts of a common mission.

The opening sessions established this framework early. Modern geopolitical competition does not occur solely through military power. Economic relationships, technology, industrial capacity, critical materials, trade policy, sanctions, tariffs, and supply chain dependencies can all become instruments of national strategy. The United States’ economic relationship with China was an obvious focus because China is not isolated from the global economy. It is deeply integrated into it. That integration creates opportunities for commerce, but it can also create dependencies and vulnerabilities that may not become apparent until a disruption occurs.

COVID provided an obvious example. Companies and governments discovered dependencies on foreign sources for pharmaceuticals, medical supplies, critical materials, and other products only after those dependencies became urgent. The message at TCSS was that neither government nor industry should wait for the next crisis to discover the next vulnerability.

For trade professionals, this expands the meaning of compliance. Classification, valuation, origin, and admissibility remain fundamental, but companies must increasingly consider ownership, sourcing, production, geopolitical exposure, forced labor, sanctions, industrial policy, and supply chain resilience. The compliance department may know where a product is classified, but senior leadership also needs to understand what happens if the source of that product becomes unavailable, prohibited, sanctioned, subject to additional tariffs, or implicated in a forced labor investigation.

Trade compliance is therefore becoming a boardroom issue, not simply a customs issue.

Holding Out for a Hero: Protecting the Homeland

The national security theme became considerably more personal during the DHS luncheon keynote. One of the moments I found most memorable was Secretary Mullin’s discussion of family, service, and protection.

My takeaway from his remarks was not primarily political. It was personal. He spoke about the importance of his family and his instinct to protect the people he cares about. He then connected that instinct with his responsibility at DHS. In his framing, protecting the homeland and supporting the people who work within DHS are expressions of service and commitment to the country.

That sentiment resonated with me. Most of us understand the instinct to protect our families, even when we may disagree about the policies used to accomplish broader political objectives. The Secretary’s message extended that responsibility to those of us working within the trade community. Legitimate trade is not simply something CBP regulates. Trade professionals, importers, brokers, carriers, service providers, and government personnel all participate in protecting the integrity of the system.

Perhaps “Holding Out for a Hero” by Bonnie Tyler is a slightly playful musical interpretation of a very serious message. I certainly did not arrive in Dallas thinking my tariff classifications made me part of the homeland defense infrastructure. By the end of the Summit, however, it was difficult to miss the expectation that trade professionals are being asked to participate in something larger than customs administration.

There is merit to that argument. Companies that intentionally evade duties, use forced labor, disguise origin, manipulate value, or circumvent trade remedies do not merely violate customs rules. Their actions can create unfair competitive advantages over companies investing significant resources in compliance. Effective enforcement can therefore protect legitimate businesses as well as government revenue and broader national interests.

The challenge is ensuring that the call to protect legitimate commerce does not become so dominated by enforcement rhetoric that the partnership message gets lost.

Getting to Know You: Know Your Supply Chain

If one song captures the most important operational message of TCSS, it is “Getting to Know You” from The King and I.

The instruction to “know your supply chain” appeared repeatedly across sessions dealing with forced labor, transshipment, national security, cybersecurity, trade fraud, CTPAT, business partner risk, and artificial intelligence. More importantly, the concept of what it means to “know” the supply chain has expanded.

Knowing a Tier 1 supplier is no longer enough. Importers increasingly need to understand the manufacturer, production facility, source of important materials, beneficial ownership, logistics providers, carriers, warehouses, consolidators, brokers, and other parties participating in the transaction. Depending upon the risk, they may also need to understand the supplier’s supplier and the origin of materials several levels removed from the finished product.

This was particularly apparent in discussions of forced labor and transshipment. A supplier attestation may be useful, but an attestation is not necessarily proof. Companies should be prepared to corroborate representations using government information, commercial databases, ownership information, supplier records, production documentation, bills of material, logistics records, and other available sources.

The same principle applies to country of origin. Goods legitimately move through multiple countries every day, and legitimate substantial transformation occurs every day. The difficulty is distinguishing legitimate production from routing or processing intended primarily to conceal origin or avoid trade remedies. CBP’s message was that importers should understand what actually happened to the merchandise and maintain evidence capable of supporting the resulting origin determination.

This changes the nature of reasonable care. Reasonable care increasingly begins upstream, during supplier selection, onboarding, sourcing, purchasing, and production. Waiting until the broker is preparing the entry is often too late to obtain information that should have been collected months earlier.

It also means that documentation should not exist as a collection of unrelated files. The purchase order, commercial invoice, packing list, bill of lading, bill of material, certificate of origin, production records, supplier documentation, and customs entry should collectively tell a coherent story. When the documents tell different stories, the importer should identify and resolve those differences before CBP does.

Somebody’s Watching Me: Data Changes the Enforcement Environment

The repeated discussion of government analytics made “Somebody’s Watching Me” by Rockwell another natural addition to the TCSS soundtrack.

CBP and its partner agencies are becoming increasingly sophisticated users of data. Government agencies are sharing information, applying analytics, using artificial intelligence, and accessing commercial tools capable of identifying ownership relationships and supply chain connections that would have been extraordinarily difficult to uncover manually only a few years ago.

That creates a fundamental change in compliance risk. Historically, an importer might reasonably assume that obscure relationships several tiers into its supply chain were unlikely to attract government attention. That assumption is becoming increasingly dangerous.

If the government can identify a connection between a supplier, manufacturer, sanctioned party, forced labor entity, or suspicious ownership structure, the importer needs to consider whether its own due diligence program could identify the same relationship. Government access to commercial ownership and supply chain intelligence also creates the very real possibility that CBP may know more about an importer’s supply chain than the importer itself.

TCSS also included repeated references to whistleblowers, competitors, partner agencies, and others identifying suspicious activity. I admit that portions of this discussion occasionally felt like we were being encouraged to keep an unusually close eye on our neighbors. My inner school child heard a faint echo of, “Teacher, I think somebody is cheating.”

There is, however, a legitimate compliance principle beneath the humor. Deliberate fraud damages legitimate trade, and employees need safe mechanisms for reporting misconduct internally. Competitors and other parties may also possess information that government agencies would never otherwise receive. The practical lesson is not that every trade professional should become a professional tattletale. It is that companies should assume anomalies can and will be discovered.

The best defense is to identify them internally first.

Under Pressure: More Expectations and Less Time

Perhaps my greatest concern coming out of TCSS was the growing mismatch between the sophistication government expects from industry and the amount of time industry is sometimes given to implement significant changes. “Under Pressure” by Queen and David Bowie captures this issue nicely.

CBP wants more data, deeper due diligence, stronger documentation, better supply chain visibility, improved cybersecurity, faster remediation, and more sophisticated use of technology. I agree with much of that direction. Better information can produce better compliance.

The difficulty is that regulatory implementation occurs in the real world. New requirements may require software development, ERP changes, broker programming, supplier education, new data fields, API modifications, revised operating procedures, employee training, customer communication, testing, and validation. Foreign suppliers may need to provide information they have never previously collected for a U.S. customer.

Those changes cannot always be implemented responsibly overnight.

The Summit acknowledged the difficulty created when information cannot be released until a particular legal or policy action becomes public and the effective date follows almost immediately. This has become particularly challenging during a period of extraordinarily active tariff and trade policy changes.

There is an important partnership issue here. If government expects companies to build sophisticated controls capable of supporting national economic security, companies need sufficiently clear rules and reasonable implementation opportunities whenever possible. Industry should be expected to invest in compliance, but government should recognize that technology, processes, and global supply chains require time to change.

True partnership should include accountability on both sides. Industry must build better systems and respond more quickly. Government should provide clear definitions, useful technical guidance, consolidated communications, meaningful feedback, and workable implementation periods whenever circumstances allow.

We’re All in This Together: The Growing Importance of CTPAT

The partnership theme naturally brings us to “We’re All in This Together” from High School Musical.

CTPAT was one of the more important directional signals from TCSS. It is essential to state the current position accurately: CTPAT remains a voluntary program. The Summit did not announce that CTPAT has become universally mandatory.

What I heard instead was more subtle and potentially more consequential over time. Trusted trader concepts increasingly appear to be woven into discussions of importer credibility, security, business partner validation, facilitation, risk assessment, and eligibility for particular benefits or programs.

The potential development is not necessarily a future regulation simply declaring CTPAT mandatory. Participation could instead become increasingly important one program or benefit at a time. A company might retain the legal ability not to participate while discovering that certain opportunities, facilitation benefits, validations, or preferred treatment increasingly depend upon CTPAT status or equivalent trusted trader credentials.

In other words, CTPAT could remain voluntary in law while becoming increasingly important operationally.

Companies should therefore monitor more than the legal status of CTPAT. They should watch how CBP uses CTPAT status, validation dates, foreign AEO equivalencies, minimum security criteria, and evidence of implementation within other programs and risk models.

The larger significance is the continuing convergence of customs compliance and security. Importer identity, cybersecurity, physical security, ownership, supplier validation, carrier controls, trade data, and traditional customs compliance are becoming parts of the same risk management framework.

Let’s Get Together: Partnership in a Global Supply Chain

The repeated emphasis on partnership also makes “Let’s Get Together” from The Parent Trap particularly appropriate.

The fundamental concept is difficult to dispute. Government cannot secure global commerce by itself. Importers cannot comply by themselves. Brokers, carriers, technology providers, manufacturers, suppliers, attorneys, consultants, and government agencies all possess different pieces of the information necessary to understand a global transaction.

International cooperation is equally unavoidable. An American importer attempting to map its supply chain must obtain information from foreign manufacturers and suppliers. Origin analysis may require detailed information about production occurring outside the United States. Forced labor analysis may require information several tiers removed from the importer. Cybersecurity and cargo security may involve foreign carriers, facilities, and logistics providers.

This is where I found some of the broader political rhetoric somewhat difficult to reconcile with the operational message being delivered to trade. We were being encouraged to deepen relationships with foreign business partners at the same time that political discussions can characterize important trading partners in increasingly adversarial terms. Canada was one example that particularly stood out to me given the extraordinary integration of the North American economy.

This observation is not intended as a partisan argument. Administrations change, trade disputes occur, tariffs change, and even close allies disagree. The operational reality, however, is that global supply chains do not reorganize themselves every time the political vocabulary changes.

Companies still need their suppliers tomorrow morning.

If the United States wants deeper supply chain transparency, cooperation with foreign business partners becomes more important, not less. The government and trade community therefore share an interest in maintaining channels through which legitimate international partners can provide reliable information and participate in secure commerce.

Should I Stay or Should I Go? The Dissonance Between Partnership and Enforcement

This brings me to the part of TCSS that I found most difficult to reconcile. “Should I Stay or Should I Go?” by The Clash provides the musical accompaniment.

Throughout the conference, legitimate trade was described as a partner. Brokers were described as partners. CTPAT emphasized trusted relationships. Industry was asked to participate in the national economic security mission. Government and industry were encouraged to collaborate on technology and artificial intelligence.

At the same time, the vocabulary frequently returned to bad actors, bad brokers, criminal enforcement, DOJ involvement, penalties, conspiracies, whistleblowers, fraudulent importers, and the need to report suspicious conduct.

Both messages can be true. There are unquestionably importers and other parties deliberately committing fraud. There are illegal transshipment schemes, false origin claims, undervaluation schemes, shell companies, forced labor concerns, and intentional attempts to evade antidumping and countervailing duties or other trade remedies. Those activities deserve enforcement, and legitimate companies have a commercial interest in seeing intentional fraud addressed.

My concern is more nuanced. The trade professionals attending TCSS are disproportionately the people who have chosen to engage with CBP, educate themselves, invest in compliance, and improve their programs. A heavily enforcement-oriented message delivered to that audience can therefore create an unusual dynamic. The people most willing to listen may not be the people who most need the warning.

More importantly, the frequent use of the term “bad actor” risks obscuring an important compliance continuum. An administrative mistake is not equivalent to gross negligence. Gross negligence is not equivalent to deliberate evasion. A broker making an isolated error is not equivalent to a broker knowingly facilitating fraud. A company with an immature compliance program is not necessarily engaged in a criminal conspiracy.

Where the government has a legitimate concern is when companies identify problems and fail to correct them. Repeated errors, inadequate investment, poor follow-up, weak vendor oversight, missing evidence, or continued reliance on a known defective process can progressively change the government’s assessment of a company’s conduct.

The appropriate response for legitimate trade is therefore not fear. It is demonstrable corrective action. When a problem occurs, investigate it, determine the root cause, identify affected transactions, correct the process, document the remediation, test the solution, escalate appropriately, and consider disclosure when circumstances require it.

That is what separates a functioning reasonable care program from the impossible expectation of perfection.

Human in the Lead: AI and the Future of Trade Compliance

One of my genuine favorite things from TCSS was the discussion of human responsibility in an increasingly AI-enabled environment.

CBP has used predictive analytics for years and is now exploring increasingly sophisticated generative and agentic AI applications. Industry is following the same path. Artificial intelligence can potentially research entities, analyze documents, compare data, identify anomalies, retrieve regulatory guidance, map ownership relationships, flag risks, and propose conclusions at a scale that would be impossible for most human compliance teams.

The most important message, however, was that AI does not assume legal responsibility for the decision.

Humans do.

I particularly appreciated the concept of “human in the lead.” It is stronger than the increasingly familiar phrase “human in the loop.” A human in the loop can become little more than someone clicking an approval button at the end of an automated process. A human in the lead remains responsible for understanding the issue, evaluating the evidence, challenging the technology when necessary, making the decision, and documenting the rationale.

That distinction will become increasingly important as both government and industry automate more compliance activity.

Companies cannot realistically respond to government AI and sophisticated data analytics by continuing to manage complex compliance programs exclusively through spreadsheets, email chains, disconnected documents, and institutional memory. Technology will become essential. The objective should not be to remove the trade professional from the process, but to allow technology to perform more of the research, retrieval, comparison, monitoring, and repetitive analysis so that human expertise can concentrate on judgment, exceptions, escalation, and accountability.

What TCSS Means for Trade in the Coming Year

When the musical references are removed, the practical direction from TCSS is remarkably consistent. Companies should begin by mapping their supply chains more deeply and doing so before a government inquiry forces the issue. Supplier, facility, ownership, material, production, transportation, and business partner information should increasingly be viewed as part of the compliance record.

Reasonable care should also move upstream. Supplier onboarding, sourcing, purchasing, product setup, origin analysis, and documentation collection provide opportunities to prevent problems that cannot easily be solved when an entry is ready to transmit. The further upstream a company can validate its data, the more likely it is to identify inconsistencies before they become customs violations.

Companies should also examine whether their documentation tells a coherent story. Purchase orders, commercial invoices, packing lists, bills of lading, bills of material, certificates of origin, supplier records, and customs filings should not exist in isolation. Modern compliance programs need the ability to connect those records and identify inconsistencies across them.

Data analysis will also become increasingly important. Companies should look for repeat errors across classifications, countries of origin, values, Chapter 99 reporting, brokers, vendors, and transactions. A single error may be understandable. A pattern of errors that the company could have identified and corrected presents a different risk.

CTPAT and other trusted trader concepts should be monitored carefully, not simply for changes in their formal legal status but for the extent to which they become prerequisites for particular benefits, programs, validations, or facilitated treatment.

Finally, trade compliance needs greater executive visibility. Supply chain risk now touches sourcing, finance, availability, cybersecurity, ESG, national security, reputation, legal exposure, and corporate strategy. Compliance professionals need to translate those risks into language that executives and boards understand.

Bringing the Soundtrack Home

When I look back at TCSS 2026, I do not believe the conference fundamentally changed the direction of trade compliance. It accelerated trends that have been developing for some time and made the government’s expectations considerably clearer.

The United States is moving toward a trade environment in which economic security, national security, customs enforcement, supply chain visibility, and technology are increasingly interconnected. CBP expects importers to know more, document more, validate more, and respond more quickly. Government agencies will increasingly use data and artificial intelligence to identify risk, and companies will need comparable capabilities to understand their own transactions.

There were parts of that message I strongly support. I believe deeply in upstream compliance. I believe companies should know their supply chains and business partners. I believe technology can dramatically improve compliance when it is paired with qualified human oversight. I believe companies intentionally cheating the system harm the businesses that invest in doing things correctly. I also believe partnership between government and legitimate trade is essential.

Where I remain less comfortable is with the tone that occasionally surrounded those messages. Partnership works best when legitimate trade understands that government distinguishes between an honest error, an inadequate process, negligent conduct, and intentional fraud. It also works best when government recognizes that sophisticated compliance systems require clear guidance and sufficient implementation time.

Perhaps that is the real lesson hidden inside my TCSS soundtrack.

We may be “In the Army Now” because economic security has become national security. We certainly need to spend more time “Getting to Know You” when it comes to our suppliers and business partners. We should assume “Somebody’s Watching Me” because government analytics and enforcement capabilities are improving rapidly. Trade is unquestionably “Under Pressure” as regulatory change accelerates. CBP tells us “We’re All in This Together,” and the global nature of commerce means we really do need to “Get Together.” Occasionally, the combination of partnership and enforcement may leave legitimate trade wondering “Should I Stay or Should I Go?”

And perhaps there really is a little “Holding Out for a Hero” in all of this. Not because trade compliance professionals need capes, although I am not completely opposed to the idea, but because the government is clearly asking legitimate trade to take a more active role in protecting the integrity of the U.S. economy and supply chain.

That is a serious responsibility.

It deserves serious investment, serious technology, serious human oversight, and serious cooperation between government and industry.

Those may not all be a few of my favorite things.

But after TCSS 2026, they are certainly things we cannot afford to ignore.

The TCSS 2026 Soundtrack

“These Are a Few of My Favorite Things” from The Sound of Music
YouTube: https://youtu.be/0IagRZBvLtw?si=HeV3vLPjATHyPoWd

“I’m in the Army Now” by Status Quo
YouTube: https://youtu.be/why7UbwsisY?si=XMMm2U8b_xV_mNqu

“Getting to Know You” from The King and I
YouTube: https://youtu.be/Vlx6gQWfjp0?si=ar1xHeGns4CKebNh

“Somebody’s Watching Me” by Rockwell
YouTube: https://youtu.be/7YvAYIJSSZY?si=48NFkZjaWzO2egKA

“Under Pressure” by Queen and David Bowie
YouTube: https://youtu.be/a01QQZyl-_I?si=pMzxOvIs3Gb8bFBi

“We’re All in This Together” from High School Musical
YouTube: https://youtu.be/DykVJl6wr_4?si=fEkpmZCVxhFsF3yq

“Let’s Get Together” from The Parent Trap
YouTube: https://youtu.be/graoQ7e0DoY?si=F-kHDFw13zUZHBA9

“Should I Stay or Should I Go?” by The Clash
YouTube: https://youtu.be/xMaE6toi4mk?si=70XKLsKGP6zavv2_

“Holding Out for a Hero” by Bonnie Tyler
YouTube: https://youtu.be/bWcASV2sey0?si=Jwi0vJHpoyEKPVWt