New Part 165 to Customs Regulations in September 2016 emphasizes enforcement on evasion. Also ties into political rhetoric on Free Trade Protection. Signifies some effort in this direction political or otherwise. Suggest that you assess countries (rank by activity) and see what dumping exists by the country and do risk assessment. There is no de minimis amount; if you have a commodity that is associated with an action you must deal with it. Our programs (import manual, export manual, itar manual) and support materials equip you to have effective compliance in these activities training and internal audit.