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Customs Audits Detect KRW 2.702 Trillion, and Why Regulatory Violations, Not Tax Evasion, Have Taken Center Stage

The 2025 customs audit results announced by the Korea Customs Service are data that show how the targets and methods of audits are changing.

Regulatory violations account for most of the total amount detected, and the fact that violations of the Foreign Exchange Transactions Act in particular make up a large share confirms that customs audits are no longer confined to the customs clearance stage but are expanding across the entire transaction structure.

CONTENTS
  • 1. Recent Trends in Customs Audits: Changes in the Scale and Structure of Detection
    • - Total Scale and Composition of Detection
    • - The Shift to Audits Centered on Regulatory Violations
  • 2. Analysis of Customs Audit Detection Types: Changes in Audit Direction Confirmed by the Figures
    • - Violation of the Foreign Exchange Transactions Act: The Focus of Audits Shifts to the Flow of Funds
    • - Violation of Import Requirements and Safety Certification: Expansion of the Regulatory Sphere
    • - Violation of Country-of-Origin Labeling: Structural Violations Aimed at Tariff Benefits
  • 3. Direction of Customs Audit Operations for 2026: A Response Centered on Public Welfare, Safety, and Trade Order
    • - Audits Centered on Stabilizing Public Welfare: A Focus on Fields Directly Tied to Prices
    • - Audits Centered on Public Safety: Expansion to Household Goods and Industrial Materials
    • - Blocking Acts That Disrupt the Trade Order: Intensive Response to Dumping and Country-of-Origin Violations
    • - Strengthening the Audit System: Operation of Dedicated Organizations and Special Investigation Teams
    • - Easing the Burden on Businesses: Expansion of the Simplified Audit and Audit Deferral Systems
  • 4. Major Legal Risks Arising from the Expansion of Customs Audits
    • - Risks That May Arise
  • 5. Daeryun Law Firm LLP's Response Strategy
    • - Daeryun's Strategy

1. Recent Trends in Customs Audits: Changes in the Scale and Structure of Detection

The most important point in the 2025 customs audit results is that the structure of detection has completely changed.

Whereas the detection of tax evasion was the focus in the past, regulatory violations now account for most of the audit results, which means that the purpose and methods of customs audits have fundamentally shifted.

Total Scale and Composition of Detection

The total amount detected was recorded at KRW 2.7020 trillion.

Of this, tax evasion accounted for KRW 444.2 billion, a portion of the total, while regulatory violations accounted for KRW 2.2578 trillion, or about 83% of the total.

Although tax evasion increased, its share within the overall structure is low; instead, regulatory violations account for an overwhelming share, which confirms that customs audits have shifted from a focus on collecting back taxes to a focus on cracking down on regulatory violations.

The Shift to Audits Centered on Regulatory Violations

The fact that regulatory violations account for most of the total means that the Korea Customs Service is no longer looking only at amounts that were underpaid in tax but is reviewing the full scope of legal obligations related to imports.

This change leads to an expansion of the audit targets.

The scope of audits has expanded to include verifying whether the transaction in question is a legally permissible structure and whether the relevant regulations are being complied with.

As a result, customs audits are changing in character from tax investigations to a regulatory enforcement function, and this is likely to continue in the direction of future audits.

2. Analysis of Customs Audit Detection Types: Changes in Audit Direction Confirmed by the Figures

〈 Detection Results by Type 〉

(Unit: KRW 100 million)

Category

2022

2023

2024

2025

Tax Evasion

1,418

1,900

2,945

4,442

Regulatory

Violations

Violation of Import Requirements

2,612

581

670

3,643

Violation of Country-of-Origin Labeling

2,205

4,077

1,219

1,805

Violation of the Foreign Exchange Transactions Act

4,063

2,504

1,605

17,130

Subtotal

8,880

7,162

3,494

22,578

Total

10,298

9,062

6,439

27,020

Source - Korea Customs Service

The 2025 customs audit results clearly show, in figures, which types of cases audit resources are being concentrated on.

In particular, even within regulatory violations, detection is concentrated on certain items, and this allows us to see how far customs audits have now expanded.

Violation of the Foreign Exchange Transactions Act: The Focus of Audits Shifts to the Flow of Funds

In 2025, the amount detected for violations of the Foreign Exchange Transactions Act was KRW 1.7130 trillion.

Compared with the previous year's KRW 160.5 billion, this is a level that increased roughly tenfold or more within a short period.

Whereas existing customs audits centered on the accuracy of import prices and declared contents, audits now directly verify even the movement of funds that occurs during the course of a transaction.

This is the part that most clearly shows that customs audits have been reorganized around the entire transaction structure rather than around goods, and within that, around the flow of funds.

Violation of Import Requirements and Safety Certification: Expansion of the Regulatory Sphere

Violations of import requirement audits amounted to KRW 364.3 billion as of 2025.

Compared with the levels of KRW 58.1 billion in 2023 and KRW 67.0 billion in 2024, this is a figure that has again increased significantly.

This item is directly connected to whether the product in question can be distributed within Korea.

A representative example is products that have not obtained safety certification, such as KC certification.

In particular, this audit includes not only products closely tied to daily life, such as electrical appliances, but also industrial products such as construction equipment, which confirms that the scope of regulatory application is expanding.

Violation of Country-of-Origin Labeling: Structural Violations Aimed at Tariff Benefits

The amount detected for violations of country-of-origin labeling was KRW 180.5 billion as of 2025.

Although this is a decrease compared with KRW 407.7 billion in 2023, it remains a major type of violation.

This issue is significant in that it is directly connected to tariff burdens.

For example, a representative method is labeling goods that were actually produced in a particular country as if they were products of a country to which tariff benefits apply.

In practice, methods such as rerouting the import path through a third country or declaring a country of origin different from the country of production are used.

Such methods are often carried out for the purpose of obtaining the lower tariff rates available under free trade agreements, and as a result, they are acts that distort the conditions of competition with companies that bear taxes properly.

For this reason, violations of country-of-origin labeling are recognized as a problem that destabilizes the trade order, and they continue to be a major target of enforcement in customs audits.

3. Direction of Customs Audit Operations for 2026: A Response Centered on Public Welfare, Safety, and Trade Order

If the 2025 customs audit results are data that show the structural change, the direction of customs audit operations for 2026 is a policy standard that shows how this trend will continue.

The Korea Customs Service is giving concrete shape to its audit direction with a focus on stabilizing public welfare and protecting industry.

Audits Centered on Stabilizing Public Welfare: A Focus on Fields Directly Tied to Prices

Amid continuing uncertainty in domestic and external conditions and persistently high prices, the Korea Customs Service has set the stabilization of public welfare as its top priority in order to minimize the burden on the national economy.

Accordingly, while the overall scale of audits is maintained at the level of previous years, a method of selectively concentrating audit resources is being applied.

In particular, among acts of tax evasion carried out on the basis of trade, the structure prioritizes responding to areas that affect prices.

Specifically, centered on the "Korea Customs Service Public Living Prices Special Inspection Team," intensive inspections are conducted of illegal acts such as price manipulation and tax evasion targeting items in the national food supply, such as meat, and imported goods directly connected to the cost of living.

Audits Centered on Public Safety: Expansion to Household Goods and Industrial Materials

The Korea Customs Service plans to further strengthen its inspection of illegal acts that affect the lives and safety of the public.

Last year, through the "Transnational Crime Response Headquarters," it already audited the import and distribution of household goods and industrial products that had not obtained safety certification, detecting violations on the scale of KRW 139.1 billion.

This trend continues this year as well, and the Korea Customs Service plans to continuously inspect acts of importing and distributing, without confirmation of safety, products used directly in the daily lives of the public and in industrial settings, such as household goods and industrial machinery and equipment.

Blocking Acts That Disrupt the Trade Order: Intensive Response to Dumping and Country-of-Origin Violations

The response to unfair acts that abuse trade transactions is also being strengthened.

Beginning in 2026, the Korea Customs Service plans to introduce a "regular dumping review system" and continuously inspect acts by which foreign companies encroach on the domestic market through dumping and circumvention dumping.

In addition, it is focusing on maintaining a fair market order by strengthening monitoring of acts that distort consumer choice, such as false country-of-origin labeling that disguises goods as domestic products and country-of-origin manipulation through circumvention imports.

Strengthening the Audit System: Operation of Dedicated Organizations and Special Investigation Teams

The Korea Customs Service has established dedicated organizations at major main customs offices, including Seoul, Busan, and Incheon, and has completed the assignment of personnel; in particular, to respond to malicious and sophisticated unfair acts, it has additionally established two special investigation teams at the Seoul Main Customs Office.

These special investigation teams handle serious cases exclusively and are structured so that they can immediately shift to compulsory investigation procedures when necessary.

Easing the Burden on Businesses: Expansion of the Simplified Audit and Audit Deferral Systems

Meanwhile, the Korea Customs Service is also pursuing policies to ease the burden on businesses alongside the strengthening of audits.

For compliant businesses, it is promoting the "Simplified Customs Audit System," which shortens the period of on-site visit audits and concludes audits promptly, so that businesses can focus on their management activities.

In addition, for businesses facing difficulties due to recent circumstances such as the situation in the Middle East, it is applying measures to defer customs audits, and it is strengthening procedural transparency by extending the advance notice period for audits from the previous 15 days to 20 days.

4. Major Legal Risks Arising from the Expansion of Customs Audits

Looking at the customs audit trends examined above, violations are occurring simultaneously across various areas, including pricing, country of origin, certification, and foreign exchange.

The major legal risks that may arise for businesses as a result are as follows.

Risks That May Arise

Category

Key Details

Price Manipulation

False declaration of import prices, undervaluation declaration

Country-of-Origin Violation

False country-of-origin labeling, circumvention imports

Certification Violation

Failure to meet safety requirements such as KC certification

Foreign Exchange Violation

Violation of overseas remittance structures, failure to report

A characteristic of customs audits is that these risks appear simultaneously within a single transaction.

For example, the foreign exchange transaction structure may also become problematic in the course of underdeclaring a price, and there are many cases in which a country-of-origin violation is connected to a tariff benefit issue.

As a structure forms in which a single violation spreads simultaneously into tax, criminal, and business risks, the level of risk that businesses must bear is also rising significantly.

Accordingly, current customs audits need to be understood not as a matter of confirming whether a particular violation exists, but as a method of inspecting the entire transaction structure.

5. Daeryun Law Firm LLP's Response Strategy

As customs audits expand to cover transaction structures and the flow of funds, professional responses capable of jointly reviewing complex areas such as customs, taxation, and foreign exchange are becoming crucial.

Daeryun Law Firm LLP provides one-stop legal assistance throughout the entire customs audit process, centered on international trade attorneys, customs specialist advisors holding licensed customs broker qualifications, and tax attorneys.

Daeryun's Strategy

Reviewing the Transaction Structure and Establishing a Response Strategy:We analyze import prices and the transaction structure to diagnose tax evasion risks and establish the direction of the audit response.

Building a Country-of-Origin Verification System and Organizing Supporting Documents: We review country-of-origin determinations and the appropriateness of FTA application, and we systematically organize the relevant supporting documents.

Advance Review of Import Requirement and Certification Risks: We confirm the certification requirements for each product to review in advance the risks that may lead to distribution restrictions and administrative sanctions.

Reviewing the Foreign Exchange Transaction Structure and Establishing Response Logic: We analyze overseas remittance and payment structures to organize the possibility of a violation of the Foreign Exchange Transactions Act and the corresponding response logic.

Integrated Support for Customs Audit Response and Subsequent Procedures: We provide integrated support throughout the entire process, from attendance at the audit to the submission of opinions and the response to dispositions.

If you need assistance with responding to a customs audit or with related legal risks, 🔗Customs Attorney Legal Consultation Booking to confirm a more accurate direction for your response.

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