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To:Brew Readers
CFO Brew // Morning Brew // Update
Tariff enforcement is about to get real.

Hellooooo, Friday. MacKenzie Scott, formerly Bezos, has donated $7.1 billion to nonprofits this year. BRB, checking our Giving Tuesday totals.

In this issue:

Just ’riffing

What’s the scenario?

Jesse Klein

COMPLIANCE

Cargo ships with tariff percentages indicated on shipping lanes

Serg Myshkovsky/Getty Images

CFOs have spent almost a year thinking about tariffs. And as many are preparing for tariffs to be around for the long haul, they also need to be aware of increased enforcement of tariff compliance, which the Trump administration has made a priority.

The enforcement ramp-up. In a memo released in May 2025, the Department of Justice put “trade and customs fraud, including tariff evasion” second on the list of priorities for white collar crime enforcement. The memo said “prosecuting such frauds will ensure that American businesses are competing on a level playing field in global trade and commerce.”

Lenny Feldman, a tariff lawyer and managing partner at Sandler, Travis & Rosenberg, said he expects tariff enforcement to increase in 2026. “The Administration rolled out a very complex and comprehensive tariff overhaul in an extremely short period of time,” Feldman said in an email. “This had led to numerous errors—most unintentional, but some intentional. As the stakes have never been higher, I would expect more CBP enforcement to ‘clean up’ these errors.”

A smattering of the confusing events in the tariff rollout this year include flipflopping on applying tariffs on certain goods, levying tariffs followed almost immediately by pausing them, and imposing tariffs on uninhabited Antarctic islands.

“There’s going to be increased scrutiny on every single import,” Christopher Desmond, the principal in the customs and international trade group at PwC, told CFO Brew, agreeing with Feldman. And it’s worth noting that Republicans’ “One Big Beautiful Bill” gave Customs and Border Protection $4 billion to hire 8,500 employees.

Keep reading.JK

Presented By CIBC

RISK MANAGEMENT

A portrait of Adam Rymer, vice president of finance at Chipotle

Adam Rymer

Uncertainty has been a major theme for CFOs in 2025. Are we in a recession or not? Will AI rewrite (or erase) vast swaths of the workforce, or become an essential tool to be integrated into workflows? How do you plan for federal policy when it can swing with the president’s pen or get backtracked by the Supreme Court? CFOs are running a lot of scenario models these days. But this isn’t the first time uncertainty has gripped the CFO desk.

So how’s a CFO to manage in an era of heightened uncertainty? To learn a thing or two, we interviewed a wide range of finance executives about another recent extreme spike in uncertainty: the Covid-19 pandemic, when CFOs also went into scenario planning overdrive. They had to make plans for if their sales went to zero, if suppliers couldn’t fulfill invoices, how much money they needed to survive, and thousands of other questions. Many CFOs were doing daily scenario planning sessions.

A silver lining of all that turbulence is that it might have laid the groundwork for more robust financial planning in the years since. Read on to find out.

Interviews have been edited and condensed for length and clarity.

Adam Rymer, vice president of finance at Chipotle in 2020: We have a very conservative balance sheet. We have no debt. We have what we believe to be ample cash on hand at the time. It’s probably just over a billion dollars. But what was amazing, when you look at these different scenarios, either a significant revenue impact or no revenue for a period of time, it’s amazing how quickly you can burn through money in that scenario…And so it was intense. You realize, as conservative as you are, nobody is prepared for a situation where you can have weeks and weeks and weeks of zero revenue.

We definitely started to run different scenarios for how much cash we had on hand and how much we would burn through. And the most dire scenario would be, we cannot operate our restaurants. Basically, our sales would go to zero. How do we retain our people? How do we continue to pay our people, knowing that we weren’t sure if this is going to last a week, two weeks, a month, but we want to do what’s right by our employees, and continue to pay them. But also have them readily available when we are able to open that we can open quickly, because in order to be really successful at Chipotle requires quite a bit of training.

Keep reading.JK

Together With Treasury.org

MARKET FORCES

market forces chart

Francis Scialabba

Today’s top finance reads.

Stat: 4,400%. That’s how much the price of rare earth element yttrium (no, that’s not a typo) has risen outside China between January and November of this year. 🪨(Reuters)

Quote: “Rather than just being silent on crypto, this bill strips the few safeguards that exist for crypto and erodes many protections for traditional securities. If passed, it will undercut the safety of many assets and cause problems across retirement investments.”—Randi Weingarten, president of the American Federation of Teachers, in a letter to the Senate Banking Committee regarding the crypto market bill (CNBC)

Read: SEC Chief Accountant Kurt Hohl discussed auditor independence rules, the PCAOB’s future, and more. (Wall Street Journal)

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