Strategy & Horizon Scannning

Christopher Salmon

Chief Executive

TLDR

The Senior Accounting Officer function puts personal responsibility for tax and customs oversight squarely at board level. With HMRC demanding clear evidence of adequate controls, customs is no longer a hidden line item but a governance test of accountability, data quality, and risk management. Leaders who treat SAO compliance as continuous assurance – not just an annual certificate – will build stronger, more robust organisations.

 

When HMRC introduced the Senior Accounting Officer (SAO) regime under Schedule 46 of the Finance Act 2009, its goal was clear: to sharpen accountability at the top of large organisations. 

For qualifying UK companies, the SAO requirement places a named individual (often the CFO or finance director) personally responsible for the adequacy of their company’s tax accounting arrangements.

While the regime was originally designed with corporation tax and VAT in mind, its scope also extends to customs duty. And in today’s post-Brexit trading landscape – where errors in classification, valuation, or origin can quickly spiral into costly disputes – overlooking customs within the SAO framework is a dangerous blind spot.

For senior leaders, this is not just a compliance formality. It’s a test of governance, operational robustness, and risk maturity.

→ ClearBorder helps leadership teams integrate customs into SAO frameworks: minimising risk while strengthening strategic control. Talk to us today.

The Senior Accounting Officer: a quick primer

Not every company falls under the SAO regime. To qualify, a business must be:

  • Incorporated in the UK; and
  • Either exceed £200 million in turnover or hold £2 billion+ in balance sheet assets, whether individually or when aggregated with other UK group companies.

A qualifying company must appoint an SAO, who is typically the CFO, finance director, or head of tax. This individual must provide an annual certificate to HMRC confirming whether the company maintained “appropriate tax accounting arrangements” during the financial year.

Failure to comply can result in:

  • £5,000 personal fines per year of failure (applied to the SAO personally).
  • Potential corporate penalties, reputational harm, and increased HMRC scrutiny.

What an SAO must certify

Each year, the SAO must sign off one of two statements to HMRC:

  1. That the company’s tax accounting arrangements were appropriate and adequate throughout the year; or
  2. That they were not adequate, with details of the gaps or failures.

This certification must cover all relevant taxes, including VAT, corporation tax, PAYE, and crucially, customs duty. To demonstrate adequacy, businesses need evidence of:

  • Clear policies and documented procedures
  • Defined roles and responsibilities across finance, tax, and compliance
  • Internal controls and monitoring systems to prevent and detect errors
  • A complete audit trail of decisions, records, and data

Customs duty in the SAO framework

Typically, customs duty represents a smaller proportion of overall tax liability compared to VAT or corporation tax. This sometimes leads boardroom stakeholders to underestimate its importance when preparing the SAO certificate. This is an oversight that carries material risks.

First, the volume and frequency of customs transactions are far higher than for other taxes. Each import or export declaration presents opportunities for error: in tariff classification, customs valuation, or rules of origin. Even minor missteps, multiplied across thousands of consignments, can add up to significant underpayments or overpayments.

Second, HMRC scrutiny of customs duty has intensified since Brexit. Though the exact figure is not disclosed, in 2024, HMRC reported that post-clearance audits and interventions recovered a significant amount in underpaid customs duties. 

An SAO who overlooks customs is, effectively, signing off blind on a high-risk area.

Third, customs duty compliance is no longer just about cost. Errors can result in:

  • Delayed shipments, disrupting supply chains
  • Retroactive duty bills, damaging financial predictability
  • Loss of preferential tariff treatment under trade agreements
  • Reputational harm, especially if investors or customers see governance failures

For example: imagine a multinational retailer importing consumer electronics. If it relies solely on suppliers’ declarations without robust verification, it risks misclassification under the UK Global Tariff. A subsequent HMRC audit could impose backdated duties and also question the adequacy of the SAO’s certification – triggering both corporate and personal liability.

The key takeaway, then, is that treating customs as immaterial within the SAO regime is a strategic miscalculation. A genuinely “adequate” tax framework must integrate end-to-end customs processes (from broker oversight to data validation) into its governance structures.

The Senior Accounting Officer and the boardroom: a governance lens

The Senior Accounting Officer represents an expectation of personal accountability at boardroom level, with implications that cut across governance, risk management, and corporate culture.

For the board, the SAO framework should be seen as:

  • A governance test: does the organisation have effective controls in place, not just for headline taxes but for complex, high-volume areas like customs?
  • A risk barometer: weaknesses flagged by the SAO can highlight broader operational fragilities, from supply chain management to data quality.
  • A trust signal: regulators, investors, and stakeholders view a clean SAO certification as evidence of robust internal oversight.

In this sense, the SAO role exists to embed a culture where tax and trade risks are managed with the same seriousness as financial reporting or cybersecurity.

Common weaknesses in SAO compliance for customs
In practice, HMRC has noted recurring gaps in SAO compliance where customs is concerned. The most typical issues include:

  1. Over-reliance on customs brokers without adequate oversight
  2. Fragmented data across ERP, logistics, and finance systems
  3. Lack of clear ownership of customs processes within the business
  4. Insufficient audit trails, making it difficult to evidence adequacy

Even sophisticated organisations can stumble on these points, potentially leaving the SAO exposed.

Building robust customs controls under the SAO regime

To meet the SAO standard mandated by HMRC, customs responsibilities need to be integrated into the company’s wider tax governance architecture. Strong, high-performing frameworks generally include:

  • End-to-end process mapping

Documenting how customs data flows from purchase order to declaration to accounting entry.

  • Defined accountability structures

Assigning responsibility between finance, supply chain, and compliance teams.

  • Broker management protocols

Ensuring contracts, SLAs, and audit rights allow effective oversight of third-party declarations.

  • System integration and data validation

Reconciling customs entries with ERP and finance systems to catch anomalies early.

  • Regular internal reviews and testing

Conducting mock audits, classification reviews, and risk assessments before HMRC does.

  • Board-level reporting

Elevating customs metrics (e.g. duty exposure, compliance error rates, preferential origin utilisation) into management dashboards.

Making customs a part of wider risk and control frameworks has a double-edged benefit. It means companies not only protect their SAO, but also improve supply-chain predictability, financial accuracy, and resilience in the face of regulatory scrutiny.

Last word: the Future of the SAO, and what leaders should do now

The SAO regime is now over a decade old, but its significance has only grown in today’s environment of heightened regulatory attention and supply chain complexity. 

Several dynamics point to an evolving role for the SAO:

  • Customs risk is more visible than ever. 

Since Brexit, duty exposures have grown, and HMRC has signalled a sharper focus on post-clearance audits.

  • Personal accountability is a governance trend. 

Just as directors are held individually responsible in areas like data protection and financial reporting, tax accountability is moving the same way.

  • Technology contains both power and risk potential. 

Automation can reduce manual error, but it also concentrates risk if systems or data mapping are flawed.

In the boardroom, the central question is how to embed the role of the Senior Accounting Officer into broader governance and resilience strategies.

Leaders should look to:

  1. Treat SAO compliance as a board-level agenda item, not a finance-side technicality.
  2. Recognise customs as a material area of exposure, despite its comparatively modest headline value.
  3. Invest in systems, training, and oversight that provide defensible evidence of adequacy.
  4. View the SAO certificate not as an annual hurdle, but as a continuous assurance process that strengthens trust with regulators and stakeholders.

All signs indicate that the future of the SAO role lies in strategic accountability. 

By integrating customs into the heart of governance, organisations protect themselves from penalties, and – perhaps more pertinently, as the sands of global trade continue to shift – they also demonstrate maturity in managing complex international risks.

Ready to strengthen your compliance and reduce customs risk? 

We help boardrooms build controls that stand up to HMRC scrutiny.

Contct our team today →

What is a Senior Accounting Officer? | FAQs

What is a Senior Accounting Officer (SAO) and who needs one?

A Senior Accounting Officer is a board-level executive responsible for signing off that a UK company has appropriate tax accounting arrangements, including customs duty. 

HMRC requires an SAO if a company is UK-incorporated, has a turnover above £200 million, or a balance sheet total exceeding £2 billion.

What must a Senior Accounting Officer certify?

An SAO must provide an annual certificate to HMRC confirming whether the company’s tax accounting arrangements – covering VAT, corporation tax, PAYE, and customs duty – were appropriate throughout the year. If not, the SAO must identify specific weaknesses.

Why is customs duty often overlooked in SAO compliance?

Compared to corporation tax or VAT, customs duty can appear immaterial. 

But HMRC includes it under SAO obligations, and failures in customs controls (from incorrect tariff classifications to poor data retention) can expose companies to penalties, reputational damage, and financial risk.

What are the penalties for SAO non-compliance?

If an SAO fails to comply with their responsibilities, HMRC can impose personal fines of £5,000 per financial year. 

Repeated failings may also trigger wider compliance investigations across the business.

How can businesses strengthen customs oversight under the SAO regime?

Companies should move beyond spreadsheets to automated customs data management, implement clear policies for record-keeping and risk assessment, and integrate customs duty into board-level compliance reporting. Partnering with independent experts helps ensure SAO certification is not just a tick-box exercise but a strategic advantage.

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Strategy & Horizon Scannning

Steel and Aluminium at a Crossroads: Supply Chains, Tariff Wars, Business Impacts

  TLDR 2025 reshaped steel and aluminium supply chains. U.S. tariffs, EU uncertainty, and Chinese overcapacity have all driven structural rerouting, pricing instability, and compliance pressure. Businesses elevating metals sourcing to a strategic capability – with stronger origin assurance, supplier governance, and scenario planning – typically outperform competitors in terms of resilience, cost control, and market access. Firms will need to adapt to preserve their position and competitiveness. 2025 saw the sharpest escalation in metals-trade interventions since the original, President Trump-era Section 232 measures, in 2018. What began as a series of “targeted” moves early in 2025 has evolved into a multi-jurisdictional reset, touching tariffs, origin rules, industrial policy, and supply chain governance. For global businesses reliant on steel and aluminium, this will represent a fundamental shift in operations and market position. Steel and aluminium are systemic commodities. They underpin every major industrial value chain: automotive, aerospace, defence, energy infrastructure, construction, household appliances, and large consumer goods. When trade conditions tighten around these materials, the shockwaves propagate quickly: rising input costs, margin compression, delayed production cycles, and forced redesign of sourcing strategies. Several trigger events collided in 2025: In May 2025, the U.S. raised tariffs to 50% on a wide range of steel and aluminium categories, materially altering the economics of imports. By Q4, Washington introduced tightened melt-and-pour origin rules, significantly raising the bar for compliance and due diligence. Meanwhile, the EU remained locked in slow-moving negotiations with the U.S. on tariff-rate quotas, while simultaneously confronting the long-running challenge of Chinese overcapacity depressing European prices. China’s own pricing volatility (driven by subsidised overproduction and domestic demand swings) continue to distort global markets. Taken together, developments like these show that steel and aluminium supply chains are not experiencing a temporary disruption – they are undergoing a deeper, structural reorganisation. Businesses will need to adapt to preserve their position and competitiveness. Why this matters Global metals policy is moving faster than most supply chains can adjust. The 50% U.S. tariffs, melt-and-pour rules, EU safeguard activity, and China’s continued overproduction are reshaping sourcing and pricing across entire industries. For manufacturers and importers, this is not just a cost issue; it’s a governance, compliance, and competitiveness issue. How firms respond will determine whether they stay ahead of regulatory pressure, or become ensnared in a rapidly tightening enforcement environment. Expert guidance on international trade Contact clearBorder today →  How tariffs reshape global flows The 50% U.S. tariffs  Under the administration of President Trump, the U.S.’s move to increase tariffs to 50% on a wide range of steel and aluminium products marked a pivot in metals trade. The measures affect core inputs such as semi-finished steel, rolled products, extrusions, and several aluminium categories. Downstream products such as cars, domestic appliances, and industrial machinery are increasingly examined for the embedded origin of their metal content. The tariff shock has created three immediate consequences: Domestic inflation in U.S. metals markets. Manufacturers face significantly higher input costs, prompting either price rises or margin erosion. Redirected flows from Asia to Europe. Exporters seeking to avoid U.S. duties have diverted excess supply toward the EU, exacerbating oversupply conditions and placing further pressure on European producers. A new compliance burden for global exporters. The tightened melt-and-pour rules raise the risk of inadvertent non-compliance. Trans-shipment scrutiny has increased; origin validation is now a core operational requirement. EU’s dilemma The EU finds itself between a rock and a hard place. On one side are slow, uncertain EU–U.S. negotiations on tariff-rate quotas and metals cooperation frameworks; on the other is intensifying pressure from the steel lobby to protect European producers from diverted Asian supply after the U.S. tariff shock. European manufacturers face irregular and unpredictable input costs, complicating price setting, inventory planning, and long-term contracting. The EU’s Green Deal Industrial Plan adds further complexity, as imported metals are essential for its energy-transition ambitions, yet those same imports now threaten domestic competitiveness. The overcapacity question China’s long-standing overcapacity issue remains the gravitational centre of global metals instability. Production levels continue to exceed domestic demand, pushing subsidised excess onto global markets and driving renewed price volatility. This places other jurisdictions in a defensive posture. European and U.S. producers have reported intensified undercutting; Asian and Latin American manufacturers face narrowing margins; and developing economies risk deeper dependence on low-cost Chinese supply. Beijing may consider retaliatory measures, or deepen its alignment with Global South partners (such as Malaysia, Indonesia, Vietnam, and Thailand in Southeast Asia, or members of the Community of Latin American and Caribbean States) to mitigate against Western trade interventions. Either path would add new layers of complexity to an already fragmented global steel and aluminium market. Re-routing, re-pricing, re-risking How supply chains are responding The reshaping of steel and aluminium trade is visible in operational patterns, with supply chains reorganising at pace. Businesses are re-routing in order to defend margin and meet compliance thresholds. According to emerging reports, Asian-origin metals that previously flowed into the U.S. are being diverted toward Europe, Turkey, and the Middle East. European manufacturers, in turn, are exploring alternative inputs from India, Brazil, and the Gulf to avoid the tariff spillover effects. This repositioning may also trigger changes in logistics: greater use of east-west routes into the EU, potentially more inventory buffering, and in some sectors (such as automotive and machinery) a shift toward nearshoring for critical components. Cost structures are being re-priced globally. The U.S. tariff shock has lifted domestic prices sharply, while excess supply has depressed segments of the European market. Producers in China and Southeast Asia have adjusted export strategies in real time, offering deeper discounts to maintain throughput. For buyers, this creates a two-speed market: inflationary in the U.S., deflationary or erratic elsewhere. Long-term contracts are harder to negotiate, and index-linked pricing is seeing a resurgence. Perhaps most importantly, supply chains are being re-risked. Compliance is now inseparable from commercial decision-making – a cheap tonne of steel that ultimately fails melt-and-pour verification is a liability, not a saving. Manufacturers are mapping exposure at a deeper level than before, tracing inputs back to smelters (not mills), and stress-testing for tariff escalation or port inspections. Insurance markets are responding too, with new language around origin risk and misdeclaration liability appearing in trade credit and marine cargo policies. Rising compliance complexity The enforcement of the U.S. melt-and-pour rule is proving to be one of the most consequential compliance developments. By requiring origin to be established at the smelting stage – not the final manufacturing stage – regulators have effectively redrawn the documentation burden for the entire value chain. Finished goods manufacturers, especially in automotive, appliances, construction products, and machinery, must now evidence multi-layered provenance to avoid penalties or shipment holds. This comes alongside broader tightening: The EU is advancing anti-circumvention probes and designing new safeguard mechanisms around diverted Asian supply Tariff-rate quota negotiations with the U.S. remain uncertain, complicating long-term planning The UK faces a hybrid challenge: exporters into the U.S. or EU must meet foreign origin standards and navigate domestic decarbonisation requirements shaping the future of UK steelmaking For business boardrooms, this translates into elevated expectations around: Proving origin at smelter level Supplier vetting across multiple jurisdictions End-to-end documentation capable of withstanding audits Horizon scanning for tariff escalation and market fragmentation Avoiding unintentional trans-shipment exposure, especially in multi-country routing models Implications for business Cost structures will remain unstable for the near term. U.S. tariffs have created inflationary pressure domestically; Europe is facing oversupply; and Chinese volatility continues to inject uncertainty into global reference prices. Businesses should anticipate continued dual-market dynamics throughout 2026. Compliance risk has moved from operational to existential. The melt-and-pour rule, EU safeguard mechanisms, and intensified anti-circumvention enforcement mean that the regulatory exposure of a single misclassified input far exceeds the cost of the input itself. Boardrooms increasingly view origin assurance as part of corporate governance, not logistics. Supply chain strategy is entering a redesign phase. Nearshoring and multi-regional sourcing are gaining momentum Dual or triple sourcing for steel and aluminium is becoming standard in automotive, engineering, and construction Inventory models are shifting from just-in-time to strategic buffering Quality and compliance maturity are becoming as important as price when selecting a supplier Commercial positioning is changing, too. Companies that can evidence clean origin, stable sourcing, and strong governance are positioned to outperform competitors in tenders – particularly with OEMs (original equipment manufacturers) facing strict regulatory exposure of their own. For some sectors, metals compliance is now a competitive differentiator. The last word Steel and aluminium have always been essential industrial inputs, but in the current climate, they’ve become a barometer of global economic and geopolitical tension. Tariffs, origin rules, and enforcement actions are all actively reshaping supply chains, capital allocation, and competitiveness. The businesses equipped to succeed in this environment treat metals not simply as commodities to be purchased, but as strategic exposures to be governed. This means that decision-makers have visibility deeper than tier-one suppliers; they can evidence origin at smelt stage. They plan for tariff escalation; not react to it. And they embed compliance into commercial decision-making. Early, proactive movement will help protect against price shocks, audit interventions, and market-access constraints, as the next phase of trade policy unfolds. For manufacturers, importers, and exporters, the question is not whether to adapt, but how quickly. The former era of (relatively) stable and predictable metals flows is over – strategic readiness is now the defining commercial advantage. For trade advisory tailored to your business and its operations Contact the clearBorderteam today → 

Steel and Aluminium at a Crossroads: Supply Chains, Tariff Wars, Business Impacts
Strategy & Horizon Scannning

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Strategy & Horizon Scannning

A fragile reset? What the US–China tariff truce means for cross-border trade strategies in 2026

In late October 2025, a diplomatic thaw between Washington and Beijing produced a narrowly scoped trade “pause” – a tactical (and temporary) easing of the headline tensions which have dominated the trade-sphere in recent months.  The agreement trimmed select U.S. tariff categories (for example, halving certain fentanyl-related duties), and opened the door to resumed Chinese purchases of U.S. soybeans; while Beijing signalled a conditional scaling back of some export controls on rare earth elements.  For boardrooms, this pause buys time for resilience-building; what it does not do is remove structural levers that can reignite escalation. China retains decisive market power over rare earths and refining capacity, and Beijing’s export restrictions – introduced and then expanded in October 2025 – remain a latent threat to industries from EV batteries to defence suppliers. Financial and commodity markets treated the announcement as tentative: rare-earth prices and equities briefly eased, but analysts warned supplies and stocks could re-tighten if the geopolitical headwinds shifted.  Meanwhile, political and legal fault-lines persist in Washington. The administration’s tariff authority under the International Emergency Economic Powers Act (IEEPA) is the subject of active judicial scrutiny at the U.S. Supreme Court; justices heard oral arguments on 5 November 2025 and raised serious questions about executive reach. A negative ruling could remove a major instrument of U.S. trade policy – or force the administration to pivot to other statutory levers. That legal uncertainty compounds the truce’s fragility.    Why this matters The US–China tariff truce offers a temporary pause, not lasting certainty. For boardrooms and global supply chain teams, understanding the risks, monitoring key signals, and proactively planning for multiple outcomes is critical to maintaining stability, protecting margins, and mitigating the operational and strategic impacts of potential renewed escalation.   More on the U.S., China, South Korea, and what trade talks mean for you: → Borders for the Boardroom: Sean Miner on the US-China trade deal Listen now on Spotify and Apple Music What changed in October 2025… and what didn’t What changed Targeted tariff adjustments and commitments. In the late-October negotiations, U.S. officials said certain tariff lines tied to fentanyl precursor chemicals would be halved – from 20% to 10% – lowering the headline U.S. tariff burden on Chinese imports by a reported few percentage points overall. The talks also included commitments for a sizeable uptick in Chinese purchases of U.S. soybeans (Treasury officials cited a figure in the region of 12 million metric tonnes for the season). It’s likely these moves were partially influenced by the U.S. administration’s desire to appease what it sees as a core voter base of workers and farmers. A temporary easing of export control pressure. Beijing signalled it would pause, or at least temper, certain enforcement actions tied to rare-earth export controls, helping to calm thin but critical supply lines for some manufacturers. Markets interpreted the message as conditional rather than permanent, and subsequent industry commentary urged caution.  Regional tariff alignment moves. The U.S. also reached or reaffirmed tariff understandings with regional partners (notably arrangements that set some levies for Japan and South Korea at lower bands), reshaping near-term trade exposure for particular sectors such as autos and shipbuilding. Those regional moves probably form part of a broader attempt to compartmentalise tensions and avoid a wider regional fallout.  What didn’t change The strategic rivalry remains. The truce is tactical. China’s longer-term industrial strategy – including control over mining, processing and refining of many rare earths – has not been reversed. Beijing’s October 2025 expansion of export controls (adding multiple elements and equipment to control lists) shows the country still possesses structural levers that could be re-deployed if negotiations sour.  Legal and policy uncertainty in Washington. The Supreme Court review of IEEPA-based tariff authority introduces a material policy risk. If the Court constrains presidential power to impose broad tariffs, the administration may have to pivot to other mechanisms (e.g., Section 232, Trade Act tools) with different political, legal and operational implications. In short; the legal basis that enabled the rapid imposition of duties early in 2025 is not guaranteed to persist.  Domestic market realities limit quick wins. Beijing’s promise to increase U.S. soybean purchases was electorally useful for the U.S. administration, perhaps, but agricultural market signals suggest China’s immediate buying capacity may be limited by inventory and crush-margin dynamics. Reuters reports flag a soybean stock overhang that may constrain near-term purchases.  The net effect At least in the immediate future, the October ‘tariff truce’ reduces the near-term political temperature: selected tariff lines were eased, some procurement resumed, and short-term market volatility abated.  But – the structural levers that create systemic risk (rare-earth dominance, legal uncertainty over tariff authority, and the political incentives that drive tit-for-tat measures) remain very much alive.  For business leaders, the best operational position is not one of détente, but of time-boxed respite. That means acting quickly to shore up optionality, and avoid being caught in a reactive posture when the pause ends.  H2: Why the truce Is fundamentally unstable The agreement was engineered as a tactical and temporary de-escalation, not as a lasting settlement. While headline tariff lines were softened, the levers of critical economic power remain deeply asymmetrical. First, China’s rare-earth export controls remain a potent strategic weapon. Despite signaling an easing of enforcement, Beijing retains control over key mining and refining capacity. Prior expansions of export restrictions demonstrate that it is fully capable of re-tightening. Second, President Trump’s tariff authority under IEEPA is in question. The U.S. Supreme Court’s current review directly challenges the administration’s legal basis to impose broad trade duties.  Third, domestic and political incentives complicate sustained cooperation. Beijing is under pressure to protect strategic industries; Washington faces conflicting demands from agriculture, manufacturing, tech, and national security voices.  Finally, the temporary nature of the pause itself speaks volumes. This is not a comprehensive reset but a time-bound, finite window, subject to the ebb and flow of geopolitical risk.  Implications for global business and supply chains This tactical pause in trade hostilities brings into focus certain risks for multinational companies operating across complex supply chains. Borders for the Boardroom: Christopher Salmon on supply chain resilience → Listen now on Spotify and Apple Music Import exposure and tariff risk Existing duties remain in place, and the legal jeopardy stemming from IEEPA challenges means the entire tariff infrastructure could change. For supply chain teams, this is the moment to re-assess import exposure: which products are most vulnerable, and what alternative sources exist if the truce unravels. Supply chain architecture and sourcing The pause presents a moment for strategic recalibration. Firms that once relied on ‘China +1’ sourcing strategies should re-evaluate: ‘China +N’ is the more resilient, risk-mitigated position. Near-shoring, alternate production hubs, and regional diversification offer possible solutions, but such shifts can be costly and time-consuming. Contracting, procurement, and pricing governance With uncertainty lessening in the short term, companies may be tempted to renegotiate contracts or lock-in suppliers aggressively. However, such moves should be structured carefully. Procurement teams should build scenario clauses into agreements, allow for tariff escalation or rollback triggers, and articulate pass-through mechanisms.  Capital deployment and investment strategy For capital-intensive operators (especially in autos, semiconductors, and clean tech) the pause is a window of opportunity to recommit capital, under conditional terms.  However, investment without horizon scanning is a high-stakes guessing game. Boardrooms must ringfence capital and create “if-then” gateways triggered directly by treaty developments and legal outcomes. Navigating the tariff pause: signals, strategy, and stability Timely, although seemingly never built to last, the US–China tariff truce represents a holding pattern amid unresolved geopolitical, legal, and economic pressures. For boardrooms, CFOs, and global supply chain leads, vigilance here is critical. The coming 6–9 months will reveal whether the pause becomes a platform for stability, or a prelude to renewed escalation. Key signals to monitor: Supreme Court IEEPA ruling: a decision limiting or upholding presidential tariff authority will immediately reshape strategic options. China’s compliance: soybean purchases, REE export controls, and shifts in blacklists or procurement rules will test the truce’s integrity. U.S. domestic pressures: farmers, retailers, tech, and security interests may prompt rapid shifts in U.S. tariff policy. South Korea and Japan: developments in semiconductor deals, export controls, and bilateral concessions could influence Beijing’s response. China’s geoeconomic posture: incremental moves in investment screening or sector targeting may accumulate into material operational risk. What cross-border companies should do: Refresh scenario models with tariff, legal, and geopolitical triggers Audit supplier and import exposure under multiple outcomes Advance diversification and dual-sourcing strategies Strengthen contractual protections for tariffs and disruptions Monitor policy daily, not quarterly Preparation builds stability Geopolitical uncertainty cannot be entirely eliminated; but it can be priced, planned for, and strategically contained. The U.S.–China relationship is unlikely to revert to pre-2018 norms: structural forces – technological leadership, critical minerals, industrial security – render volatility a recurring reality for multinational organisations. Boardrooms focused on embedding resilience into governance, procurement, investment, and supply chain design will be significantly better-equipped to face future scenarios and weather their impacts.   → Borders for the Boardroom: Christopher Salmon on supply chain resilience Listen now on Spotify and Apple Music

A fragile reset? What the US–China tariff truce means for cross-border trade strategies in 2026
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