Does Santa Need a Trade Compliance Officer?

I’ve been joking for days about running a compliance check on the gifts Santa leaves under our trees, given the famously opaque supply chain of the North Pole. It usually gets a laugh. But the punchline lands a little too close to home, doesn’t it?

When you spend most of your waking hours thinking about trade, it becomes very hard to accept anything at face value. At this point, I don’t want a present from Santa unless it comes with proper declarations. Frankly, Santa should hire a trade compliance officer.

Because once you start looking at it seriously, the questions write themselves.

1. Where do these goods actually come from?

“Made in the North Pole” is one way to put it. To the best of my knowledge, the North Pole is not even subject to tariffs anywhere, which somehow makes this worse, not better.

Are these goods realllllllly manufactured in North Pole or just assembled there? Did they really pass the substantial transformation test? Where do the components come from, the plastics, the batteries, the electronics, the semiconductors, the technology? If parts are sourced across jurisdictions and merely put together by elves, Santa's running a real risk of misdeclaration.

2. Who touched the goods?

Then there is the uncomfortable question of who is involved in this supply chain.

Are we sure the manufacturer, trader, ports, vessels, shipping agents, or for that matter, Santa’s sleigh and reindeers, do not have any nexus with sanctioned persons or jurisdictions?

We operate in a world of near-strict liability when it comes to sanctions. The knowledge test is brutal, exposure is often indirect, and beneficial ownership chains have a way of surfacing at the worst possible moment. And no, I don’t think magic can help you get delisted.

3. Are the goods as wholesome as they should be?

Nobody can escape ESG compliance. Not even a fly-by-night operator like Santa (hehe).

If your goods are in the EU market, you cannot get by without having complete visibility over the embedded emissions in your goods. Especially now, with the potentially expanded scope of CBAM.

And then there are the elves. No transparency on working conditions. No wage disclosures. No independent audits. No grievance mechanisms. In the current regulatory climate, this is precisely the kind of supply chain that attracts forced-labour scrutiny.

4. How are these goods priced?

Santa’s entire business model also appears suspiciously subsidised. Free land. Free energy. Zero tax. Unlimited logistics. If this were any other manufacturer flooding global markets with under-priced goods once a year, domestic industries would already be preparing injury data. And, at what point does Christmas generosity start to look like dumping?

Are these goods safe?

Toys in India have no business being here if they don't comply with the BIS standards. Safety standards are not optional just because something is wrapped in red paper and goodwill. If a toy fails BIS requirements, it doesn’t matter whether it came from a factory, a sleigh, or a chimney, it shouldn’t be here.

How has Santa compiled the 'Naughty or Nice' list?

What data is being collected? Surveillance across jurisdictions? Where is this data stored, for how long, and who has access to it?

No privacy notice. No consent. No opt-out.

What is the prompt? Surveillance capitalism, but make it festive?

So yes. I think it’s safe to say I’ve become the Trade-Scrooge this season. But if there is anything I have learned in 2025, it's that there is no way you can bah-humbug your way out of trade compliance.