Creative problem solving is usually a good a thing, but when it comes to customs compliance, overlooking even one little detail can turn those great new solutions into great big problems.
“You’ve got to be careful when C-level people are asking you to find creative ways to massage compliance,” says Brent Krug, chief of staff, International Trade Compliance Group, LLC. “Then you end up on the front page of the Wall Street Journal for the wrong reasons.”
Krug and Jeremy Page, founding partner of PageFura, P.C., shared their experiences working with importers, exporters, and the brokerage-forwarding community during an AIAG Customs Town Hall presentation titled, “You Don’t Know What You Don’t Know.”
Among the examples of often overlooked risks, Krug said data and software can lead to very tricky territory. “A lot of people might think, ‘It’s just data,’ and then move on,” he said. “However, if your company compiles data or reports in Brazil, your VP in France can’t look at the data. It’s considered a Brazilian product. You would need to license it or make sure its compliant. It’s tough to tell the C-suite they can’t see their own company’s data because of where it originated, but explaining that is part of the job.”
While many of these “little things” are relevant to non-traditional imports, Page noted there is always a danger in not knowing what you don’t know.
“It’s amazing how many problems arise because someone signed a document they shouldn’t have,” he said. “They mean well. It’s the person down in loading saying, ‘Our company has NAFTA certification, so I can sign for that.’ They don’t know that certification is held by a person, not the company as a whole. Then, of course, that’s the one document that gets pulled for an audit.”
AIAG's Customs Town Hall is an annual gathering of importers, exporters, and associated service providers to discuss new and ongoing programs which impact customs clearance, compliance programs, and cost. The 2020 Customs Town Hall is Wednesday, November 4th at the Suburban Collection Showplace in Novi, Michigan. The program will focus on developments in trade policy, effective best practices for trade compliance programs, and critical insights into understanding how the trade and U.S. CBP can work together toward maintaining effective relationships.
“We joke about a lot of these problems stemming from the C-suite — and it’s certainly important that they know or are at least aware of these small challenges — but it’s equally important for everyone involved with any step of the process to be on the look-out for the little things,” Krug said. “It’s a lot easier to fix a little thing than it is to deal with a major compliance risk.”
Visit the event page to find out how you can get involved as an attendee, exhibitor, or sponsor, call AIAG Customer Service at 248-358-3003.
