Trade Compliance Management Services

Trade compliance management is the set of policies, procedures, records, and checks that keep your import and export activity inside U.S. law. On the import side it covers exercising reasonable care over classification, valuation, and country of origin, paying the correct duties, and retaining entry records for five years. On the export side it covers classifying your products under export control rules, screening every party against restricted lists, obtaining licenses when required, and filing electronic export information. Wrapped around both is a written manual, staff training, internal audits, and a defined way to answer regulators. The point is not paperwork for its own sake; it is being able to prove, on demand, that your company knew and followed its obligations on every shipment.

Reasonable care is the legal standard the Customs Modernization Act places on the importer of record. It means you, not your broker, are responsible for using reasonable care to enter, classify, and value your goods correctly and to provide CBP accurate information. Hiring a broker does not transfer this duty; it helps you meet it. In practice, exercising reasonable care means having written procedures, asking for and following binding rulings when classification is unclear, keeping the documents that support each declaration, and correcting errors when you find them. CBP judges reasonable care by what you did before the entry, not by the outcome. A company that documents its process and acts on what it learns is far better positioned in an audit than one that simply trusted whatever its supplier wrote on the invoice.

Denied party screening checks the companies and people you do business with against government restricted lists, including the OFAC Specially Designated Nationals list, the BIS Entity List, the Denied Persons List, and debarred party lists. Doing business with a listed party, even unknowingly, can trigger serious civil and criminal penalties. You should screen every customer, supplier, freight forwarder, bank, and consignee, and you should screen them on every transaction rather than only at onboarding, because the lists change constantly and so do the parties in a shipment. Automated screening at the point a purchase order or shipment is created, plus periodic rescreening of your master data, is the practical standard. We build screening into the workflow so a hit stops the shipment before it moves rather than surfacing after the fact.

Often, yes. Export controls reach more companies than people expect. If you re-export goods, ship samples or repair returns abroad, send technology or software to a foreign national even inside the United States, or resell imported items to overseas buyers, the Export Administration Regulations can apply. Products with a specific Export Control Classification Number, or anything on the U.S. Munitions List under ITAR, may need a license before leaving the country. Even items that fall under the general EAR99 category still require you to screen the destination, end user, and end use. The safe approach is to classify your products, understand which of your flows count as exports, and screen every outbound party, so a routine shipment abroad does not become a controlled export you failed to license.

The general rule for U.S. import records is five years from the date of entry, covering entry summaries, invoices, packing lists, payment records, and any documents that support the classification, value, and origin you declared. Export records are generally kept five years from the date of export or from the license expiration. Certain drawback and program records run longer. The obligation is not just to keep the documents but to produce them promptly if CBP asks, which is where disorganized archives cause problems. We index your records by entry and export so any file can be pulled in minutes rather than reconstructed, which matters when a Request for Information gives you a fixed number of days to respond with supporting evidence.

A CF-28 is a Request for Information CBP sends when it wants more detail about an entry, often about classification, value, or country of origin. It is not yet a penalty, but how you answer shapes what happens next. You typically have thirty days to respond, and a weak or late response frequently leads to a CF-29 Notice of Action that changes your classification or rate, or worse. The right response is complete, accurate, and backed by the documents already in your file: invoices, purchase orders, product specifications, and any rulings that support your position. Because our compliance program captures that evidence when the shipment moves, a CF-28 is answered from the record instead of a last-minute scramble, and we involve trade counsel when the amount or exposure warrants it.

A written manual is not legally mandatory for every importer, but it is the single strongest piece of evidence that your company exercises reasonable care, and regulators expect serious traders to have one. It also keeps your program from living only in one experienced employee's head. A good manual assigns clear responsibility for compliance decisions, documents your procedures for classification, valuation, and origin, defines your screening and licensing steps, sets recordkeeping rules, and describes how you handle errors, disclosures, and regulator requests. It should reflect your actual products, trade lanes, and systems rather than a generic template. We write the manual to your operations, train your staff against it, and review it on a schedule so it stays current as your sourcing and the rules change.

A Focused Assessment is CBP's structured audit of an importer's internal controls. It usually starts with a questionnaire about how your company manages compliance, followed by a review of sample entries to test whether your declared classifications, values, and origins are supported and whether your controls actually work. If CBP concludes your controls are adequate, the assessment closes. If it finds gaps, it can expand into a detailed review, propose rate adjustments, and assess duties and penalties on past entries. The companies that come through cleanly are the ones that can hand over an organized record set and point to written procedures they demonstrably follow. We prepare clients for assessments by running the same tests internally first, so weaknesses are found and fixed on our timeline rather than CBP's.

A broker files your entries and helps you clear cargo, which is essential but transactional. Trade compliance management is the program around those entries: the written procedures, screening, export controls, recordkeeping, training, and audit readiness that prove your company as a whole meets its legal duties. A broker acts on the information you give it; a compliance program governs whether that information is right and whether you can defend it later. The two work best together. At CargoTrans the compliance team and the brokerage desk are the same organization, so the controls we design are the controls your entries are actually filed against, and there is no gap between what your manual says and what gets declared to CBP.

Pricing usually splits into a one-time build and an ongoing run. The build covers the gap assessment, risk profiling, and writing your procedures and manual, and it is scoped to the number of commodities, trade lanes, and entities you operate, since a single-product importer is far less work than a multi-entity exporter. The ongoing run covers denied party screening, periodic internal audits, recordkeeping oversight, and drafting responses when a regulator writes to you. Screening is often priced by the volume of parties or transactions checked. Training is usually a fixed fee per session. We scope the program to your actual risk rather than selling a fixed package, because a company shipping controlled technology needs more than one importing a single benign commodity. You get a defined build price and a predictable monthly run cost.

A working program is usually in place within four to eight weeks, though the timeline scales with your complexity. The first week or two is the gap assessment and risk profiling, where we review your current procedures, records, and screening against what the law requires and rank your exposure by commodity and trade lane. Writing the procedures and the manual takes another two to three weeks. Turning on screening and recordkeeping workflows and training your staff runs in parallel toward the end. A single-commodity importer can be live faster; a multi-entity operation with export-controlled products takes longer because there are more classifications and flows to document. We prioritize the highest-risk gaps first, so the exposures most likely to draw a penalty are closed early rather than waiting for the full program to finish.

A screening hit is not automatically a blocked deal, but it does stop the transaction until it is resolved. Most hits are potential matches on name or address rather than confirmed ones, so the first step is to review the match quality and gather identifying details to confirm whether your counterparty is actually the listed party. If it is a false positive, we document the review and release the shipment, keeping the record in case a regulator asks later. If it is a true match, the transaction must not proceed, and depending on the list and the facts you may have a reporting obligation to the relevant agency. The critical point is that the decision and its evidence are recorded, because acting on a hit without documenting the review is itself a compliance weakness. We build that review-and-document step into the workflow.

Partner government agency rules sit inside the same program rather than beside it. If you import products regulated by the FDA, USDA, EPA, or another agency, your procedures have to cover the extra registrations, codes, and reporting those agencies require, and your screening and recordkeeping have to capture that data too. For medical devices, for example, our FDA initial importer program manages establishment registration, listing, and prior notice as a defined part of the broader controls. The advantage of governing agency obligations inside one program is that a device or food shipment is not treated as an exception handled by a different team; it runs through the same reasonable care, screening, and records everything else does. That is what keeps a regulated shipment from being the one that slips through an otherwise disciplined process.

The program maintains the full evidentiary record behind every entry and export. On the import side that is the entry summary, commercial invoice, packing list, bill of lading, proof of duty payment, and any ruling or certificate that supports your declared classification, value, and origin. On the export side it is the electronic export information filing, the commodity classification, license determinations, and destination and end-user screening results. Around those sit your written procedures, your compliance manual, training records, internal audit findings, and the log of how each denied party hit was resolved. All of it must be retained for five years and produced on demand. We index the record by entry and export so a Request for Information or a Focused Assessment is answered from an organized file, pulled in minutes, rather than reconstructed under a deadline.