I recently attended a conference where “leaders” in companies providing trade compliance services were discussing trusted trader program procedures. As always, there was a focus on the downstream benefits which would accrue across all regulatory agencies for those companies who excel in getting it right. No gutter balls allowed.
A major presentation was given on the measurement of compliance with the focus on a scorecard approach. Basically, what I call the how many approach. How many ports do you import through, how many countries do you source from, how many manufacturers do you use, how many entries do you file, how many products do you import? Ultimately, what does this tell you? Well, it tells you how many ports you use, your source countries, etc., but does it make a reliable statement about your company’s overall compliance health?
Frankly, I was very disappointed that we haven’t moved past this scoring approach. With the advent of the Centers for Excellence and Expertise (CEEs), Customs and Border Protection is applying different ways of doing business. While CEEs are continuing to experience growing pains, the ability for the trade community to leverage the concepts of virtual teams, and the intelligent use of data and technology is critical to move the compliance goalpost in a more advantageous direction.
It does not matter if you are importing goods across the entire tariff and through every port of entry, as long as you have the correct internal controls and oversight structure in place. It is not a numbers game, but rather the process a company uses continually to monitor, test, assess, readjust if necessary, and report its compliance. This process will enable companies to make a more meaningful and accurate statement on how well their corporate policies and procedures effect compliance.
Let’s move in a more useful and productive direction and keep the scorecard where it belongs–at the bowling alley.
