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No, You Can’t Have Gummy Bears for Dinner, and Other Best Practices

Posted by Nara Mitchell

5/27/15 8:50 AM

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I’m always trolling the internet looking for ideas on a new blog (and new shoes, it’s just fact). As I read my standard compliance publications, I realized that there was not a whole lot of new hot material in the world of Customs Compliance.  Then I ran upon this oldie but goodie that CBP published a few years back: “US Customs and Border Protection Best Practices of Compliant Companies.” 

I am not going to overview all of their points, rather, the points I personally find the most important ( you can read the document in its entirety here )

  1. Have Management’s Commitment - Listen, our staff can decide that it is casual Tuesday, but if management isn’t brought in, I assume quite a few folks will be sent home to change. That’s just embarrassing. 
  2. Assign Authority - Who’s running the show here? And when you are assigning authority, it can’t be “Nara Scheib will be our key person to contact when tomatoes are stuck at the border.” It has to state “Practice Manager will be our key person to contact when tomatoes are stuck at the border.”  Because what happens when Nara Scheib is no longer working for you and therefor can’t deal with your stuck tomatoes.  Right, you see where I am going here. Define the responsibility in the job description. “Practice Manager is responsible for all tomatoes that are stuck at border.” 
  3. Develop Formal Policies - Let me tell you, if there was not a “No gummy bears for dinner” rule in my house, what do you think would happen.  Yep, every night, we would be having the gummy bear convo.  Your policies have to be known and communicated. Go into this knowing, that not everything is going to work. But with that knowledge, you need the commitment to modify controls that are inefficient. 
  4. Establish a Training Program - It’s all well and good for you to have these amazingly compliant ideas in your head, but if you don’t brain dump them out, and formulate a program, what good are they? As a sidebar, I have some seriously good ideas in my head, basically all the time! 
  5. Develop Compliance Requirements for Suppliers - If I wasn’t so lazy, I would switch things around and make this #1….. You are responsible for reasonable care. Say it again. You are responsible for reasonable care… Third time because I can’t express the importance of this, “YOU ARE RESPONSIBLE FOR REASONABLE CARE.” Point. Made. 
  6. Implement Monitoring - Not kidding here, I tell my oldest all the time “Bigs, I see everything you do.” He never believes me, but I will catch him mid-air, about to pounce on his brother and I am like “Yo yo, remember, I see everything.” Trust but validate. Monitor the effectiveness of your controls. Are they still working? Are they documented? 
  7. What Are Your Goals? - This is a toughie. It is like the compliance version of “What do I want to be when I grow up.” I dunno?? Really think about this, what are you trying to accomplish? And it can’t be as broad as “To be compliant.” I mean, right, we get that. You need to know what is important to your organization. 

Familiarize yourself with Best Practices, however, when it comes down to brass tacks, that is what experts are for. While I might not be able to stop your mini’s from eating gummy bears for dinner, Tradewin can guide your company through establishing an internal compliance program. 

Topics: Best Practices

Written by Nara Mitchell

Nara is a US Licensed Customs Broker and has worked in the Global Logistics industry since 2010. She specializes in import and export compliance with an emphasis in the textile and apparel chapters of the Harmonized Tariff Schedule of the United States (HTSUS). Nara is a graduate of Western New England University with a Bachelor of Science in Business Administration.