I will be safely flying to Seattle tonight. From Charleston, SC to Boston and then on to Seattle. I listened to the Governor of South Carolina talk about assessing the ongoing risk and damage to the environment, to assets and to people’s lives. There are currently more than 500 roads closed in South Carolina. A cascade of dams are being breached. As my wife, Liz was driving us through the 18” of water on the road we were looking around at the carnage and it got me thinking about how this risk might have been assessed and mitigated earlier versus just assessing and repairing the damage after the fact.

In a similar manner, unidentified risks can lead to unexpected damage to your company. Experience tells us that it often starts with a single-issue request for information (CF28) from Customs and Border Protection and cascades like those dams, where each failure swiftly leads to the uncovering of others. I am sure that you have seen this. One classification inquiry leads to a second, and a third and then a request for a sample, and documents confirming transaction value. Then what about those free trade claims? It is very difficult to stop the process once it starts.

Our staff has performed hundreds of risk assessments and while they are a deep dive encompassing dozens of areas from our client’s processes we see many of the same issues crop up repeatedly:

• A lack of a regularly scheduled audits
• A limited understanding of import valuation principles
• Harmonized tariff classification rendered by untrained employees and suppliers
• Poor recordkeeping practices

Please spend your time and resources on these issues and focus more on risk mitigation! Assess your risk in a comprehensive way every three years. It is very important to your company’s health. Be sure to hire experienced trade compliance staff and when needed reach out to experts in the trade and in government. More rain in the forecast.

If you work at mitigating risk in any way, comment below and let us know your tactics.