Process Definitions to Identify Revenue  
Today’s trade environment is one of shared responsibility between CBP and the importer. Our drawback approach thoroughly reviews company importing procedures and processes to determine how best to implement a drawback program geared towards its business practices.
  • Review company operations and records to determine the methodology and basis for each drawback program.
  • Develop a legal framework, based upon our audit findings, to maximize the drawback revenue.
  • Discuss audit findings.


  • Educate management on drawback requirements.
  • Meet with CBP to present the drawback program, methodology, designation basis, and recordkeeping.
  • Obtain CBP approvals.
  • Perform internal audits using reasonable care standards.
  • Implement drawback procedures for legal, data processing, and CBP regulatory requirements.
  • Document recordkeeping and record retention periods.
  • Interface with client data systems.
  • Verify data integrity between CBP, import, inventory, manufacturing, and export transactions.
  • Process drawback claims using proprietary software customized to client's business operations.
  • Track import designations on a claim and account basis to facilitate the drawback liquidation process.
  • Interface with CBP personnel.
  • Coordinate audit data requirements.
  • Resolve audit issues.
  • Follow up on audit findings.
  • Assist in the liquidation process
Our approach addresses the major components of duty: value, classification and quantity. We evaluate import compliance levels. Errors revealed by our processes that result in significant loss of revenue may be reflective of inadequate import control procedures. Resolution of these findings is critical to the import and drawback compliance process. Our focus is on data analysis not merely data collection.
A Systems Approach to Duty Drawback™