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International Trade Compliance Strategy Responsibility Matrix

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A quick reference tool that supports the white paper, The Case for an Integrated Trade Compliance Strategy. It shows a road map of relationships, owners, and tasks that are intertwined when an organization is active in international trade. This road map can assist an organization to benchmark their current practice versus that proposed with an Integrated Trade Strategy.

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International Trade Compliance Strategy Responsibility Matrix

  1. 1. Integrated Trade Compliance Strategy Responsibility Matrix t t en en ns m m tio op e ag ra m el a pe an ev Te O D M e ss ss l l s tiv ia ia m e e nc nc cu rd to in in e l ga ad EO na na us us us oa e Ex Le Tr Fi Fi B B C B C Global and International Business: Board of Directors Oversight Direction to CEO and Executive team for enterprise risk parameters √ Direction to CEO and Executive team for financial investment parameters √ Enterprise risk assessment and macro regulatory impact analysis --international expansion √ √ √ √ √ √ √ Enterprise risk assessment and macro regulatory impact analysis-manufacturing reorganization √ Director risk assessment – international expansion √ √ International expansion-investment assessment for international expansion √ √ √ √ Board of Directors Audit committee visibility to international expansion impact √ √ √ Selection of external auditors, external legal counsel, external trade counsel √ √ √ Corporate liability insurance- trade and regulatory risk assessment √ √ √ √ √ Corporate director liability insurance – trade and regulatory risk assessment √ √ √ √ √ CEO and Executive team liability insurance –trade and regulatory risk assessment √ √ √ √ √ International Business Development: CEO/ Executive Team Oversight International expansion-region/country regulatory assessment-impact analysis √ √ √ √ √ √ √ International acquisitions regulatory assessment – impact analysis √ √ √ √ √ √ √ International partnerships regulatory assessment-impact analysis √ √ √ √ √ √ √ International manufacturing –regulatory assessment-impact analysis √ √ √ √ √ √ √ International sourcing relationships assessment-impact analysis √ √ √ √ √ International sales contracts-regulatory assessment-impact analysis √ √ √ √ √ √ √ International sales partnerships-regulatory assessment-impact analysis √ √ √ √ √ √ √ International licensing and sales agreements-regulatory-impact analysis √ √ √ √ √ √ √ Financial Management Corporate international trade compliance checklist √ √ √ Valuation –regulatory assessment –tax impact analysis-Canada, US, international √ √ √ √ √ Valuation-regulatory assessment-customs impact analysis-Canada, US, international √ √ √ √ √ Impact assessment of foreign supply chain on NAFTA eligibility √ √ √ √ Regional Free Trade Agreement assessment and impact on foreign sourcing costs √ √ √ √ Regional Free Trade Agreement assessment and impact on foreign sales costs √ √ √ √ Regional FTA risk burden assessment-Canada, US, international √ √ √ Low cost country/region analysis on international sourcing options √ √ √ √ Free Trade Zone analysis-international/global opportunity assessment √ √ √ √ Free Trade Zone analysis- US, Canada opportunity assessment √ √ √ √ Canada/US OGD requirements/enforcement impact assessment √ √ √ √ International/global requirements/enforcement impact assessment √ √ √ √ √ √ Canada/US Permit, license, quota assessments √ √ √ International/global permit, license, quota assessments √ √ √
  2. 2. Canada/US restricted goods assessment √ √ √ International/global restricted goods assessment √ Canada/US restricted parties screening √ √ √ International/global restricted parties screening √ √ √ CBSA-US Bonds, GST Letter, Account Security √ √ √ CBSA, USBP financial settlement duties and taxes √ √ √ CBSA, USBP audits and interventions √ √ √ √ √ √ √ CBSA, USBP post entry adjustments √ √ √ √ CBSA, USBP fines and penalties payment √ √ √ √ Taxation model assessment and impact analysis √ √ √ √ √ Canadian and US corporate tax returns and oversight to auditors √ √ √ √ √ Valuation model assessment and impact analysis √ √ √ √ √ √ Cost of sales audits factoring trade-related expenditures √ √ √ √ Duty paid, duty saved surveillance and management √ √ √ √ Foreign vendors-terms of sale and administration of accounts payable √ √ √ √ Foreign customers-terms of sale and administration of accounts receivable √ √ √ Letter of Credit settlement and compliance assessment-exports √ √ √ √ Letter of Credit settlement and compliance assessment-imports √ √ √ √ Canadian duty drawback assessment and administration √ √ √ √ US duty drawback assessment and administration √ √ √ √ GST collection, remittance, reporting, and reconciliation √ √ √ √ Currency Exchange Assessment & Strategy √ √ √ Export Insurance Assessment & Strategy √ √ Business Operations: Global Sourcing Country of origin impact assessment on NAFTA/FTA eligibility √ √ √ √ FTA eligibility and documentation √ √ √ √ Tariff classification of imported products by part number √ √ √ Country of origin verification of imported products by part number √ √ √ Currency of settlement /conversion √ √ Valuation criteria √ √ √ √ Value included-freight, cash discounts, √ √ √ √ Value included-assists, tool and die, drawings, moulds √ √ √ √ Purchase order preparation and nomenclature √ √ Customs invoices required √ √ Special permits √ √ √ OGD requirements √ √ √ SIMA reporting √ √ √ DFAIT applicability √ √ √ Annex Code eligibility √ √ √ Landed cost assessment √ √ Canada/US labelling/packaging requirements √ √ √ International/global packaging requirements √ √ √ Foreign sourcing process mapping √ √ Accountability matrix – supplier, importer √ √
  3. 3. Accountability matrix – importer team members √ √ √ √ Business Operations: Supply Chain-Logistics US Customs advance reporting assessment (e-manifest) and process map √ √ √ Canada advance reporting assessment (e-manifest) and process map √ √ √ International markets advance reporting requirements and process map by region √ √ √ Canadian OGD reporting requirements-in transit, on arrival, post entry √ √ √ US OGD reporting requirements-in transit, on arrival, post entry √ √ √ Import documentation flow mapping with supply chain partners √ √ √ Canadian Customs broker notification-protocol/process √ √ √ US Customs broker notification-protocol/process √ √ √ Carrier bonding and accreditation √ Carrier security clearance CTPAT, CSA √ Broker security clearance CTPAT, PIP √ √ √ In bond, bonded warehouse requirements √ √ √ Supply chain compliance map √ √ √ Accountability matrix – carrier, importer, customs broker √ √ √ Business Operations: Manufacturing Product development and engineering: international technical compliance specification review √ √ Product development and engineering: international safety compliance specification review √ √ Product development and engineering: Canada and US safety compliance specification review √ √ Manufacturing process certification: Canada and US industry specifications √ √ Manufacturing process certification: International industry specifications √ Bill of materials: part number, assembly, sub-assembly: domestic and international components √ Labour, material and overhead calculations for regional value content to support FTA benefits √ √ Segregated receiving process for international imports √ Discrepancy reporting to Customs or broker for shortages/overages, undeclared items √ √ √ Return process for internationally sourced goods –defective, warranty, repair and return √ √ Packaging and containerization requirements: Canada/US √ √ √ Packaging and containerization requirements: International/global √ √ √ Plant and grounds security: compliance with C-TPAT, PIP certification √ √ √ Personnel security and access: compliance with C-TPAT, PIP certification √ √ √ Supplier security: compliance with C-TPAT, PIP certification √ Carrier security and access: compliance with C-TPAT, PIP certification √ Business Operations: Global Exporting Importer of Record determination-vendor or customer √ √ US/Canadian security and bonding arrangements √ √ √ √ Export Control and OGD assessment (DFAIT, FDA, DND, etc) √ √ √ √ Special permits, licenses, quota reporting √ √ √ Advance reporting requirements, Canada Customs, US Customs, country of destination √ √ √ Export documentation review-country of origin √ √ √ Export documentation review-country of destination √ √ √ Export documentation review-in transit considerations √ √ √ Restricted party screening and verification √ √ √ Identification of special packaging requirements for finished goods-Canada/US √ √ √
  4. 4. Identification of special packaging or labelling requirements for country of destination √ √ √ √ Valuation determination-related party, third party, terms of sale, value included services √ √ √ Tariff classification determination of exported goods by part or item number 6 digits √ √ √ Tariff classification determination of exported goods to 10 digits – country of destination √ √ √ √ Origin criteria determination for FTA benefits if applicable √ √ √ √ Certification of origin creation and verification, sign off by qualified officer √ √ √ √ √ √ C-TPAT review – carrier(s), Customs Broker, logistics parties, customer √ √ Export Insurance Assessment & Review √ √ Risk Management and Compliance: Customs Broker Broker-importer GAA, Power of Attorney sign off √ √ √ √ √ Customs bonding arrangements-bonds, GST letters √ √ √ √ Canadian Customs clearance, brokerage, reporting to CBSA √ √ US Customs clearance, brokerage, reporting to USBP √ √ Facilitate financial obligations of importer of record to CBSA and USBP √ √ √ Facilitate record keeping obligations of importer of record to CBSA and USBP √ √ √ Facilitate security and bonding of importer of record to CBSA and USBP √ √ √ √ Interface with importer of record’s carriers and suppliers re trade documents √ √ Interface with or representation - Other Canadian and US Government Departments √ √ Assistance with or representation- CBSA, USBP audits and compliance verification reviews √ √ √ √ √ √ √ Assistance with or representation- CBSA, USBP fines, penalties, sanctions √ √ √ √ √ √ √ Assistance with or representation-CBSA, USBP prior disclosures √ √ √ √ √ √ √ Assistance with or contractor for tariff classification of imported and exported products √ √ √ Assistance with or contractor for origin determination, √ √ √ Assistance with or contractor for certification of origin validation, creation, pursuit √ √ √ Assistance with valuation determination, method, administration √ √ √ √ Assistance with or contractor for post entry adjustments and corrections √ √ √ √ Assistance with or contractor for importer’s database with all regulatory components √ √ √ Assistance with or contractor for Canadian and US duty drawback √ √ √ √ Assistance with international security certifications: CTPAT, PIP, CSA √ √ √ √ Sourcing assessments – regulatory impact analysis, FTA applicability, duty analysis √ √ √ New market assessments- regulatory impact analysis, FTA applicability, duty analysis √ √ √ √ √ Canada-US Free Trade Zone assessments and duty-tax deferral impact analysis √ √ √ √ Canada-US Free Zone administration and assistance to importer of record √ √ √ √ Special projects and contracts for services as directed √ √ √ √ Broker-importer liability matrix-fines, penalties √ √ √ √ √ √ Broker-importer responsibility matrix √ √ √ √ Broker- importer information flow map √ √ √ √ Risk Management and Compliance: Legal Counsel Client-Lawyer privilege protection √ √ √ √ International business expansion assessment for legal liability impacts √ √ √ √ Power of Attorney, General Agency Agreement review √ √ √ √ √ √ √ √ Counsel/represent importer of record before CBSA for fines, penalties, sanctions √ √ √ √ √ √ √ √ Counsel/represent importer of record before US Customs for fines, penalties, sanctions √ √ √ √ √ √ √ √ Counsel/represent importer of record- Other Canadian Government Departments √ √ √ √ √ √ √
  5. 5. Counsel/represent importer of record- Other US Government Departments √ √ √ √ √ √ Counsel/represent importer of record- CBSA audits and compliance verification reviews √ √ √ √ √ √ Counsel/represent importer of record –US Customs audits and compliance verification reviews √ √ √ √ √ √ Counsel/represent importer of record –CBSA prior disclosures √ √ √ √ √ √ Counsel/represent importer of record- US Customs prior disclosures √ √ √ √ √ √ Counsel/represent importer of record –disputes with foreign vendors for non-compliance √ √ √ √ √ Counsel/represent importer of record – disputes with foreign customers for non-compliance √ √ √ √ √ Counsel/represent importer of record- disputes with customs brokers, carriers, forwarders √ √ √ √ √ Counsel/represent importer of record-taxation disputes with CRA, IRS √ √ √ √ √ √ Risk Management and Compliance: Tax Auditor-Professional Services International business expansion assessment for taxation and financial liability impacts √ √ √ √ √ Canada/US tax audit services √ √ √ √ √ Canada/US tax preparation services √ √ √ √ √ Canada/US representation before CRA, IRS √ √ √ √ √ Valuation reviews and opinion – international sourcing, international sales √ √ √ √ Regional value content (RVC) determination for exported goods √ √ √ √ √ √ Assistance with, or contract services for GST assessments, reporting, and reconciliation √ √ Canada-US Free Trade Zone assessments and duty-tax deferral impact analysis √ √ √ √ √ √ Sourcing assessments – regulatory and tax impact analysis √ √ √ √ √ √ New market assessments- regulatory and tax impact analysis √ √ √ √ √ √
  6. 6. Integrated Trade Complia d r oa B C Global and International Business: Board of Directors Oversight Direction to CEO and Executive team for enterprise risk parameters Direction to CEO and Executive team for financial investment parameters Enterprise risk assessment and macro regulatory impact analysis --international expansion Enterprise risk assessment and macro regulatory impact analysis-manufacturing reorganization Director risk assessment – international expansion International expansion-investment assessment for international expansion Board of Directors Audit committee visibility to international expansion impact Selection of external auditors, external legal counsel, external trade counsel Corporate liability insurance- trade and regulatory risk assessment Corporate director liability insurance – trade and regulatory risk assessment CEO and Executive team liability insurance –trade and regulatory risk assessment Financial Management Valuation –regulatory assessment –tax impact analysis-Canada, US, international Valuation-regulatory assessment-customs impact analysis-Canada, US, international CBSA, USBP audits and interventions Taxation model assessment and impact analysis Canadian and US corporate tax returns and oversight to auditors Risk Management and Compliance: Legal Counsel Client-Lawyer privilege protection International business expansion assessment for legal liability impacts Power of Attorney, General Agency Agreement review Counsel/represent importer of record before CBSA for fines, penalties, sanctions Counsel/represent importer of record before US Customs for fines, penalties, sanctions Counsel/represent importer of record- Other Canadian Government Departments Counsel/represent importer of record- Other US Government Departments Counsel/represent importer of record- CBSA audits and compliance verification reviews Counsel/represent importer of record –US Customs audits and compliance verification reviews
  7. 7. Counsel/represent importer of record –CBSA prior disclosures Counsel/represent importer of record- US Customs prior disclosures Counsel/represent importer of record-taxation disputes with CRA, IRS Risk Management and Compliance: Tax Auditor-Professional Services International business expansion assessment for taxation and financial liability impacts Canada/US tax audit services Canada/US tax preparation services Canada/US representation before CRA, IRS
  8. 8. ated Trade Compliance Strategy Responsibility Matrix t t en en ns m em io op at ag am el r pe an ev Te O D M e s s l l iv ia ia es es t nc nc cu d in in l ga r EO na na us us oa e Ex Le Fi Fi B B B C √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  9. 9. √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  10. 10. l s ia om nc de l ga t na us a Le Tr Fi C √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  11. 11. √ √ √ √ √ √ √ √ √ √
  12. 12. Integrated Trade Complia d r oa B C International Business Development: CEO/ Executive Team Oversight International expansion-region/country regulatory assessment-impact analysis International acquisitions regulatory assessment – impact analysis International partnerships regulatory assessment-impact analysis International manufacturing –regulatory assessment-impact analysis International sourcing relationships assessment-impact analysis International sales contracts-regulatory assessment-impact analysis International sales partnerships-regulatory assessment-impact analysis International licensing and sales agreements-regulatory-impact analysis Financial Management Valuation –regulatory assessment –tax impact analysis-Canada, US, international Valuation-regulatory assessment-customs impact analysis-Canada, US, international International/global requirements/enforcement impact assessment CBSA, USBP audits and interventions Taxation model assessment and impact analysis Canadian and US corporate tax returns and oversight to auditors Valuation model assessment and impact analysis Business Operations: Manufacturing Plant and grounds security: compliance with C-TPAT, PIP certification Personnel security and access: compliance with C-TPAT, PIP certification Business Operations: Global Exporting Certification of origin creation and verification, sign off by qualified officer Risk Management and Compliance: Customs Broker Broker-importer GAA, Power of Attorney sign off Customs bonding arrangements-bonds, GST letters Facilitate security and bonding of importer of record to CBSA and USBP Assistance with or representation- CBSA, USBP audits and compliance verification reviews
  13. 13. Assistance with or representation- CBSA, USBP fines, penalties, sanctions Assistance with or representation-CBSA, USBP prior disclosures Broker-importer liability matrix-fines, penalties Risk Management and Compliance: Legal Counsel Client-Lawyer privilege protection International business expansion assessment for legal liability impacts Power of Attorney, General Agency Agreement review Counsel/represent importer of record before CBSA for fines, penalties, sanctions Counsel/represent importer of record before US Customs for fines, penalties, sanctions Counsel/represent importer of record- Other Canadian Government Departments Counsel/represent importer of record- Other US Government Departments Counsel/represent importer of record- CBSA audits and compliance verification reviews Counsel/represent importer of record –US Customs audits and compliance verification reviews Counsel/represent importer of record –CBSA prior disclosures Counsel/represent importer of record- US Customs prior disclosures Counsel/represent importer of record –disputes with foreign vendors for non-compliance Counsel/represent importer of record – disputes with foreign customers for non-compliance Counsel/represent importer of record- disputes with customs brokers, carriers, forwarders Counsel/represent importer of record-taxation disputes with CRA, IRS Risk Management and Compliance: Tax Auditor-Professional Services International business expansion assessment for taxation and financial liability impacts Canada/US tax audit services Canada/US tax preparation services Canada/US representation before CRA, IRS Valuation reviews and opinion – international sourcing, international sales Regional value content (RVC) determination for exported goods Canada-US Free Trade Zone assessments and duty-tax deferral impact analysis Sourcing assessments – regulatory and tax impact analysis New market assessments- regulatory and tax impact analysis
  14. 14. ated Trade Compliance Strategy Responsibility Matrix t t en en ns m em io op at ag am el r pe an ev Te O D M e s s l l iv ia ia es es t nc nc cu d in in l ga r EO na na us us oa e Ex Le Fi Fi B B B C √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  15. 15. √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  16. 16. l s ia om nc de l ga t na us a Le Tr Fi C √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  17. 17. √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  18. 18. Integrated Trade Complia d r oa B C Global and International Business: Board of Directors Oversight Selection of external auditors, external legal counsel, external trade counsel International Business Development: CEO/ Executive Team Oversight International expansion-region/country regulatory assessment-impact analysis International acquisitions regulatory assessment – impact analysis International partnerships regulatory assessment-impact analysis International manufacturing –regulatory assessment-impact analysis International sourcing relationships assessment-impact analysis International sales contracts-regulatory assessment-impact analysis International sales partnerships-regulatory assessment-impact analysis International licensing and sales agreements-regulatory-impact analysis Financial Management Valuation –regulatory assessment –tax impact analysis-Canada, US, international Valuation-regulatory assessment-customs impact analysis-Canada, US, international International/global requirements/enforcement impact assessment CBSA, USBP audits and interventions CBSA, USBP fines and penalties payment Taxation model assessment and impact analysis Canadian and US corporate tax returns and oversight to auditors Valuation model assessment and impact analysis Business Operations: Manufacturing Plant and grounds security: compliance with C-TPAT, PIP certification Personnel security and access: compliance with C-TPAT, PIP certification Business Operations: Global Exporting Certification of origin creation and verification, sign off by qualified officer Risk Management and Compliance: Customs Broker
  19. 19. Broker-importer GAA, Power of Attorney sign off Assistance with or representation- CBSA, USBP audits and compliance verification reviews Assistance with or representation- CBSA, USBP fines, penalties, sanctions Assistance with or representation-CBSA, USBP prior disclosures Broker-importer liability matrix-fines, penalties Risk Management and Compliance: Legal Counsel Client-Lawyer privilege protection International business expansion assessment for legal liability impacts Power of Attorney, General Agency Agreement review Counsel/represent importer of record before CBSA for fines, penalties, sanctions Counsel/represent importer of record before US Customs for fines, penalties, sanctions Counsel/represent importer of record- Other Canadian Government Departments Counsel/represent importer of record- Other US Government Departments Counsel/represent importer of record- CBSA audits and compliance verification reviews Counsel/represent importer of record –US Customs audits and compliance verification reviews Counsel/represent importer of record –CBSA prior disclosures Counsel/represent importer of record- US Customs prior disclosures Counsel/represent importer of record –disputes with foreign vendors for non-compliance Counsel/represent importer of record – disputes with foreign customers for non-compliance Counsel/represent importer of record- disputes with customs brokers, carriers, forwarders Counsel/represent importer of record-taxation disputes with CRA, IRS Risk Management and Compliance: Tax Auditor-Professional Services International business expansion assessment for taxation and financial liability impacts Canada/US tax audit services Canada/US tax preparation services Canada/US representation before CRA, IRS Valuation reviews and opinion – international sourcing, international sales Regional value content (RVC) determination for exported goods Canada-US Free Trade Zone assessments and duty-tax deferral impact analysis Sourcing assessments – regulatory and tax impact analysis New market assessments- regulatory and tax impact analysis
  20. 20. ated Trade Compliance Strategy Responsibility Matrix t t en en ns m em io op at ag am el r pe an ev Te O D M e s s l l iv ia ia es es t nc nc cu d in in l ga r EO na na us us oa e Ex Le Fi Fi B B B C √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  21. 21. √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  22. 22. l s ia om nc de l ga t na us a Le Tr Fi C √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  23. 23. √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  24. 24. Integrated Trade Complia d r oa B C Financial Management Impact assessment of foreign supply chain on NAFTA eligibility Regional Free Trade Agreement assessment and impact on foreign sourcing costs Low cost country/region analysis on international sourcing options CBSA, USBP audits and interventions CBSA, USBP post entry adjustments CBSA, USBP fines and penalties payment Cost of sales audits factoring trade-related expenditures Duty paid, duty saved surveillance and management Foreign vendors-terms of sale and administration of accounts payable Foreign customers-terms of sale and administration of accounts receivable Letter of Credit settlement and compliance assessment-imports Canadian duty drawback assessment and administration US duty drawback assessment and administration GST collection, remittance, reporting, and reconciliation Business Operations: Global Sourcing Country of origin impact assessment on NAFTA/FTA eligibility FTA eligibility and documentation Tariff classification of imported products by part number Country of origin verification of imported products by part number Currency of settlement /conversion Valuation criteria Value included-freight, cash discounts, Value included-assists, tool and die, drawings, moulds Purchase order preparation and nomenclature Customs invoices required Special permits OGD requirements SIMA reporting
  25. 25. DFAIT applicability Annex Code eligibility Landed cost assessment Canada/US labelling/packaging requirements International/global packaging requirements Foreign sourcing process mapping Accountability matrix – supplier, importer Accountability matrix – importer team members Business Operations: Supply Chain-Logistics US Customs advance reporting assessment (e-manifest) and process map Canada advance reporting assessment (e-manifest) and process map International markets advance reporting requirements and process map by region Canadian OGD reporting requirements-in transit, on arrival, post entry US OGD reporting requirements-in transit, on arrival, post entry Import documentation flow mapping with supply chain partners Canadian Customs broker notification-protocol/process US Customs broker notification-protocol/process Carrier bonding and accreditation Carrier security clearance CTPAT, CSA Broker security clearance CTPAT, PIP In bond, bonded warehouse requirements Supply chain compliance map Accountability matrix – carrier, importer, customs broker Business Operations: Manufacturing Product development and engineering: international technical compliance specification review Product development and engineering: international safety compliance specification review Product development and engineering: Canada and US safety compliance specification review Manufacturing process certification: Canada and US industry specifications Manufacturing process certification: International industry specifications Bill of materials: part number, assembly, sub-assembly: domestic and international components Labour, material and overhead calculations for regional value content to support FTA benefits Segregated receiving process for international imports Discrepancy reporting to Customs or broker for shortages/overages, undeclared items Return process for internationally sourced goods –defective, warranty, repair and return Packaging and containerization requirements: Canada/US Packaging and containerization requirements: International/global Plant and grounds security: compliance with C-TPAT, PIP certification
  26. 26. Personnel security and access: compliance with C-TPAT, PIP certification Supplier security: compliance with C-TPAT, PIP certification Carrier security and access: compliance with C-TPAT, PIP certification Business Operations: Global Exporting Importer of Record determination-vendor or customer US/Canadian security and bonding arrangements Export Control and OGD assessment (DFAIT, FDA, DND, etc) Special permits, licenses, quota reporting Advance reporting requirements, Canada Customs, US Customs, country of destination Export documentation review-country of origin Export documentation review-country of destination Export documentation review-in transit considerations Restricted party screening and verification Identification of special packaging requirements for finished goods-Canada/US Identification of special packaging or labelling requirements for country of destination Valuation determination-related party, third party, terms of sale, value included services Tariff classification determination of exported goods by part or item number 6 digits Tariff classification determination of exported goods to 10 digits – country of destination Origin criteria determination for FTA benefits if applicable Certification of origin creation and verification, sign off by qualified officer Export Insurance Assessment & Review Risk Management and Compliance: Customs Broker Broker-importer GAA, Power of Attorney sign off Canadian Customs clearance, brokerage, reporting to CBSA US Customs clearance, brokerage, reporting to USBP Facilitate financial obligations of importer of record to CBSA and USBP Facilitate record keeping obligations of importer of record to CBSA and USBP Facilitate security and bonding of importer of record to CBSA and USBP Interface with importer of record’s carriers and suppliers re trade documents Interface with or representation - Other Canadian and US Government Departments Assistance with or representation- CBSA, USBP audits and compliance verification reviews Assistance with or representation- CBSA, USBP fines, penalties, sanctions Assistance with or representation-CBSA, USBP prior disclosures Assistance with or contractor for tariff classification of imported and exported products Assistance with or contractor for origin determination, Assistance with or contractor for certification of origin validation, creation, pursuit Assistance with valuation determination, method, administration
  27. 27. Assistance with or contractor for post entry adjustments and corrections Assistance with or contractor for importer’s database with all regulatory components Assistance with or contractor for Canadian and US duty drawback Assistance with international security certifications: CTPAT, PIP, CSA Sourcing assessments – regulatory impact analysis, FTA applicability, duty analysis Canada-US Free Trade Zone assessments and duty-tax deferral impact analysis Canada-US Free Zone administration and assistance to importer of record Special projects and contracts for services as directed Broker-importer liability matrix-fines, penalties Broker-importer responsibility matrix Broker- importer information flow map Risk Management and Compliance: Legal Counsel Power of Attorney, General Agency Agreement review Counsel/represent importer of record before CBSA for fines, penalties, sanctions Counsel/represent importer of record before US Customs for fines, penalties, sanctions Counsel/represent importer of record- Other Canadian Government Departments
  28. 28. ated Trade Compliance Strategy Responsibility Matrix t t en en ns m em io op at ag am el r pe an ev Te O D M e s s l l iv ia ia es es t nc nc cu d in in l ga r EO na na us us oa e Ex Le Fi Fi B B B C √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  29. 29. √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  30. 30. √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  31. 31. √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  32. 32. l s ia om nc de l ga t na us a Le Tr Fi C √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  33. 33. √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  34. 34. √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  35. 35. √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  36. 36. Integrated Trade Complia d r oa B C Global and International Business: Board of Directors Oversight Enterprise risk assessment and macro regulatory impact analysis --international expansion International expansion-investment assessment for international expansion Board of Directors Audit committee visibility to international expansion impact Selection of external auditors, external legal counsel, external trade counsel Corporate liability insurance- trade and regulatory risk assessment Corporate director liability insurance – trade and regulatory risk assessment CEO and Executive team liability insurance –trade and regulatory risk assessment International Business Development: CEO/ Executive Team Oversight International expansion-region/country regulatory assessment-impact analysis International acquisitions regulatory assessment – impact analysis International partnerships regulatory assessment-impact analysis International manufacturing –regulatory assessment-impact analysis International sourcing relationships assessment-impact analysis International sales contracts-regulatory assessment-impact analysis International sales partnerships-regulatory assessment-impact analysis International licensing and sales agreements-regulatory-impact analysis Financial Management Corporate international trade compliance checklist Valuation –regulatory assessment –tax impact analysis-Canada, US, international Valuation-regulatory assessment-customs impact analysis-Canada, US, international Impact assessment of foreign supply chain on NAFTA eligibility Regional Free Trade Agreement assessment and impact on foreign sourcing costs Regional Free Trade Agreement assessment and impact on foreign sales costs Regional FTA risk burden assessment-Canada, US, international Low cost country/region analysis on international sourcing options Free Trade Zone analysis-international/global opportunity assessment Free Trade Zone analysis- US, Canada opportunity assessment
  37. 37. Canada/US OGD requirements/enforcement impact assessment International/global requirements/enforcement impact assessment Canada/US Permit, license, quota assessments International/global permit, license, quota assessments Canada/US restricted goods assessment International/global restricted goods assessment Canada/US restricted parties screening International/global restricted parties screening CBSA-US Bonds, GST Letter, Account Security CBSA, USBP financial settlement duties and taxes CBSA, USBP audits and interventions CBSA, USBP post entry adjustments CBSA, USBP fines and penalties payment Taxation model assessment and impact analysis Canadian and US corporate tax returns and oversight to auditors Valuation model assessment and impact analysis Cost of sales audits factoring trade-related expenditures Duty paid, duty saved surveillance and management Foreign vendors-terms of sale and administration of accounts payable Foreign customers-terms of sale and administration of accounts receivable Letter of Credit settlement and compliance assessment-exports Letter of Credit settlement and compliance assessment-imports Canadian duty drawback assessment and administration US duty drawback assessment and administration GST collection, remittance, reporting, and reconciliation Currency Exchange Assessment & Strategy Export Insurance Assessment & Strategy Business Operations: Global Sourcing Country of origin impact assessment on NAFTA/FTA eligibility FTA eligibility and documentation Currency of settlement /conversion Valuation criteria Value included-freight, cash discounts, Value included-assists, tool and die, drawings, moulds Landed cost assessment Foreign sourcing process mapping Accountability matrix – supplier, importer
  38. 38. Accountability matrix – importer team members Business Operations: Manufacturing Labour, material and overhead calculations for regional value content to support FTA benefits Discrepancy reporting to Customs or broker for shortages/overages, undeclared items Business Operations: Global Exporting Importer of Record determination-vendor or customer US/Canadian security and bonding arrangements Export Control and OGD assessment (DFAIT, FDA, DND, etc) Identification of special packaging or labelling requirements for country of destination Tariff classification determination of exported goods to 10 digits – country of destination Origin criteria determination for FTA benefits if applicable Certification of origin creation and verification, sign off by qualified officer Export Insurance Assessment & Review Risk Management and Compliance: Customs Broker Customs bonding arrangements-bonds, GST letters Facilitate financial obligations of importer of record to CBSA and USBP Facilitate record keeping obligations of importer of record to CBSA and USBP Facilitate security and bonding of importer of record to CBSA and USBP Assistance with or representation- CBSA, USBP audits and compliance verification reviews Assistance with or representation- CBSA, USBP fines, penalties, sanctions Assistance with or representation-CBSA, USBP prior disclosures Assistance with valuation determination, method, administration Assistance with or contractor for post entry adjustments and corrections Assistance with or contractor for Canadian and US duty drawback Assistance with international security certifications: CTPAT, PIP, CSA New market assessments- regulatory impact analysis, FTA applicability, duty analysis Canada-US Free Trade Zone assessments and duty-tax deferral impact analysis Canada-US Free Zone administration and assistance to importer of record Special projects and contracts for services as directed Broker-importer liability matrix-fines, penalties Broker-importer responsibility matrix Broker- importer information flow map Risk Management and Compliance: Legal Counsel Power of Attorney, General Agency Agreement review Counsel/represent importer of record before CBSA for fines, penalties, sanctions Counsel/represent importer of record before US Customs for fines, penalties, sanctions
  39. 39. Counsel/represent importer of record- Other US Government Departments Counsel/represent importer of record- CBSA audits and compliance verification reviews Counsel/represent importer of record –US Customs audits and compliance verification reviews Counsel/represent importer of record –CBSA prior disclosures Counsel/represent importer of record- US Customs prior disclosures Counsel/represent importer of record –disputes with foreign vendors for non-compliance Counsel/represent importer of record – disputes with foreign customers for non-compliance Counsel/represent importer of record- disputes with customs brokers, carriers, forwarders Counsel/represent importer of record-taxation disputes with CRA, IRS Risk Management and Compliance: Tax Auditor-Professional Services International business expansion assessment for taxation and financial liability impacts Canada/US tax audit services Canada/US tax preparation services Canada/US representation before CRA, IRS Valuation reviews and opinion – international sourcing, international sales Regional value content (RVC) determination for exported goods Assistance with, or contract services for GST assessments, reporting, and reconciliation Canada-US Free Trade Zone assessments and duty-tax deferral impact analysis Sourcing assessments – regulatory and tax impact analysis New market assessments- regulatory and tax impact analysis
  40. 40. ated Trade Compliance Strategy Responsibility Matrix t t en en ns m em io op at ag am el r pe an ev Te O D M e s s l l iv ia ia es es t nc nc cu d in in l ga r EO na na us us oa e Ex Le Fi Fi B B B C √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  41. 41. √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √
  42. 42. √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √

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