Managed Service Programs and Risk

While international business provides a world of market opportunities, it exposes your organization to significant risk. Managing and mitigating risks directly impact your bottom line. What keeps you up at night? Maybe it’s just not knowing what you don’t know. Braumiller Consulting specializes in assessing, designing and managing programs to exceed our clients’ expectations.

The seasoned professionals at BCG Consulting offer a full range of Managed Services to support your trade compliance needs. Since no two companies benefit from the same support, we tailor all managed services to our client’s business model. Our commitment to superior service, measurement and reporting allow for continuous improvement and risk containment. Below are examples of the managed service programs we’ve designed for our clients.

US & Global HTS Product Classification – Import and Export Schedules
- Product based determination of correct HTS codes for import and export into and out of the U.S., as well as around the world. Associated duty rates, additional duties, and import taxes such as GST and VAT can also be provided to assist in making better sourcing and supply chain decisions.
Risk Assessments
- Evaluation of import and export risks including prioritization. Let us help you understand where your greatest compliance risks reside and assist with a roadmap to mitigate risk in your purchasing, selling, and shipping channels.
Mexican Trade Law
- Are you new to the Mexican market or maybe you need legal help with your established business there. Our Mexican Trade Law practice can be your one stop shop for legal guidance and help with regulations, IMMEX, and all types of customs business. We are your “boots on the ground” in Mexico.
Customs Broker, Freight Forwarder, and Vendor Management
- Let us help you manage your customs broker, freight forwarder, and vendor partners. These partners can be excellent and reliable resources when they are properly managed. From the monitoring of transactions to establishing SOP’s and regular meeting schedules, we can help your partner relationships to be more productive and compliant. Proper vendor management ensures that goods will be properly marked and otherwise compliant and that documentation will be in accordance with your instructions and requirements.
Program Certification and Annual Reviews – CTPAT, CTPAT Trade Compliance, etc.
- Do you need help setting up your CTPAT programs or are you struggling to complete your annual reviews to remain certified? Let our experts work with you and your supply chain partners to make sure all of the criteria are met and your responses to CBP are filed correctly and timely to certify or remain certified as a trusted trader in CTPAT.
Free Trade Agreement Solicitation and Qualification
- Managing your free trade agreement solicitations and qualifications can be a time-consuming task. We can take that work off your plate by running your FTA solicitations, contacting vendors and suppliers, following up with them to ensure they respond, and vetting their information for accuracy and completeness. We can also review and qualify products for any free trade agreement for import, export, or sale domestically. If goods do not qualify, we can offer expert advice and guidance on how to modify sourcing or manufacturing so that the goods can properly qualify for the free trade agreement. On an ongoing basis, our team can manage this process from year to year and throughout the year when process and sourcing changes dictate.
Customs Valuation
- Proper customs valuation of your imported goods is critical to complying with customs requirements and regulations. Have you applied the valuation rules correctly and do you have all of the supporting documents to validate your value claims if Customs audits you? Our team can validate if you are valuing your goods correctly, correct any errors, and help you build a better process that will ensure your organization is always using appropriate valuation going forward.
Policy, Procedure & Process Analysis, Recommendations and Support
- Are your trade processes efficient, compliant, and proactive? Our team can review your current processes critically, analyze them thoughtfully, and then provide our recommendations to improve them and close any gaps. We can support the development, drafting, and implementation of policies, procedures, work instructions, terms-and-conditions, and other compliance-related documentation, as well as appropriate monitoring to ensure that any changes you make are communicated and implemented.
Import/Export Transaction Audits
- Auditing import and export transactions is an essential part of any trade compliance program. This ensures accuracy of information used and filed. Without a comprehensive audit strategy, your compliance program may not meet the monitoring requirements of Reasonable Care, as outlined by CBP in the Informed Compliance Publication. We can audit 100% of transactions, a set percentage of transactions, or conduct spot audits, depending on your needs. The result of these audits can drive process improvements, corrective actions, and strategic evaluations of supply chain partners and process. This service frees up your compliance team to focus on other issues and is more reliable than an internal audit.
Import/Export Policy, Procedure, and Process Audits
- The effectiveness of any policy, procedure or process must never be taken for granted. Are they being followed? If so, what makes them effective? If they aren’t followed, why not? And there’s always room for improvement in even the most effective documents. What are the gaps, redundancies, ambiguities, or other issues that can be addressed? We can look at your documents with the critical eye of an outsider and suggest changes, improvements, or different strategies.
Sanctioned and Restricted Party Screening and Clearing
- Exporters and importers are required to screen parties involved in their transactions to ensure compliance with all applicable restricted and sanctioned party lists. While your forwarder and customs broker may also conduct such screenings, it remains your obligation to conduct your own screenings. We can assist if your company lacks the appropriate resources to screen, or your confidence in the ability of internal resources to properly screen for sanctioned and/or restricted parties. Our knowledgeable advisors will use licensed software to properly screen and clear parties for you, giving you the confidence that you are not selling or shipping to, or buying from sanctioned or restricted parties.
Export License and License Exception Determination
- Determining when export licenses and exceptions are required can be technical and detailed work. Failure to obtain an export license or utilize an appropriate exception may result in monetary penalties and denial of export privileges.
Foreign Trade Zone Projects and Support
- From feasibility studies to establishing a Foreign Trade Zone, to assisting established FTZ’s, we have the expertise to understand what you need and create a plan that meets your needs. Our industry recognized FTZ experts can help you identify potential FTZ savings and put together a project plan and timeline to get you up and running as quickly as possible. Established zones often need assessing compliance or dealing with inventory issues. We have the experience and knowledge to help you with whatever issues you are facing and get your zone operation back on track and keep the FTZ savings flowing.
- Foreign Trade Zone Administration
- Our FTZ administration service removes the worry of day-to-day administration of your zone. You no longer have to worry about head count to staff your FTZ administration or covering vacations and medical leave. Our experienced staff can handle your FTZ transactions and interface with your operations and I.T. staff to address inventory issues, ERP issues, and software integration updates. By relying on the FTZ administration experts at Braumiller Consulting, you can realize actual savings based on efficiency and lower head count while increasing your compliance and access to available resources.
Post Entry Support – CF28 & CF29 analysis and response, Post Summary Corrections (PSC), Protests, Prior Disclosures, Voluntary Self-Disclosures
- Many of the issues that arise when importing goods occur after the entry is filed. CBP may issue a CF-28 or CF-29 that can often have implications beyond the targeted entry. It’s not unusual for an importer to discover material errors that need to be addressed (classification, value, origin, FTA qualification, 301 tariff exclusions, etc.), but there are specific processes and requirements for making corrections depending on the circumstances. We can help you determine the scope of the issue and the required actions needed.
Country of Origin Determination & Marking
- Country of origin rules may differ based on product and circumstance. We can review the various regulations pertaining to country of origin and assist with Country of Origin marking recommendations.
ADD/CVD Review & Determination
- Antidumping and countervailing duties may be assessed on a range of goods. We can perform a scope analysis to determine whether your goods are captured by an ADD/CVD order.
ADD/CVD Scope Rulings
- ADD/CVD orders are often vague or ambiguous. We can help you get the clarity your business needs by submitting a request for a scope ruling to determine if your products are subject to ADD/CVD.
Customs Binding Ruling Submissions
- CBP will issue binding rulings to importers on various import-related issues, including HTS classification, customs valuation, country-of-origin and marking determinations, and entry requirements. We have decades of experience in the research and preparation of ruling requests.
PGA Research and Support
- Many federal agencies have special rules that must be followed for specific products or circumstances. For example, the FDA and USDA have rules that regulate the importation of food, and the EPA and the Dept. of Transportation regulate the importation of automobiles. We can help you navigate the regulatory maze of these partner government agencies (PGAs).
Duty Drawback Claims Processing, Set-up, and Support
- An importer can recover 99% of customs duties from CBP under certain specific conditions through a process called duty drawback. We can help you review your business activities for drawback opportunities.
Reconciliation Entry Preparation & Filing
- CBP has a reconciliation entry program for flagging entries that require post-entry correction, but not every correction is eligible for reconciliation. We can review your business and guide you on whether the reconciliation entry process would be appropriate for your business.
CCATS Submissions
- Determining the appropriate ECCN for the goods you need to export can be a daunting task. When the ECCN cannot be reasonably determined, we can help to research, prepare, and submit a CCATS request to BIS.
Export License Submissions
- The export licensing process can be complex and time-consuming. We can research, prepare, and submit export license applications for BIS, DDTC, NRC/DOE, and OFAC. These licenses can be for physical exports, reexports, and in-country transfers; deemed exports; technology exports; and software exports.
Encryption License Arrangements
- The cryptographic capabilities of goods and software is highly controlled and is subject to unique export requirements. We can help you navigate the encryption rules.
OFAC Sanctions
- The Treasury Department’s Office of Foreign Assets Control (OFAC) is responsible for most of the sanctions imposed against countries, entities, industry segments, and persons. Compliance with the complex and ever-changing rules is mandatory. These rules can be especially troublesome for multinational companies with global operations. We can help you navigate these rules.
DDTC Registration
- U.S. companies that work in the defense sector must be registered with DDTC. We can help you prepare and submit your registration application.
ITAR Support
- Companies that deal with defense- and military-related goods will typically be subject to the ITAR, which are the regulations that control defense/military exports. We can help you navigate the ITAR, including classifying your items under the appropriate USML Category.
Expert Witnesses
- Our broad and deep experience in import and export matters makes us uniquely qualified to serve as an expert witness before an agency or a court.
Antiboycott
- Antiboycott compliance is one of the more neglected aspects of trade compliance. The antiboycott rules are extremely dense and long (over 100-pages in the EAR). We have the expertise to help you determine whether a transaction or relationship is affected by a boycott issue, and we can assist you in taking the appropriate action to resolve the boycott request.
Red Flag
- An effective red flag policy and procedure is one of the best proactive tools for avoiding trade compliance fall-downs. We can help you develop and implement a red flag program, including training employees and resolving actual and potential red flags.
Training & Education
- A well-trained and -educated workforce is critical to effective trade compliance. We can prepare and deliver training modules on any trade compliance topic, tailored to your company’s specific needs and delivered either in-person or via webinars.
Tariff Engineering Opportunities
- Tariff engineering is the proactive structuring of your products and processes so that the duty your company pays is less than it otherwise would be. We have the expertise to explore your company’s potential tariff engineering opportunities.
Incoterms
- Incoterms are ubiquitous but often misunderstood. They define the point in a transaction where the financial, compliance and logistical responsibilities transfer from a seller to a buyer. We can help you understand the implications of using or agreeing to an Incoterm that is not optimal for your transactions.
Technology Control Plans
- Technology is the lifeblood of every company, but the sharing of your technology with others can be a minefield of export restrictions. We can help you draft and implement an effective Technology Control Plan (TCP).
Assist with compliance evaluations of M&A opportunities
- M&A activities can also be a minefield of potential trade compliance concerns for a company acquiring another company. The acquiring company assumes all of the target company’s liabilities, whether they are disclosed or not during the vetting process. We can help you create a plan for reviewing the target company’s business for trade compliance risks, concerns, and liabilities.
Assist with compliance evaluations of facility relocations
- The relocation of a facility from one country to another has many trade compliance implications that must be proactively identified.
Recordkeeping
- Every company is required to maintain records for varying retention periods. We can review your company’s activities and help you develop a process to effectively maintain records.
Nuclear exports (NRC/DOE)
- Certain activities related to the nuclear power industry are subject to the export requirements of the NRC and DOE. We can help you navigate these requirements and obtain the necessary licenses and authorizations.

Our Firm

Care to have a consultation call regarding our services? Contact bob@braumillerlaw.com.