Pack Your Bags; We're Going on a Journey! The Import Compliance Roadmap
John Goodrich - 2/26/2007
While every journey begins with a single step, it also begins where you stand. I would suggest to you that many of your companies do not truly know where they stand today when it comes to import compliance. Worse yet, they likely disagree about where the issues and opportunities exist. How is a company to begin its import compliance journey when there are varying views on what the issues are and where to begin?

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Every journey begins with a single step. No journey, of course, would begin without first referring to a map. Which step should be your first? In which direction should you go? The map helps decide the answers to these questions.

And so it is with the import regulatory compliance journey.

In a previous article we scored your company’s import compliance program and learned that you needed to take a journey. We did not, however, discover where and how to begin that trip. For many of you the questionnaire in that previous article likely raised more questions than it answered and did not leave you with a clear sense of what you need to do to strengthen your import regulatory compliance program.

While every journey begins with a single step, it also begins where you stand. I would suggest to you that many of your companies do not truly know where they stand today when it comes to import compliance. Worse yet, they likely disagree about where the issues and opportunities exist.

To demonstrate, I challenge you to distribute the questionnaire to a variety of individuals within your organization. The varying answers and levels of awareness will be instructive.

How is a company to begin its import compliance journey when there are varying views on what the issues are and where to begin?

Create a Roadmap

The answer is in designing a roadmap or compliance plan that will guide you on your journey. Each company’s compliance plan will be different but will have a number of characteristics in common.

The roadmap is first and foremost a record of where your company is today regarding the fundamentals of import compliance. It should record what your company is good at and where your company has opportunity to improve. This is the starting point from which you will begin your journey and the benchmark against which you will measure your progress.

The roadmap must have a destination. It should define what it means for your company to have a successful import compliance program. It may be an ambitious goal such as qualifying your company for the Importer Self Assessment or a more modest goal such as preparing for a Focused Assessment.

The roadmap should include an itinerary or an action plan detailing the steps you will follow to implement your plan. Finally your roadmap must allow you to measure your progress along the way and make changes. Importing is a dynamic field. What appeared to be a reasonable plan today may not be an effective control in a year or two.

Engage a Mapmaker

An effective method of developing your roadmap is to engage the services of a third party to review your import program, help you identify the greatest risks, and set priorities for addressing those risks.

Yes, we are talking about a consultant. To those of you who prefer the alternate spelling of that word (con-$ultant), I suspect there is little I can do to sway you. I hope, however, that over the past few years I have earned enough of your trust that you will at least finish reading this article.

Why Go Outside the Organization?

Why engage an external consultant when you could do the work yourself? The question is perfectly reasonable. If your company is well equipped with knowledgeable, experienced staff and the resources to move forward, you should do so. Even companies with the internal expertise find it helpful to look to the outside when it comes to designing a compliance program.

A consultant can bring qualities to a project that may not fully be found within the internal organization.

Qualifications: A consultant, particularly in the import arena, should be a licensed Customhouse Broker, well versed in the import regulations. Engaging a consultant allows a company to access expertise it might not otherwise be able to employ on a full-time basis.

Experience: In addition to their customs background, consultants typically have a breadth of experiences working within the importing industry and with other clients. A consultant is skilled at identifying compliance risks and suggesting actionable solutions.

Neutral Party: For better or worse companies are staffed by humans with egos and emotions. Engaging a third party can neutralize internal politics and help a company deal with an issue in a neutral, dispassionate way.

Catalyst/Lightening Rod: Instead of using consultants as a neutral third party, they can be used as a catalyst for change. The consultant can be the grain of sand that gives rise to the pearl. When the irritating consultant is gone the pearl of increased import compliance remains and so too does peace and harmony among the ranks of the employees.

Contextual Perspective: External consultants can provide companies a contextual perspective that can help build consensus within the organization. To internal compliance professionals, this approach can feel as if management doesn’t believe or trust you. The contrary is actually the case. Management did hear you. They simply needed to hear it from a different perspective.

Validation: For companies already scoring highly on internal compliance evaluations, looking to the outside is a method of validating the effectiveness of their internal controls.

Processes: Consultants come armed with processes, templates and ideas that work. These may seem cumbersome at times, but they allow a company to learn and move forward more quickly, effectively and economically than if a company was to develop these processes internally.

Visibility & Commitment: Engaging an external resource is a method for companies to signal their commitment to the compliance process. As a result staff members may grant the consultant access and respect not normally awarded to internal resources.

Bandwidth: Consultants have the luxury of focusing all their time on short, quantifiable projects that employees, engaged in the day-to-day business, find difficult to complete. While internal resources could certainly do the work, the short-term engagement of a consultant can help get that work done quickly.

Start Your Journey!

No matter how you devise your compliance plan roadmap; don’t forget to take the journey. A plan is no good if you don’t implement it. So pack your bags, put on those hiking boots and take that first step towards a more compliant import program.

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