The Case Defined:
A large Canadian electronics speciality firm geographically divided its imports across multiple professional service providers. When Canada Border Services Agency (CBSA) did an audit they found an issue and communicated that to the importer. Upon receipt of that information, from a CBSA perspective, the importer had ‘reason to believe’ that the information they had reported was in error, and therefore a compliance issue. The importer did notify the one professional services provider to address the issue that CBSA had found on a transaction that provider had processed for them, no other communication to other parties was done, thereby leaving a compliance hole open for the importer.
Communication is Key:
The key issue is lack of communication with the 4 providers in their trade program, the communication channels of an integrated trade compliance strategy would have helped them be transparent to all providers. It also raises the issue of why they diversified so much and created a more complex trade program then necessary?
Responsibility Matrix Key Tool for Accountability
A secondary issue is that of process. How did each provider arrive at the determination of tariff? The answer again goes back to the up front strategy. We would recommend a responsibility matrix or standard operating procedures is necessary to define up front how the relationship will work and who is responsible for what, clarity of risk.
Both of these issues are addressed in an Integrated Trade Compliance Strategy. Do you need one?