Trade compliance managers
Decide how each CBP question is answered and sign the reply as preparer
- Open requests sorted by business days left
- A contradiction stopped before it reaches a signature
- Counsel’s past rulings at the moment of decision
Features
CF-28 response features, from the CBP request to the broker’s filing in ACE
The trade compliance manager, the analyst, counsel and the director use them to answer a request from the evidence. The screens follow one case on cast steel fittings.
demoThe importer, its supplier, the people, the entries and the figures on these screens are sample data.
- 01Request case
CBP Form 28 requests grouped as one case on a business-day clock
- One case for forms asking the same questions. CBP sends one form per entry; the manager answers the shared questions once, and the reply goes back with a copy of each form.
- Checked items and officer message split into questions. Each question carries its own status, so the manager sees which ones still wait on the supplier.
- Reply clock counted in business days. Weekends and federal holidays are taken out of the days left to the due date, so supplier chases are planned against the working days that remain.
- 02Reply draft
CF-28 response drafted sentence by sentence, each footnoted to its page
- Each reply sentence footnoted to its source. CBP can follow each claim to the document behind it, and the official who certifies can check the same trail.
- Agents steered in the middle of a run. The manager or analyst can widen the search mid-run, for example to last year’s entries, and the added step is logged with name and time.
- Draft stopped at a contradicted sentence. A sentence the evidence contradicts is struck and held for a person, so it cannot reach a signature.
- 03Challenger
Draft read as a CBP import specialist would, before anyone signs
- Points raised against the draft. Each point carries the follow-up question an import specialist would ask, so weak answers surface while the reply can still change.
- Answered with a source or handed to a person. The drafter answers what documents can settle; contradictions, weak evidence and entries not named go to the manager or counsel.
- Past rulings beside each point. The team’s own rulings on similar conflicts sit next to the point, so the same question gets the same answer from one request to the next.
- 04Evidence map
Melt and pour country traced heat by heat to each mill certificate
- Each entry line traced to its heat. Packing list, declared country, supplier field and certificate sit on one row, so the analyst stops reconciling four systems by eye.
- Contradictions marked on the line. A line whose certificate names another country than the entry declared is flagged before anyone drafts an answer on it.
- Unreadable heat numbers resolved from evidence. When a packing list cannot be read, the heat number comes from the supplier’s photo of the cast marking, never from a guess.
- 05Supplier request
Supplier requests in fixed fields, checked against each heat’s certificate
- Fixed fields asked for each heat. Foundry, country of melt and pour, pour date and an inspection certificate per heat, so answers arrive comparable instead of as paragraphs in email.
- Reply fields compared with the certificates. A supplier field that disagrees with its own attached certificate is flagged, so a declaration alone cannot carry the answer.
- Supplier free text routed to a person. Notes the supplier writes stay out of the agents’ reasoning; a person reads them, and counsel sees them in the supplier’s exact words.
- 06Exposure what-if
Duty exposure what-if across the entries CBP did not name
- Named and unnamed entries in one scope. Entries CBP did not name that share the supplier, heat or foundry are found and priced before anyone decides how to answer.
- Assumptions labeled and editable. Origin outcome, duty rate and interest are inputs the analyst confirms, so counsel reads a rehearsal as a rehearsal.
- Each way of answering priced as a path. Answering from the documents and asking for more time are compared on interest and deadline; an answer the documents contradict is not offered.
- 07Decision
Certificate against declaration, decided by the trade compliance manager
- Certificate and declaration side by side. The manager sees what the supplier declared against what the certificate shows, each source one click away.
- Counsel’s earlier ruling at the moment of decision. How counsel ruled the last time a declaration met a contradicting certificate is shown before the manager chooses.
- A reason on each decision. The manager answers from the documents, asks for time or holds the reply, and the record shows the reason code and why.
- 08Counsel review
Prior disclosure decided by counsel before the CF-28 response is certified
- Legal sentences routed to counsel. Any sentence telling CBP something was reported wrongly, or saying what the importer will do, is read, edited if needed and signed by counsel.
- Disclosure decided before certification. Counsel records prior disclosure first, with the reply, or none; certification stays blocked until a second person confirms it.
- Privileged notes kept out of the reply. Counsel’s notes are left out of citations and attachments, and the evidence binder lists them as excluded.
- 09Sign and file
Four sign-offs on the CF-28 response, the last one the broker’s filing in ACE
- Preparer, counsel, company official, broker. Each signature states what it means, and nobody certifies a reply they prepared or confirms a decision they made.
- Full reply opened before certifying. The director cannot certify until the whole reply has been opened, so the Form 28 certification rests on a reading.
- Attachments counted from the final reply. What goes to CBP lists the sentences, the attached documents and the guidance cited but not attached, with privileged notes excluded.