Continuous oversight, monitored compliance

Drawback compliance & governance.

A sustainable drawback program requires ongoing governance, not one-time setup. We continuously monitor regulatory updates, compliance guidance, and CBP requirements to keep your program aligned, defensible, and audit ready as trade conditions and activity evolve.

Apollo · Compliance Monitorall current
Privilege applications currentOK
Recordkeeping, 5 year retentionOK
Quarterly SOP reviewDue
Data reconciliation and controlsOK
Regulatory change trackingOK
Reviewed continuously against CBP requirements
Ongoing governance

Governance is a practice, not a project.

Four disciplines keep your program aligned as regulations, trade conditions, and your own operations change.

Regulatory Monitoring & Guidance

We stay current on the regulatory landscape and translate changes into practical program actions.

  • Ongoing monitoring of CBP regulations, guidance, and policy updates
  • Assessment of impact to existing privileges, rulings, and methodologies
  • Advisory support on regulatory changes affecting eligibility or recovery
  • Clear communication of required adjustments

Periodic Data & Claim Reviews

Regular program reviews help ensure accuracy, consistency, and continued compliance.

  • Scheduled reviews of your drawback program
  • Validation of claim logic, quantities, and values
  • Identification of trends, anomalies, and emerging risks
  • Recommendations for corrective action when needed

SOP Maintenance & Improvement

As your business and trade flows change, procedures must evolve with them.

  • Periodic review and refinement of drawback SOPs
  • Updates to reflect regulatory changes and operational shifts
  • Reinforcement of roles, responsibilities, and controls
  • Alignment with audit expectations and best practices

Proactive Risk Detection

We identify and address risks before they become compliance issues.

  • Early detection of data inconsistencies and control gaps
  • Assessment of events impacting claims, including amendments and corrections
  • Support for corrective actions and disclosures, when required
  • Ongoing strengthening of internal controls

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