What's the difference between an evaluation and an audit?

An evaluation is your own internal review, run on your schedule to find and fix gaps. A customs audit is CBP’s examination of your compliance, run on the government’s terms. A good evaluation program is the best preparation for the audit you don’t control.

How is an evaluation different from a one-time checklist?

A checklist confirms a policy exists; an evaluation tests whether it’s followed by sampling real transactions and the records behind them. The evidence — not the policy — is what passes or fails.

Should we use outside counsel for the evaluation?

It depends on your risk and resources. Outside counsel adds independence and can preserve attorney-client privilege over sensitive findings, which an internal review generally cannot. High-risk programs often justify the cost.

What do we do with the findings?

Build an action plan: each gap gets a fix, an owner, and a deadline, ranked by risk. Then re-test the corrected areas to confirm the fix worked. Findings without follow-through are a liability if a regulator later finds you knew. An honest evaluation surfaces the gaps you’d rather not find — which is exactly why it’s worth doing before CBP does it for you. Reidel Law Firm runs independent trade compliance reviews and delivers a prioritized compliance memo on a flat fee. Get a trade compliance memo.

INTERNATIONAL TRADE LAW

How to Evaluate Your Trade Compliance Program

Schuyler 'Rocky' Reidel July 13, 2023 4 min read

Evaluating a trade compliance program means testing whether your written policies actually hold up in practice — by pulling real transactions, checking the records behind them, and finding the gaps yourself before a regulator does. A binder of procedures proves nothing; an evaluation proves whether the procedures are followed. This guide covers what to test, how to run the review, and how