Whether you’re part of the Great Resignation, quietly quitting, or just career cushioning, you may find yourself in the following scenario someday: It’s your first day on the job as the new Trade Compliance Manager for ABC, Inc. Where do you go? What should you do? Who should you see? Perhaps most importantly, how will you know if you’re hitting your milestones?
Stepping into a new company environment can feel overwhelming, even if you have years of import/export compliance experience. We’ve put together a roadmap to help you start (and stay) strong in your new role. Think of this as a “30/60/90-day” plan for trade compliance success.
The first 30 days: Getting to know you
Starting at a new company can feel daunting. They are learning new systems, and understanding the company culture … not to mention all their internal acronyms! As a new trade compliance manager, your efforts during the first 30 days should be focused on learning the company’s compliance system as it exists today. (They do have a compliance program. If not, we may need to make some immediate changes.)
Some ideas to help during this time:
Conduct a general overview of current policies, procedures, forms,, and documents to facilitate import/export compliance. Are there any glaring errors? Any “quick wins” you could make with a simple change? At this stage, you aren’t looking to boil the ocean. Not even rock the boat.
Your goal is to understand (as best as possible) the existing compliance structure (or lack thereof). Make notes on areas that may need attention and start developing a plan.
If you spend too much time behind closed doors reading policies, people might wonder what’s up. It’s essential to get out there and meet with the people who touch compliance in some way during their day-to-day jobs. As you wnow, just because a policy exists doesn’t necessarily mean it’s being followed. (Or followed in the right way.) Schedule time and get to know these people.
Ask open-ended questions and let them fill in the gaps with their knowledge of how they do trade compliance.
The list of departments will vary from one company to the next, but typical job functions include: Procurement, Sales, Shipping & Receiving, Legal, HR, IT, Engineering ,and Quality.
3. Management Support
While you’re getting to know those functional roles that interact with trade compliance, it’s also a good idea to meet with the highest management level (reasonable for your role). Discuss the importance of import/export compliance with them. Ask if they have any problem areas that need attention. Ensure you have their support as you step into this new role.
4. Review Sample Shipments
Gather together a group of documents for a typical import and export shipment. (Someone keeps these documents, right? If not, we may have identified our first compliance “gap” that needs to be addressed.) Review these for accuracy and errors.
Create a list of the required information and crosscheck it with the sample documents. Is anything missing? For example, are the values the same for the same items? What about the USML/ECCN and HTS codes? Is there consistency here? Are licensed shipments handled according to the provisos of the license? Are these tracked against end user, quantity, and value? What about AES/ACE filings?
5. Expect to Hear
During this phase of your new role, expect to hear many people say: “We’ve always done it this way.” That’s OK. You don’t need to correct every little mistake or show people all the ways they’re getting it wrong. Make allies and let people know you’re here to help.
Days 31—60: Laying the groundwork
By now, you’re learning the terminology, and you’ve figured out how to use the fancy espresso machine in the breakroom. Good work! Take this time to develop plans and forge deeper relationships with the people who will help you execute your vision. Resist the urge to drop a brand-new compliance program on everyone without any notice or buy-in.
Some milestones to think about:
1. Management Policy Statement
Does the company have one? Should it be updated? Does it address ABC Inc.’s commitment to compliance? Discuss with your leadership and create one as appropriate. Management commitment is one of the most important aspects of any Import/Export Compliance Program. This can be a helpful tool to send out in advance of any future changes you might make.
2. Putting Out Fires
We’ve all been here. As people get to know you, they’ll come around with the daily “emergency fire” they need you to put out. Trade compliance is undoubtedly about getting products in (or out) the door in the most efficient and compliant way possible.
Just realize that not everything is an actual “fire” that requires you to drop everything. During this stage, understand the real priorities and what can wait. Try to respond, not react.
If you spend all your time reacting to everyone else’s problems, you’ll wind up with no time to implement the big-picture changes and goals on your list.
3. Forge Relationships
Continue to develop relationships with the key personnel responsible for trade compliance. You should have some ideas about what you’d like to change by now. Ask those people for input. “What would it look like if we did this? How would that change your operations? Would it make things better or worse?”
If you obtain buy-in from people and have a say in what’s happening, they will be more likely to support your initiatives and execute your plan to improve the trade compliance functions across the organization.
4. Create an Implementation Plan
From your assessment, develop a plan to implement all the corrective actions. Share this with your functional leads. Please give them a preview of what’s coming.
5. Evaluate Training
Now would be a good time to review the company’s training materials. Are they outdated? Are they being delivered to the right audience with the right learning objectives? Are there knowledge gaps that need to be addressed?
6. Expect to Hear…
You might start to hear: “Why are we changing something that isn’t broken?” Help people understand that the company isn’t changing for change’s sake. This is about improvement.
Let them know that you’re on the same team and, by working together, they can help the company mitigate compliance risks and become more efficient.
Congratulations! You’ve spent weeks preparing, and now it’s time for the big reveal. During this phase of your new Trade Compliance Manager role, you’ll be rolling out improvements and new systems to help ABC Inc. comply.
Worthwhile goals to consider:
1. New Compliance Program
Finalize your complete review of policies and procedures. Begin executing your implementation plan. Avoid sending the program out to everyone and saying, “Let me know if you have any questions.”
Instead, hold meetings with each group affected by the compliance program. Explain what’s changing for them and what’s staying the same. Let them know you’re here to help.
2. Implementation Training
This is also when you can address any training deficiencies identified earlier. Spend time training people on the elements of the new program that apply to their jobs. They don’t need to be an expert on the entire program. (That’s your job!)
Instead, people want to know what needs to be done differently and how to do this. They’ll also want to know they have a resource to go to for questions or help.
3. Advisory Board
As appropriate for your organization, consider establishing a Trade Compliance Advisory Board. This is an opportunity to hear from stakeholders about what’s working and what can be improved. Hold monthly or quarterly meetings with this group. (Bonus points for making the meetings fun! We recommend donuts.)
4. Expect to Hear
In a perfect world, you should hear people saying: “Great job! You’ve helped us. I don’t know how we did this before without you!” Give yourself a pat on the back. You might also receive pushback or conflict from people who still want to do things the old way. Lean into that conflict, but don’t lose your cool.
Always stay professional and respectful. Remind people of management’s commitment and how you’re hear to help. Sometimes, those difficult discussions can turn out to be the start of great relationships and improvements you never even considered before! So, don’t shy away.
Continued improvement for Trade Compliance Managers
Now that you’ve made it the first 90 days into your new role as a Trade Compliance Manager, you can kick up your feet and coast … right? Ha! It would be nice. However, compliance is a day-to-day, ongoing activity at ABC Inc.
Keep pushing forward, staying updated on the changing import/export regulations. Talk to people and be sure to audit/assess your program along the way. Consider bringing in a consultant for fresh perspectives and ideas. (Best practice is to have an outside audit of your trade compliance program every two or three years.)
Following this plan will help you establish yourself as a valued compliance resource within the organization, and set the stage for years of success in your new role.
Tom Reynolds is the President of Export Solutions, a consultancy firm which specializes in helping companies with import/export compliance.